ML20206M012
| ML20206M012 | |
| Person / Time | |
|---|---|
| Issue date: | 05/05/1999 |
| From: | Advisory Committee on Reactor Safeguards |
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| References | |
| ACRS-T-3077, NUDOCS 9905140164 | |
| Download: ML20206M012 (285) | |
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C) OFFICIAL-TRANSCRIPT OF PROCEEDINGS )
NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
Title:
MEETING: 462ND ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
TRC4 .ACRS:
RETURN CRIGINAL TO BJWHITE M/S T 2E26 4 : =. 7 : :e O -8 :
Docket No.:
Work Order No.: ASB-300-768 r51 g
4 990505 T-3077 PDP -
LOCATION: Rockville,MD l
DATE: Wednesday, May 5,1999 PAGES:1 - 213
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DISCLAIMER UNITED STATES NUCLEAR REGULATORY CCMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MAY 5, 1999 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory
[)
\_s Committee on Reactor Safeguards, taken on May 5, 1999, as I reported herein, is a record of the discussions recorded at the meeting held on the above date.
This transcript had not been reviewed, corrected 1
and edited and it may contain inaccuracles.
O_
1 1 UNITED STATES OF AMERICA
() 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 ***
5 462ND ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 ***
8 USNRC 9 11545 Rockville Pike, Room T-2B3 10 Rockville, Maryland 11 Wednesday, May 5, 1999 ;
12 The subcommittee met pursuant to notice, at 1:05 13 p.m. ,
1 14 MEMBERS PRESENT:
(f~)j 15 DANA POWERS, Chairman, ACRS 16 GEORGE APOSTOLAKIS, Member, ACRS 17 JOHN BARTON, Member, 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
l
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l 2 1 1 PROCEEDINGS 2
t(-- ) (1:05 p.m.)
3 DR. POWERS: The meeting will now come to order.
4 This is the first day of the 462nd of the Advisory Committee {
l 5 on Reactor Safeguards. During today's meeting, the 1
6 committee will cover the following: Electric Power Research j 7 Institute application of risk-informed methods to in-service 8 inspection; proposed final revision to 10 CFR 50.59; safety 9 evaluation for the Calvert Cliffs Nuclear Power Plant 10 license renewal application.
11 The meeting is being conducted in accordance with 12 the provisions of the Federal Advisory Committee Act. Dr.
13 John T. Larkins is the designated Federal official for the 14 initial portion of the meeting.
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\
15 We have received no written statements or requests 16 for time to make oral statements from members of the public 17 regarding today's session. A transcript of portions of the 1
18 meeting is being kept, and it is requested that speakers use 1 19 one of the microphones, identify themselves, and speak with 20 sufficient clarity and volume so they can be readily heard.
21 Now let me begin with a few items of interest.
22 One of the item that may most interest the members of this 23 committee is that a proposed new member, Jack Siebert, who I 24 believe is in the audience -- Jack?
l 25 I think many of you have had a chance to meet and ANN RILEY & ASSOCIATES, LTD.
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1 talk to Jack. He has an impressive resume of credentials of f
2 experience within the nuclear power industry and now has his 3 own company.
4 Tom, you might be particularly interested in his 5 experience at Prairie Island.
6 DR. KRESS: Oh. Yes.
7 DR. POWERS: And so I think he brings a wealth of 8 experience to the committee.
l i
9 DR. APOSTOLAKIS: You mean Dr. Wallis will not be 10 the junior member anymore?
11 [ Laughter. ]
12 DR. POWERS: Now, we may reserve that place for 13 Dr. Wallis especially.
14 DR. APOSTOLAKIS: Oh. Bonaca. I'm sorry. I'm 15 sorry.
16 [ Laughter.) j 17 DR. POWERS: No, I think we'll reserve it for Dr.
18 Wallis. I think he'll be the permanent junior member.
19 [ Laughter.]
[ 20 DR. POWERS: For those of us who lived through it, 21 I see that Millstone II has been approved for restart, that l 22 the Clinton plant is making significant progress toward 23 restart. And again for Dr. Kress, I note the Commission is 24 considering revisions to the KI policies.
25 With those items of interest, I'll ask if any of I ANN RILEY & ASSOCIATES, LTD.
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4 1 the members have items that they would like to bring up at OG 2 this time?
3 Seeing none, I think we'll turn to the first of 4- our topics, which is the application of risk-informed 5 methods to in-service inspection. Dr. Shack, I believe you 6 are the cognizant member in that area.
7 DR. SHACK: Yes. We reviewed the EPRI application 8 of risk-informed methods to in-service inspection this 9 morning, and Mr. Mitman is going to give us a few highlights 10 of this morning's discussion and presentation.
11 MR. MITMAN: Good afternoon. My name is Jeff 12 .Mitman,-I'm the EPRI project manager on risk-informed ISI.
13 I'm going to go -- I have an overview presentation '
j 14 this afternoon that will highlight some of the things that 15 we talked about this morning.
16 I will say that the various individuals involved 17 with the discussions this morning on the EPRI project team 18 are still available for questions, so if I'm unable to 19 answer your questions, we'll ask them to come to the l 20 microphone and answer your questions.
21 The objective of the discussions between the EPRI 22 team and the ACRS are to facilitate review in concurrence 23 the EPRI methodology to support an SER in September of this 24 year. What I'll talk about this afternoon is a little bit 25 about the topical status, a little bit about the pilot plant ANN RILEY & ASSOCIATES, LTD.
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1 status, a very short presentation on the methodology itself, 2 and then some summary and concluding remarks.
(
3 The topical has been revised and submitted to the 4 NRC in June of this -- or, excuse me, let me back up. The l 5 original topical was submitted to the NRC in June of 1996.
I 6 We received RAIs on that in 1997. The RAIs were responded 7 to in 1998 after we had completed a couple of the pilots and I 8 done some additional research. That information, along with 1
, 9 an enhanced description of the bases and the procedure, 10 lessons learned from the pilots and resolutions of questions 11 and comments from the NRC RAIS, along with related EPRI 12 .research, were all rolled into the revised topical, which l
13 the ACRS members should have a copy of.
14 The expectations are to receive -- for the staff,
() 15 the NRC staff to write a draft SER in the middle of June of 16 this year, and our hope is to have an SER from the NRC by 17 the end of September of this year.
18 The pilot plants, there are two slight variations 19 to the methodology. One applies ASME code case N-560 and 20 the other N-578. The N-560 approach is applied only to 21 class 1, while N-578 can be applied to class 1, 2, 3 and 22 non-code piping.
23 The first plant to be submitted was Vermont 24 Yankee, which is a class 1 submittal. It was the first l 25 plant to receive an SER in the risk-informed ISI arena.
I O
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1 The ANO2 was also submitted last year. It
(~') 2 received an SER in December of last year and that's a full V
3 plant submittal.
4 ANO1, which is a class 1 submittal, was submitted 5 back mid-year last year. We're currently in the process of 6 answering RAIs from the staff, and those should go into the 7 -- back to the staff in a week or so.
8 Fitzpatrick is the other full plant submittal.
9 That's 14 systems. Final submittal preparation is in 10 progress. The work is essentially complete with the 11 exception of putting the submittal together.
12 Braidwood in the final four plant pilots are all 13 class 1 only applications. Braidwood, a Westinghouse unit, 14 is about 80 percent complete. South Texas is approximately
, ( ,) 15 75 percent complete. That's also a Westinghouse unit. And 16 Riverbend and Waterford are planned for the second half of 17 this year.
18 A short discussion of the methodology itself. The 19 first task is to determine the scope, whether we want to do 20 class 1, class 1, 2, 3, where the system boundaries are, 21 that type of thing. The two major tasks in the methodology 1 22 are consequence analysis and a degradation analysis. Those 23 take up approximately 50 to 50 percent of the total time 24 involved with it. They're independent processes that can be 25 done simultaneously or one before the other.
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7 1 Once those tasks are completed, we take a second
/\ 2 look at plant-specific service experience. We then U
3 categorize our segments into -- or our welds into risk 4 regions on our risk matrix. We then pick individual 5 locations for inspection, along with picking the individual 6 inspection methodologies.
7 Coming out of that, we do a risk impact assessment I
8 and then we finalize the program. There are two feedback )
l 9 loops, one coming out of the risk impact assessment, that if )
10 we determine the risk impact is unacceptable, we can go back 11 and re-assign or add elements to ensure that the risk impact 12 is acceptable. And there is also a feedback loop coming out
]
13 of the bottom of the process where we monitor the plant, 14 monitor what's going on in the industry with damage
() 15 mechanisms to ensure that the individual plant and the l 16 process are modified appropriately based on new experience.
I 17 The final slide I have is a slide of summaries and 18 conclusions. The revised topical has been submitted. It 19 addresses questions and comments raised by the NRC staff.
20 It's in compliance with Reg Guide 1.174 and Reg Guide 1.178.
21 The methodology has been applied to a broad range of plants 22 -- GE, Westinghouse, B&W and CE plants; it's been applied it 23 multiple architect engineers, and we have applied it both in 24 the full scope and partial scope applications.
25 Cna of the big drivers to this is that it allows O
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8 1 for significant decrease in rem exposure to the plant staff.
2 And finally, the pilots and the research that's
(}
3~ been done supports the conclusion of a negligible impact on 4 risk.
5 DR. SHACK: What's an estimated cost for the 6 implementation of a plan like this?
7 MR. MITMAN: It's fairly straightforward to cost 8 out a class 1 only application. Approximately cost is about 9 150,000 dollars. When you go to a full plant 10 implementation, it's not as easy to delineate because, one, 11 you have to tell -- you have to decide what the scope is; 12 and depending on how you look at it, the scope, you know, 13 the scope is not clearly defined. The estimate is around 14 three times the cost of a class 1 only implementation.
() 15 DR. POWERS: What drives the cost?
16 MR. MITMAN: What drives the cost? The reason the 17 costs are so much higher on class -- on a full plant 18 implementation are -- there are two reasons: one, the 19 number of inspections that you're looking at is three or 20 four times higher. Also, with the class 1 implementation, 21 most of the analysis is inside containment where we've 22 already taken into consideration -- or the design is already 23 taken into consideration spacial effects. You get out into 24 class 2 and class 3, you break a pipe in-service water or 25 CCW, it can go off and affect other systems. So we have to O ANN RILEY & ASSOCIATES, LTD.
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9 1 do a lot more work, a lot more tension to cross system 2 analysis.
3 DR. POWERS: System interactions and whatnot.
4 MR. MITMAN- Yes.
5 DR. POWERS: What drives the risk? You said it 6 was a negligible increase in risk.
7 MR. MITMAN: Because of the implementation of the 8 program?
9 DR. POWERS: Uh-huh.
10 MR. MITMAN: We've done analysis where we can show !
11 that eliminating all the inspections has negligible impact 12 on risk, so by changing the inspection locations and 13 optimizing them on risk, typically we're seeing a small 14 improvement en risk. But the probability of failure of the
() 15 piping systems is fairly low to begin with.
16 DR. POWERS: The fact that you can eliminate all 17 the inspections and not make any impact on risk, is that a 18 statement concerning the reality of the reliability of 19 piping, or is it a statement that deals with the 20 inadequacies of the risk assessment tools?
21 MR. MITMAN: It has to do with the -- the piping I 22 is very reliable. The typical failure frequencies that l 23 we're seeing on an individual weld are -- I think the highs l
l 24 are in the neighborhood of 1E to the minus 4 on a weld, and 25 to goes down from there, probably averages per weld around ANN RILEY & ASSOCIATES, LTD.
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10 l' 1E to minus 5, 1E to the minus 6. So the piping is already 2 very reliable.
3 As far as the accuracy of the PSA and its ability l 4 to answer the questions, we've done quite a bit of 5- uncertainty analysis and we feel very comfortable that even i 6 though there is significant uncertainty in the question --
7 in the answers, that the answers are -- we're erring in the 8 conservative direction and we're not significantly 9 underestimating the risk.
10 DR. POWERS: We've seen a lot of components within
)
11 the plant, and to be discovering degradation mechanisms with 12 nice little three-word -- three- or four-letter, 4 13 five-letter, six-letter initialisms, depending on what I
14 variations of stress corrosion cracking you're talking )
15 about, how do the PRAs accommodate the possibility of 16 heretofore undiscovered but feasible degradation mechanisms 17 affecting pipes?
18 MR. MITMAN: The EPRI methodology is based upon 19 service experience, so we're not trying to predict a new 20 damage mechanism that we haven't seer in the past; i 21 therefore, any new damage mechanism that would appear would 22 -- is planned to be caught by this feedback loop that we've 23 got in the process. We'll continue to monitor what's going 24 on in the industry and capture insights that way. We're not 25 trying to predict a new damage mechanism.
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i 11 1 DR. POWERS: It seems to me lots of the corrosion 2 effects, degradation of piping due to corrosion, are very, 3 very sensitive to the water chemistry.
4 It seems to me that there are lots of 5 opportunities for human error in adjusting that water 6 chemistry. Why doesn't -- is that the common mode failure 7 mechanism that comes in, human error and water chemistry?
8 MR. MITMAN: Water chemistry is certainly taken 9 into consideration as part of the analysis. Each of the 10 damage mechanisms has laid out deterministic criteria that 11 looks at water chemistry and operating condition of the 12 piping, and out of that comes susceptibility determination 13 for that damage mechanism on the appropriate piping. So in 14 that sense, it is. considered. It's not rolled back into the
() 15 16 consequence analysis. The consequence analysis is a
' conditional core damage probability that assumes that that 17 pipe segment fails.
18 DR. POWERS: I guess what I'm asking is, what is 19 the likelihood that you have a human error that results in 20 an inappropriate water chemistry in the plant that leads to 21 corrosion, and how do you take that into account in the PRA?
22 MR. MITMAN: We haven't looked at the probability l 23 of acts of omission or acts of commission in the operation 24 of the plant. It is not factored into the PRA analysis 25 that's done. There is a feedback on operating conditions O
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12 1 into the degradation analysis, though there is no -- there 2 is no attempt to identify lack -- or acts of commission or
}
3 acts of omission in it.
4 DR. POWERS: I guess I don't understand how you 5 can do a risk analysis without taking that kind of human 6 error rate into account.
7 MR. MITMAN: I'd like to get a response from one 8 of the team members on that.
9 MR. FLEMING: This is Karl Fleming from ERIN 10 Engineering. I think the answer to the question is that in 11 the EPRI methodology, the PRA is not used as a tool to 12 estimate the likelihood of pipe ruptures. The tools that 13 are used to estimate the likelihood of pipe ruptures is to 14 deterministically examine the physical conditions necessary l'
\_
15 for degradation mechanisms. The PRA is used to evaluate the 16 consequences of pipe rupture in terms of given that pipe 17 rupture is assumed to occur, what would be the consequences l l
18 in terms of operability of plant equipment and flooding l 19 effects and so forth on the plant.
20 So we don't really try to use the PRA to predict 21 the likelihood that human errors create piping conditions; 22 however, human-induced -- human-caused failures are evident 23 in the service experience. When you look at the service 24 experience of piping failures, you know, there are some 25 events that are attributed to human error.
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T 13 1 DR. APOSTOLAKIS: But let me follow up with a
'2 question. The question I thought -- part of the question
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3 was whether, if you ever come across failure, in which case l 4 you could have more than one segment affected by the 1
l 5 mechanism, in which case, your estimation of the 6 consequences would take that into account.
! 7 You put down individual segments, not 8 combinations; is that correct? Is it possible to have only L 9 one? j
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10 MR. FLEMING: Well, if there was a single problem I 11 that was creating the physical conditions for damage 1
l 12 mechanisms in two or more segments, they're going to be i 13 separately picked up. So if there was a --
14 DR. APOSTOLAKIS: A common combination.
() 15 16 MR. FLEMING: Well, they're going to be separately
' analyzed, and if it turns out that there is some root cause 17 .that's creating many segments to have a susceptibility to a 18 damage mechanism, that would be identified in the analysis.
19 But it's identified in a deterministic way, not a 20 probabilistic way. ;
21 DR. POWERS: I guess I'm still a little perplexed.
22 Could we go back to your viewgraph where you mentioned there 23 is no change in risk. Maybe I didn't understand well what 24 the significance of that statement is. You said this 25 supports the conclusion of the negligible risk impact.
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14 1 Maybe I don't understand what you're trying to say there.
2 MR. MITMAN: What we're trying to say with that
)
3 statement is that by going from the current ASME Section 11 4 requirements to the risk-informed implementation, you do not 5 see a significant change in risk because of that move 6 neither up nor down. There tends to be a small decrease in 7 risk because we're applying the inspections more -- in areas 8 where they're more risk-significant; however, because of 9 changing from ASME Section 11 requirements to the 1
l 10 risk-informed requirements, there is no increase -- no 11 significant increase in risk, and typically it's a decrease.
12 DR. POWERS: I guess I am not grasping the risk 13 here. You have said that you use the PRA to assess the 14 consequences, and what I think one would like to know here n
() 15 is what the change in probability of rupture times those l 16 consequences would be.
17 MR. MITMAN: You are correct. The original i 18 analysis or the flow chart of the analysis shows a l 19 consequence analysis there that's looking at conditional 20 core damage probability and conditional large early release 21 probability. However, down at the bottom is a risk-impact 22 assessment that's being performed, and out of that 23 risk-impact assessment we gather the evidence to be able to 24 make that claim.
25 DR. POWERS: But this risk assessment that you've I
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15 1 done, despite the operational experience that human errors 2 can cause degradation, doesn't address that aspect. It's 3 just not taken into account.
4 MR. MITMAN: The impact of -- I'll have Vesna 5 address that.
6 MS. DIMITRIJEVIC: Well, Karl already talked about 7 that, and I just want to point out, and if you put the risk 8 matrix, maybe that will help us in the discussion, 9 The consequence analysis and degradation analysis 10 in this matrix which determine leaks are done completely 11 independently. So the consequence analysis from the plant's
, 12 point has all the human reactions which the plant needs to 13 survive accidents given the pipe break.
14 Now when it comes to the human action which
() 15 creates or can influence pipe breaks, that analysis wasn't 16 done specifically, because we assume that that was already 17 included in the data which we look in. So whatever 18 degradation which we have, if there is a human action which 19 contributes to this likelihood, that was already reflected 20 through the data.
21 Also we should note that once when -- and Pete, 22 maybe you can tell us about once when they discover failed 1 23 you did certain degradation mechanism which can result in 24 common cause data. It's this program proposed to go and 25 look at other locations which are exposed to the same 1
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16 1- ' conditions. So we don't expect that these failures are
, 2 going to happen instantaneously, but if one of them fails, 3 we're going to go and look in the similar locations and make 4 sure it doesn't happen on those locations.
5 DR. APOSTOLAKIS: I guess one question that comes 6 to my mind is can what Dr. Powers said go undetected for a 7 long time? Can the chemistry of the water be off and 8 allowed to corrode the pipes, for example, or there are 9 other mechanisms for catching it?
10 MR. MITMAN: There is plant systems or processes 11 to monitor chemistry, and those processes would apply 12 whether you're using ASME section 11 --
13 DR. APOSTOLAKIS: Sure.
14 MR. MITMAN: Inspection criteria or these
() 15 inspection criteria. If that went undetected, then most of 16 the damage mechanisms would exhibit themselves as a gradual 17 change in wall thickness or crack growth, and we should 18 begin to see the effects of that on the plant.
19 DR. APOSTOLAKIS: So it's not just a probability 20 of committing the error. You have to include in the 21 calculation the probability of catching it. And since the 22 degradation mechanisms operate at a relatively slow time 23 scale --
24 MR. MITMAN: Right.
25 DR. APOSTOLAKIS: The probability of catching it, O ANN RILEY & ASSOCIATES, LTD.
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17 1 I suspect -- I don't know -- would be pretty high.
2 MR. MITMAN: Most of the detection --
3 DR. APOSTOLAKIS: Is that correct, from the plant 4 people?
5 DR. BARTON: I agree.
6 MR. MITMAN: Moct of the detection of the events 7 is going from leaks that are being picked up by 8 leak-detection systems or pressure leak testings and 9 walkdowns of systems. That's how we've found leaks in the 10 past. Typically you're not finding leaks by nondestructive 11 examination.
12 DR. POWERS: So we want them to have bad chemistry 13 so we can pick it up quickly by detecting leaks.
14 DR. SHACK: No , I mean, he monitors water 15 chemistry in the primary and secondary --
16 DR. POWERS: I grant you that they monitor it, but 17 there is clearly the opportunity for a failure of that 18 monitoring process. I mean, something goes wrong in the 19 course of doing the monitoring, and it seems like, I mean, 20 one of the concerns you have, maybe not in connection with 21 this particular issue, but in general, is if we hide that 22 failure of -- control the water chemistry within the pipe 23 damage frequency, you know, just lump it all together and 24 hide it in there, then when we come through and we use this 25 PRA to say what are the risk-important systems in this, the ANN RILEY & ASSOCIATES, LTD.
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18 4 1 monitoring of water chemistry is effectively hidden from us,
/~Sg 2 and we attribute everything to the integrity of the pipes, 3 when in fact what we ought to do is make sure our 4 water-monitoring chemistry is good.
5 DR. BARTON: There's a QA' program. I don't know 6 where you're coming from, Dana. You take samples, you 7 analyze them, there's a QA program on the chemistry lab, the 8 techs-are qualified, examined, et cetera, et cetera. So 9 there's ways to catch problems in the monitoring system. '
10 DR, POWERS: All that gets you down to is a 5 11 times 10 to the minus 3 probability of human error. I mean, 12 that's the best you can hope for for all those systems.
13 MR. DINSMORE: This is Stephen Dinsmore from the 14 staff.
() 15 16 We discussed the CCF problem that you could have a degradation mechanism acting on several different segments 17 at the same time, but essentially what we decided was yes, ,
18 that might be true, but you're probably going to get a 19 failure somewhere first. The whole system isn't just going 20 to disintegrate on you. And when you get the first failure, 21 a leakage or even a rupture, then that's a fairly large i 22 event, I mean, people are going to pay attention to that. I 23 It's not going to disappear in the plant records. So to get 24 a second failure or the third failure within the time frame 25 which would -- so they'd be acting together we didn't think 1
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19 1 was a real credible process. And.that's kind of why we --
2 DR. POWERS: Well, I would assume that it's driven
(}
3 by your pressure transient frequency. I mean, in normal 4 operation I think you're right, you're going to fail 5 someplace first, unless you have a pressurization wave going 6 through the system, and then you can get multiple failures.
7 I mean, water hammer of course is the classic example of 8 that, where you can get multiple failures from a single 9 event.
10 MR. DINSMORE: Due to the slow degradation and 11 then the extra kick from the water hammer.
12 DR. POWERS: Yes, you can put the extra punch into 13 it, and then it's enough to -- you just can't relieve fast 14 enough through a single break. So it breaks everything.
() 15 16 MR. DINSMORE: Supposedly when they do the consequence, they -- or I mean the degradation, they look at 17 whether they can get a water hammer. And if they can, then 18 that should bump -- that's supposed to bump the 19 categorization for the degradation to the next highest 20 category, which I'm not sure entirely addresses your
! 21 question, but it is --
l l 22 DR. POWERS: That's the mechanics of carrying it I
! 23 on. What I'm worried about is how we use PRA to hide plant 24 systems here.
25 DR. SHACK: But, I mean, these processes are slow.
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20 1 I mean, even if_you colossally screwed up the water
() 2 chemistry, I mean, the stress corrosion crack is still 3 growing a quarter inch a year. I mean, it isn't as though 4 it --
5 DR. POWERS: I understand.
6 DR. SHACK: Is going to rip through the pipe.
7 DR. POWERS: I understand. And your detection 8 frequency is zip till it gets about halfway through.
9 DR. SHACK: Well, no, but your -- I mean, the 10 chances of having your water chemistry screwed up for a 11 year, you know --
12 DR. POWERS: I would think are pretty --
13 DR. SHACK: Are about 5 times 10 to the minus 3, 14 you know.
15 DR. POWERS: I think for having it screwed up for 16 a year or like you say 5 times 10 to the minus 3, having it 17 for two years, then I grant you it drops off pretty 18 dramatically there, simply because you have multiple people 19 looking at these things.
20 DR. SHACK: Well, even now, I mean, you have 21 multiple people, you have online instrumentation, you have 22 grab samples, I mean, all of that would have to get screwed
]
23 up. It's just -- it seems to me --
l 24 DR. BARTON: Pretty incredible.
25 DR. SHACK: Yes, that's --
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l_
21 1 DR. POWERS: All you're talking --
() 2 3 that one.
DR. SHACK: I wouldn't lose too much sleep over 4 DR. POWERS: All you're talking about is redundant 5 systems. We do it all the time in PRA.
6 DR. BARTON: Yes, but they're not redundant, 7 online monitoring systems are different than grab samples 8 and then go to a chem lab and use an entirely different set 9 of instrumentation.
10 DR. POWERS: They're redundant and diverse, okay?
11 They still have a common cause failure probability, and it's 12 not zero.
l 13 DR. MILLER: What is the common cause there?
L 14 DR. POWERS: Probably a miscalibration.
() 15 DR. SHACK: But it's to miscalibrate your online 16 instrumentation and then to miscalibrate --
17 DR. BARTON: And then miscalibrate the chem lab 18 equipment so that they're both miscalibrated the same.
19 DR. POWERS: Actually it's extraordinarily easy.
20 All you have to do is have the calibrants wrong.
21 DR. MILLER: You're saying the calibration could 22 be at the same lab then for all of them and that would be 23 the common cause?
24 DR. POWERS: Just the standards being 25 miscalibrated.
. ANN RILEY & ASSOCIATES, LTD.
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j 22 1 DR. MILLER: I think we're grabbing at straws 2 here.
3 DR. POWERS: Well, you may think that, but I 4 happen to have run chemistry labs for years and seeing go on 5 for a year doing --
6 DR. SHACK: Now we know what the problem was.
7 [ Laughter.)
8 DR. POWERS: Okay. I mean, I've seen it. It goes 9 on where you got the analysis done AA and gravimetric and 10 they got the same numbers, they agreed exactly, and they 11 were just flat wrong. And, I mean, these things happen.
12 Why it's not in the PRA is something of a mystery to me. I i 13 mean, if you're trying to use PRA to tell you what !.he 14 risk-important systems are, why isn't this modeled? Why is i
15 it hidden in the pipe damage frequency?
16 DR. APOSTOLAKIS: Another question, relevant 17 question I guess is if you go to the tables in the report, 18 2-1 and 2-2, I guess, yes, you report 1,145 failures. Did 19 you look to see whether in some of these you didn't have --
20 maybe you didn't have an actual common cause failure, you 21 know, in other words, two things failed within a short 22 period of time, but maybe you only had one, but you had a 23 situation like what Mr. Dinsmore described where other 24 segments were close to failure but they just didn't fail.
25 In other words, does this evidence of 1,145 failures include O ANN RILEY & ASSOCIATES, LTD.
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l 23 1
1 any of this?
2 MR. MITMAN: The --
3 DR. APOSTOLAKIS: You have two systems.
4 Ultimately one fails, and that's part of the 1,145. But 1
5 maybe the other one, you know, was eroded by a certain )
6 amount and could have failed two months later. Did you 7 search for these?
8 MR. MITMAN: In the data base of 1,145 events, 9 those events are only what we categorize as failures, which 10 is leaks or ruptures. However, one of the things that we're 11 working on is an expanded data base that also includes 12 cracks and other non-through-wall events. That data base is 13 now up around 4,500 events. It's not discussed in the 14 literature at all. But there is work that's being done to
() 15 look at the non-through-wall events.
16 DR. APOSTOLAKIS: But if you want them to use that 17 experience, wouldn't you have to go a little deeper and look 18 at the mechanisms and some models of the mechanisms, you 19 know, which would contradict the advice from your reviewers 1
20 on page 225 that the reviewers agree that with a decision to l
21 rely on service experience rather than probabilistic 22 fraction mechanics?
23 I don't think you can use failure rates the way 24 you derive them if you start looking at partial erosion.
25 MR. MITMAN: Right.
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24 1 DR. APOSTOLAKIS: Because you haven't failed.
( 2 MR. MITMAN: Right.
3 DR. APOSTOLAKIS: You can't use that in any other l
]
4 way in the current system. Unless you have a model that 5 goes deeper and looks at the rate at which you remove 6 material, for example, that evidence is useless to you.
7 So you are looking now to see whether you will 8 have to go deeper, delve more deeply into this or is it just 9 a first step to get insights perhaps and then see -- then 10 defer the decision.
11 MR. MITMAN Currently we are looking at expanding 12 the database, adding more data in it to see what we can 13 learn from non-leaking events. There are no plans at this 14 point to go out and expand the model to try and predict (n,,) 15 crack growth rates or --
l 16 DR. APOSTOLAKIS: Rate of --
]
17 MR. MITMAN. Right --
l 18 DR. APOSTOLAKIS: But you are looking for this 19 kind of data?
20 MR. MITMAN: We are looking. We continue to 21 monitor the events in the industry --
22 DR. APOSTOLAKIS: Okay, so if you find 65 events 23 where you had an inch or so eroded away, then you may 24 reconsider your decision not to revisit the models?
25 MR. MITMAN: Right.
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1
[
l 25 1
1 DR. APOSTOLAKIS: Okay.
.2' DR. SHACK: But in fairness if he finds physical-j 3 conditions that produce degradation, he assumes that 4 degradation is possible through the whole piping system 5 where those conditions are present so it is common cause I l
6 failure to that extent that if this piping system is l
7 susceptible to FAC it is susceptible, and then, you know, I l 8 am not sure if the piping system busts once or it busts in 9 three places -- you know, a double-ended guillotine break is 10 a double-ended guillotine break.
l 11 DR. APOSTOLAKIS: No, but right now they find that i 12 kind of evidence, they have no place in their model to use !
13 it.
l 14 DR. SHACK: No. If the physical conditions are
) 15- such that it is susceptible -- then every segment there is j 16 susceptible to flow-assisted corrosion.
17 MR. MITMAN: When we are looking at a system we 18 look at, on the degradation analysis side, we look at the l 19 system and we break it up into ISO damage mechanism l 20 segments.
l 21 That is half of the decision on what defines a 22 segment, so we are looking at pieces of the system that have 23 the same damage mechanisms applicable to it.
! 24 Likewise, on the consequence analysis, we look at 25 continuous runs of pipe that have the same consequence, and O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
f I
l l
26 1 that for us defines what a segment is. A segment has to
() 2- have common susceptibility to damage mechanisms and common l 3 consequence evaluations, so we are looking at effecte of the 4 damage mechanisms across segments and multiple segments in a 5 1 system or among several systems. '
6 DR. APOSTOLAKIS: So let me get again a clear 7 answer from you. Do you feel that this exercise that you 8 report here is done in the name of defense-in-depth and it
-9 doesn't really have an impact on the plant or not? I am not 10 talking about the augmented flow accelerated corrosion 11 program and so on, just this ISI.
12 You say there that the program -- I mean your last ,
t !
l 13 bullet --
l l l 14 MR. MITMAN: Right. I 15 DR. APOSTOLAKIS: -- that started this whole ;
16 discussion is that there is no impact on risk. Is it your l
j 17 clear statement that this is a defense-in-depth requirement 18 whose rationale escapes you?
l
- 19 MR. MITMAN
- Are you asking why we are doing the i
j 20 methodology --
l 21 DR. APOSTOLAKIS: No, not the methodology.
l 22 MR. MIThMR: Why we are doing inspections?
23 DR. APOSTOLAKIS: Yes. In light of your last l
24- bullet.
25 MR. MITMAN: In a perfect world I think it is safe
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27 1 to say that with the current plant designs we would 2 decrease, we would further decrease the number of 3 inspections. We would not walk away from all the 4 inspections. We would continue to sample somewhere around 5 five percent of the welds to continue to monitor the plants 6 and the industry to make sure that there are no new damage 7 mechanisms or that the damage mechanisms we already have 8 identified don't change and don't accelerate, so in that 9 sense we would continue to do the inservice inspection.
10 From a probabilistic standpoint, other than making 11 sure that no new damage mechanisms occur, I think it is safe 12 to say that the probabilistic analysis does not -- drives us 13 to the conclusion that you really don't have to do a lot of 14 ISI analysis.
() 15 DR. APOSTOLAKIS: One question that I didn't get 16 to ask this morning, this worth of the subsystems, and I 17- can't find it now, of the trains, who does that? Is it the 18 PRA analyst that says it is .5 or 1 or you have a whole 19 table here of which -- that I had in front of me just a 20 minute ago. Is it Vesna that does it or Fleming or somebody 21 who doesn't know how to spell P-R-A?
22 MR. MITMAN: It would be done by a PRA expert, 23 either a contractor or by the plant PSA personnel.
24 DR. APOSTOLAKIS: So what does the engineer then 25 who uses this do?
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28 1 MR. MITMAN: The ISI or piping engineer?
2 DR. APOSTOLAKIS: Yes, d
l 3 MR. MITMAN: Once the tables are calibrated then i 4 he can apply those tables to help him to determine what !
1 5 consequence category the piping segments fall into.
6 DR. APOSTOLAKIS: I see -- so when he looks at i
7 this, and the table tells him that RCSI is .5 worth, he does 8 not question that. '
9 MR. MITMAN: At that point, no. The question 10 should have been asked earlier.
11 DR. APOSTOLAKIS: Well, I'll repeat what I said 12 this morning. I mean it is a mystery to me why we have to 13 do all this when there are simpler ways of doing it, but I l 14 guess -- et cetera.
() 15 DR. SHACK: If there are no more questions, 1 16 perhaps we can move on to the Staff.
17 MR. MITMAN. Thank you.
18 MR. DINSMORE: Yes, this is Steve Dinsmore from 19 the Staff. Are you waiting for us?
20 DR. SHACK: Yes.
21 MR. ALI: My name is Syed Ali, I am from Division i
22 of Engineering, NRR, and with me is Steve Dinsmcre from DSSA !
I 23 and NRR. What we are going to do is very briefly give you j 24 J an update on some of the changes, improvements that EPRI has l l
25 made since we approved some of their pilot plants. This
()
\ ~/
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29 1 morning and also in EPRI's discussion afternoon, they
() 2 3
already went over the status of the various stages of the submittal of the EPRI topical report, our issuance of !
4 questions and comments, and their responses.
5 In addition, we have approved at this time -- at 6 this point we have approved two pilot plant ISI submittals.
7 One was Vermont Yankee and the other was ANO 2. Since the 8 approval of the pilot plants, EPRI has submitted the final 9 topical report and there are a few items that we have 10 highlighted here that are changes or improvements to the 11 items that were included in the pilot plants.
12 Specifically,'in the pilots and in the original 13 version of-the EPRI topical report, the discussion or the 14 treatment of the augmented ISI plans was not clear. And
() 15 just for clarification, this question came up this morning j 16 also. By augmented inspection programs, we mean inspection ]
17 programs that are over and above or in addition to the ASME 18 Section 11 inspection programs.
19 In the current version of the EPRI topical report, 20 they have clarified the extent to which the various 21 augmented inspection programs will be addressed. As an 22 example, the IGSCC category A weld, which is the welds for 23 the materials that have been replaced or improved, those 24 type of welds will be subsumed or included in the 25 risk-informed ISI program. Other than that, all other IGSCC ANN RILEY & ASSOCIATES, LTD.
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e l
l 30 1 category B through G welds will be done -- will be treated i()
2 .the same way that they are being done currently in response 3 to the NRC Generic Letters and the licensee's commitment to i 4 the NRC. .
5 Similarly, the erosion / corrosion or the FAC l
6 program that the individual licensee has committed to is t
i 7 going to be unchanged at this time and not included in the
- 8 risk-informed ISI program.
l 9 The second item which is the proposed submittal of 10 templates, a little bit of background on that is that the 11 staff issued its Regulatory Guide and Standard Review Plan 12 late last year. Around the same time we also approved the 13 Westinghouse topical report and three of the pilots, one 14 based on the Westinghouse methodology and two based on the l _j 15 EPRI methodology. I 16 Subsequent to that, staff and industry had several 17 discussions and decided mutually that it will be beneficial
- 18. if the staff and industry can agree on a submittal which is 19 a simplified submittal as long as the submittal states 20 clearly that it is in compliance with either the 21 Westinghouse methodology or the EPRI methodology and, 22 basically, give exceptions to those methodologies, if any.
23 So, .therefore, we agreed on a template or a simplified I
24 submittal that should expedite the staff review. So the 25 revised EPRI topical report includes that proposed template.
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i 31 1 The third item on this slide is that --
() 2 DR. APOSTOLAKIS: So this is simplified now to the 3 extent that one does not even have to have heard the word 4 PRA to use it? We have completely eliminated PRA from this? l 5 MR. ALI: Well, it is --
6 DR. APOSTOLAKIS: You don't have to respond.
7 MR. ALI: No.
8 DR. APOSTOLAKIS: It was just a comment.
9 MR. ALI: It is just so that if the individual 10 plant is in full compliance with the particular methodology, 11 then they don't have to give the details of the results.
12 But they are available if the staff, you know, chooses to 13 audit in a particular case.
14 MR. DINSMORE: This is Steve Dinsmore. I would
) 15 like to respond a little bit. Part of the methodology is 16 that you use your PRA to confirm that your trains are given 17 the appropriate weights and to confinn several dif ferent 18 things with your PRA, so we would assume that they would 19 have done that. They don't have to come in and say we did j 20 this, this, and this. They would just say we followed the 21 methodology.
22 Part of the template is also to give us a little 23 information about the PRA. Also to respond to al] the 24 comments which the staff has made about the PRA to date to 25 ensure that they have either addressed them or why they O ANN RILEY & ASSOCIATES, LTD.
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32 1 don't think that these have an impact on the results of
() 2 3
this.
And there are a couple of tables in there which 4 will allow us to see if there are some strange things. For 5 example, if they have CCDP for a large LOCA of 10 to the 6 minus 5, we might question why they got it that low.
7 So there is enough in there to kind of give you an 8 overview of what they used and how they used it. And if we 9 see something that we feel should be pursued, then we would 10 pursue it. But that is essentially the way we were going 11 with this template.
12 MR. ALI: 'The next item is that the pilots that we 13 have reviewed and approved so far either were based on a 14 full plant application of ISIR on a class 1 -- entire class k 15 1 part of the ASME. However, in the EPRI topical report 16 they have also now provided the choice of applying the 17 risk-informed ISI methodology on a system by system basis.
18 They have provided a slightly more strict criteria as far as 19 risk in order to provide some margin. Actually, it is about 20 an order of magnitude lower change in risk that is 21 permitted. So that is something that is different than what 22 we have approved or looked at so far, and the staff is 23 currently reviewing that.
24 Some of the changes in the risk calculations, 25 Steve will go through that.
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r 33 1 MR. DINSMORE: Thanks.
() 2 3
This is Steve Dinsmore from the staff.
l i
There's a couple of minor differences between what 4 they submitted in the pilots and what is given in the 5 topical. The first one there is there is some slight 6 changes in what the classification is for individual 1
1 7 elements within those tables. That has to do with comparing l 8 to the criteria, and we're working on that. i 9 This is just to give you an idea that there are 10 some changes and what they are, and if anything bothers you, ;
11 then you can ask.
12 There's a number of changes in the delta risk 13 calculation criteria. The first one is that they're 14 requesting not to do a delta risk calculation for class 1
() 15 only because they say they're doing 10 percent and that the 16 normal service experience indicates that you can go from 25 17 to 10 percent without increasing risk and in fact decreasing 18 risk if you select your welds with degradation mechanisms to 19 examine. j 20 We're still pondering that one, mainly because we l 21 didn't see a description of how you can compare your 22 particular plant to the generic service experience to make l
23 sure that that connection is made. They don't want to 24 include delta risk contribution for low safety significant 25 segments. There's a fairly good argument in the topical as
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)
34 1 to why they use bounding analysis to show that that probably r~'N t
)
2 won't impact the results, so we're kind of leaning towards l 3 that.
l They added these specific screening criterias on 4
5 the delta CDF and the delta LERF. The first line is system 6 level screening. If you did a full scope, you don't want to 7 get a plus delta CDF of 10 to the minus 7 or a LERF of 10 to 1
8 the minus 8. The second one was what Syed briefly j 9 mentioned, which was if you only do one system, you don't j l
10 want to get a delta CDF of greater than 10 to the minus 8 or i l
11 LERF 10 to the minus 9.
12 In general, with the risk-informed stuff, we 13 initially said you that you have to do full scope, but we've 14 been kind of moving back. With the single system, we might (O) 15 think that you might come in with a negative. That would 16 help a lot. If you came in with a positive on a single 17 system, you might come in 10 times with 10 different systems 18 and a slight positive. So there's a little bit of confusion 19 as to how that's going to work out in the end.
20 The last one is the added Markov option to the 21 original -- originally, they just said this qualitated in a 22 bounding option. They used the bounding options for almost 23 all the pilots. They used one qualitative argument for 24 LERF, I think VI did, and the other three were these 25 bounding calculations.
1
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1-35 1 They added Markov. We've just kind of gathered l
() '2 3
all the paper to review Markov.
We've got some --
It looks reasonable to us.
4 DR. APOSTOLAKIS: So you haven't approved it yet?
5 MR. DINSMORE: We haven't approved it yet.
6 DR. APOSTOLAKIS: Are we going to see it?
7 MR. 7INSMORE: The paper upon which we're going to 8 base our approval or rejection or comments, you certainly 9 can see, and you'll see the approval or rejection, whatever, 10 whenever we do that. If you would like the background paper 11 --
12 DR. APOSTOLAKIS: Are we going to write another 13 letter in the future about this?
14 DR. SHACK: Well, we haven't even seen the draft
() 15 SER yet, which --
16- MR. BARTON: We're not writing a letter this time, 17 but we will have to write one at some point.
18 DR. SHACK: I mean, that's something we can 19 discuss. But the thought this morning was we wouldn't write 20 a letter because they're still coming up with a draft SER in 21 June.
22 DR. APOSTOLAKIS: And the SER will include your 23 decisions and the major changes?
24 MR. DINSMORE: Correct.
25 DR. SHACK: Or open questions if there's open ANN RILEY & ASSOCIATES, LTD.
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r- o 36 1 questions.
I
() 2 3 questions.
DR. APOSTOLAKIS: So at that time, we may ask And-is EPRI coming back then, or that will 4 depend on what we.want to do at the time? Okay.
i l
5 MR. MITMAN: This is Jeff Mitman from EPRI.
l 6 We'll come back as necessary. We're planning to 7 come back in either July or early September.
8 DR. APOSTOLAKIS: Why -- I mean, maybe there's j 9 something I'm missing here -- why do we have an augmented l
10 FAC program and then risk-informed ISI?
11 DR. SHACK: In a way, augmented was, you know, the l 12 first -- when you realize the ASME code wasn't looking in 13 the right places --
l 14 DR. APOSTOLAKIS: Right.
() 15 DR. SRACK: --
the initial reaction was to tell l 16 them to go look in the right places. That was the augmented l
l 17 program. You know, that's one of the reasons the ASME l '18 doesn't find things, is it's the augmented program that's i
19 looking -- l 1
l 20 DR. APOSTOLAKIS: Right. I 21 DR. SHACK: -- where the action is.
l 22 DR. APOSTOLAKIS: But we will have the augmented 23 and this? That's what I was given to understand this 24 morning.
25 MR. DINSMORE: Right.
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37 1- DR. APOSTOLAKIS: And why is that? I mean, this 2 seems,to address FAC and other things as well,
- 3 MR. DINSMORE
- One of the things this allows you i
to do, which is in the new topical, is you can use your 4
5 augmented inspections as Section 11 inspections. So if 6 you're doing 10 percent augmented inspections on your 7 primary, you probably end up -- if you've selected those 8 right, you might change some of those because now you're 9 considering risk consequences, which I'm not sure they did 10 when they did the augmented.
11 DR. APOSTOLAKIS: So they will be combined? Is 12 that what you're saying?
13 MR. ALI: Well, what they're not doing at this 14 time is since we feel that the augmented programs are 15 appropriate and should continue, so -- at least these two 16 programs, the FAC and the IGSCC B through G, they're not l 17 going to reduce those inspections, they will continue what 18 the industry and the staff has agreed to do, at least at l
19 this time.
20 DR. APOSTOLAKIS: So what's the purpose of this, j 21 then? I mean, what's the logic behind not combining them, 22 and say, you know, we did this because we realize that 23 Section 11 was not perfect, but now that we have this new RI 24 ISI, we don't need that augmentation.
25 MR. ALI: There are certain programs that are ANN RILEY & ASSOCIATES, LTD.
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38 1 taking place. For example, for IGSCC, there is a dialogue
() 2 between the BWR Owners' Group and the NRC which was going on I 3 on a parallel path because of the experiences that have been 4 learned on that to revise that program or possibly revise 5 that program.
6 The main thrust of these -- of the Westinghouse as 7 well as the EPRI program has been that the ASME inspections 8 are a little bit t.oo much, maybe not beneficial to the 9 extent that the inspections are done, that those inspections 10 can be done in areas which are more prone to finding defects 11 and to a lesser extent. So the main emphasis has been to 12 actually revise or change the ASM~d criteria, at least as a 13 first step.
14 I mean, you know, alto keep in mind that right
{
fs
( ,) 15 now, this program is only being applied to piping and 1
16 nothing else, so, I mean, whether that will be done in the l
1 17 future or not also is something that the industry will 18 probably be looking at. Actually, they are looking at that.
19 So we consider this is a first step, this is how it has 20 started out.
21 DR. SHACK: It's the path of least resistance.
22 DR. APOSTOLAKIS: Would you explain that in --
23 DR. SHACK: Well, it's --
24 DR. APOSTOLAKIS: -- common English?
25 DR. SHACK: Rather than having --
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39 l 1 MR. BARTON: Explain it in PRA terms.
2 DR. SHACK: Rather than having to go past the 3 augmented inspection, you know, you just ask for what seems 4 relatively easy to get at the moment. They'll be back 5 trying to put it al] together. The frame work clearly --
6 DR. APOSTOLAKIS: So eventually, they will put 7 everything together?
8 DR. SHACK: Yes. I'm sure they will in the -- you ;
9 know, well, as much as one can foretell the future, yes.
10 DR. APOSTOLAKIS: Are there any plans for that?
11 MR. ALI: Yes. Like I said, the -- we know that !
12 for IGSCC, there are discussions on what is the best way to 13- devise the program, whether it should be based on risk or 14 deterministic experience. But that's something that's going I 15 on.
16 MR. DINSMORE: You see, Dr. Kress mentioned this 17 morning that the augmented programs are already for costs.
18 The ISI ones were not for cost. So the augmented programs 19 are already looking for degradation mechanisms, so it's not 20 as clearly a better idea to change them kind of quickly and 21 easily like we're doing this with the ISI, the ASME Section 22 11. So they can do the Section right now and it saves them 23 a lot of man rem exposure and all this stuff, and so it is, 24 as you said, it's least resistance.
25 MR. ALI: But it moves quickly.
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40 1 Pete?
() 2 3
MR. RICCARDELLA: Yes. 'This is Pete Riccardella from structural integrity.
4' I think, you know, the overall approach of this 5 risk-informed ISI approach is to look at the places where 6 there are degradation mechanisms that are applicable, and we 7 considered 10 or 15 different degradation mechanisms --
8 IGSCC,.FAC, thermal fatigue. You've seen the list of them.
1 9 And as we went through this, we concluded that, well, the i 1
10 IGSCC and the FAC are already being covered adequately and 11 there's and need to reinvent that wheel, but all of these 12 l others aren't being considered.
13 So as we go through the process, we do consider.
14 locations as to whether they're susceptible to FAC or
) 15 whether they're susceptible to IGSCC, and if we conclude 16 that, we say, well, they'll continue to be inspected in 17 accordance with the current augmented programs. But it's I 18 all the other things that we pick up, thermal fatigue and i 19 the others, that we're addressing in this process. l 20 DR. APOSTOLAKIS: But the existing programs are 21 not risk-informed, are they?
22 MR. RICCARDELLA: Well, they --
23 DR. APOSTOLAKIS: The existing IG --
24 MR. RICCARDELLA: In general, they didn't consider 25 consequence, but they did -- they're risk-informed from the O ANN RILEY & ASSOCIATES, LTD.
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41 1 standpoint -- they're doing the same thing that we're doing
() 2 on the degradation mechanism side -- that's determining 3 whether the degradation mechanism is applicable. In 4 general, they didn't consider the consequence side. ;
5 But the IGSCC -- it's all class 1s, so it's all 6 fairly high consequence anyway, and the FAC -- well, as we 7 go through it, if there's FAC in the systems that we're 8 applying it to, we take a consequence look at it as well. ,
9 DR. SHACK: Again, Tom, George and Dana weren't 10 here this morning. I guess the rest of us had more or less 11 tentatively come to the conclusion that we probably didn't 12 need to write a letter this time unless people had some i 13 major objections or major points that they felt we needed to 14 make, and I guess perhaps that's something we can either
( 15 discuss later or.if somebody sees a reason that we need a 16 letter now, --
17 DR. APOSTOLAKIS: When will we get the staff's --
18 DR. SHACK: The SER, draft SER?
19 MR. ALI: We currently plan to have a draft SER 20 which might have -- may or may not have some open items 21 sometime in June.
.22 DR. APOSTOLAKIS: So then we will write a letter 23 in September sometime, or July?
24 DR. SHACK: Well, we probably would write it, I 25 would think, at the final SER, unless, again, we had O ANN RILEY & ASSOCIATES, LTD.
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42 1 problems.
() 2 DR. APOSTOLAKIS: Okay.
3 MR. ALI: We expect that we'll come back again 4 once we have the SER to present that, then, you know, that 5 will be the time that we will be asking for a letter.
6 MR. MARKLEY: The other thing you'll have is the 7 benefit of the changes that EPRI might make in response to 8 that draft SER. So you will have the full package at that 9- meeting.
10 MR. ALI: We don't have anything else, unless you 11 have some questions.
12 DR. SHACK: I'll turn it back it you, Mr.
13 Chairman.
14 DR. POWERS: So what I derive from this is that
() 15 we'll leave open the option to write on the final SER, but 16 it's not assured.
17 DR. SHACK: Oh, I think we would write on the 18 final SER.
19 DR. POWERS: Oh , okay. So we will write on the 20 final SER barring complete collapse of the committee to do 21 anything.
22 DR. SRACK: Right.
23 DR. POWERS: Thank you. Okay. Which is imminent.
24 Well, thank you, gentlemen.
25 MR. ALI: Thank you.
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43 1 DR. POWERS: We turn now to one of our favorite
() 2 topics, which is the proposed final revision to 10 CFR 3 50.59, and Mr. Barton, I believe you've grown old with this 4 subject.
5 MR. BARTON: Old and ready to retire.
6 This was originally scheduled for 1:45 to 2:45.
7 Mr. Chairman, would you like me -- we'll try to get finished 8 with this as soon as we can, but we probably will not make 9 2:45.
10 DR. POWERS: No, I think this deserves our close 11 attention and with the apologies to Dr. Fontana and the 12 Calvert Cliffs, I may eat into that time. This is one of 13 our high priority activities, and I know that Eileen McKenna
~14 would resent considerably the full time -- opportunity to
() 15 present in front of this committee.
16 [ Laughter.)
17 MR. BARTON: Thank you.
18 The purpose of the meeting this afternoon is to 19 review the proposed final revision to 50.59. ACRS last 20 reviewed the proposed changes in March. The committee 21 issued a report at that time to the Chairman. The staff's 22 commission paper on the proposed final revision to 50.59 23 supplements the recommendations made in SECY 99054, 24 incorporation of results of meetings with the NEI which 25 appear to have been ben'.ficisi. in resolving the differences ANN RILEY & ASSOCIATES, LTD.
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44 1 between the staff and industry as well as informal feedback
() 2 from the Commission.
3 Major! changes in the proposed rule since we last 4
reviewed this with the staff are the addition of two new 5 criteria, which I'm sure Eileen will cover in detail.
6 In additional to the staff briefing, we'll hear 7 from NEI this afternoon, comments regarding the proposed 8 final rule. .The committee report will be developed, 9 prepared and sent to the Commission as a result of this 10 meeting.
11 At this time, I'll turn it over to the staff, Mr.
12 Dave Matthews, to introduce the speakers.
13 Dave.
14- MR. MATTHEWS: Well, you've done an excellent job
) 15 already of doing that. I think you're all familiar with 16 Eileen, who has been our senior project manager with regard 17 to revision to Part 50.59 and now associated proposed 18 revisions to other portions of the regulations who rely upon 19 similar language and similar change control processes, Part 20 72 being one in particular, and there's also a Part 71 21 implication.
22 This rule does address where we are on Part 50.59.
23 It does address changes to Part 72, and it addresses 24 potential changes in the fue.ure to Part 71.
25 The focus, though, I think is rightly on Part ANN RILEY & ASSOCIATES, LTD.
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45 i 1 50.59 as applies to operating power reactors, and we want to
() 2 3
also focus as well on criterion 7 and 8 as they're referred to in our presentation this morning. 1 4 I would indicate that the staff is still in the 5 throes of deliberation with regard to a final recommendation 6 to the Commission on implementation schedules, and the 7 attendant enforcement policy that may ensue during that 8 implementation period. So we have provided you a draft 9 package. The substance of the changes to the criteria is 10 not going to change, I can tell you that, with regard to 11 that package; however, those portions that address i
12 implementation period and enforcement policy may change l 13 before it reaches the Commission at the beginning of next 14 week. i
() 15 So just with that slight clarification, I'll turn 16 it over to Eileen.
17 DR. POWERS: Before we plunge into the details, I 18 know that part of your motivation to make changes in Part 71 19 came from public comments. Have you had any additional 20 feedback on proposing to change Part 71?
21 MR. MATTHEWS: Beyond those public comments, no, 22 but we've had some additional thoughts on a schedule for 23 doing it in our discussions with NMSS. So I think Eileen is 24 prepared to address that as well.
25 MS. McKENNA: Okay. Thank you.
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46 1 The first part, I won't belabor because I think
( 2 we've had plenty of discussion in the past. As is indicated 3 up here and was mentioned in some of the introductions, we 4 had the earlier paper, which this paper is supplementing; we 5 had a Commission meeting; and while we did not get an SRM or 6 specific votes on that,.we did have some good discussion 7 with the Commission at that meeting and the SRM and the 8 briefing and established the date of may 10th, which is 9 obviously coming up very quickly, for sending the package to 10 the Commission.
l 11 We've had interactions with the --
12 DR. POWERS: Quick question, Eileen.
13 MS. McKENNA: Yes.
14 DR. POWERS: Is it took quick for you? Is it not 15 quick enough?
16 MS. McKENNA: Well, I think it's more the latter 17 at this point.
l 18 [ Laughter.] i 19 MS. McKENNA: As mentioned, we had a number of 20 briefings with the ACRS, most recently in March, and I think !
21 we are -- the committee expressed their support for moving 22 forward the rulemaking with expression that we hope we could 23 close on these last issues with margin, which I think we 24 have been able to do.
25 As I say, what we've forwarded to you was the ANN RILEY & ASSOCIATES, LTD.
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w 47 1 final rulemaking package a week or so ago. It's had very 1
( 2 minor changes. I think David kind of illustrated the areas 3 that we're still wrestling with as to exactly what to 1
4 propose as how long to give. for implementation. I 5 There are some trade-offs between -- since we do 6 feel that on an overall basis, it provides more flexibility 7 and clarification is a reason to move faster, but when 8 you're doing rule but when you're doing rule changes and 9 people are -- want to make sure they have time to 10 familiarize themselves with everything that's been changed, 11 and have all the people brought up to speed so that, you 12 know, that is a bit of a trade-off as to exactly how long 13 you should allow for that process.
14 And we are trying to come to a final recommendation on that.
() 15 DR. WALLIS: Can I ask you about the final bullet?
16 I received a package, and it seemed to have still discussing 17 the virtues of various changes. It wasn't clear to me that 18 I could find in one place what you were proposing as the 19 actual final rule.
20 MS. McKENNA: The language is in -- is kind of at 21 the back several pages of the package.
22 DR. WALLIS: It wasn't -- I couldn't find -- this 23 is the final thing that you would like approval of. I found 24 too much still ongoing discussion of parts of it, but maybe 25 I was just too foolish to find --
l
[]
(_/
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48 1 MS. McKENNA: Well, the actual rule language is at
() 2 the back, and so it certainly is a long package, I 3 recognize, and you have to press forward I think through the 4 sections to get to -- this is language we actually proposed 5 to put into the book.
6 DR. WALLIS: Right. .
1 7 MR. MATTHEWS: The Federal Register notice itself 8 contains that lengthy discussion in the SOC which had as one 9 of its purposes to explain the evolution of our position by 10 virtue of the fact it's responding to public comment on the 11 proposed rule, so it does discuss that there were 12 alternatives considered by tne staff and the pros and cons.
13 But the actual language of the final position being 14 recommended to the Commission is included in regulatory (9
_j 15 language at the conclusion of the Federal Register notice.
16 So you have the words that the staff has recommended.
17 DR. WALLIS: You mean they are somewhere, whether 18 I have them or not. Well, we can sort that out.
19 MR. MATTHEWS: I am confident that they are in 20 that package. Whether they're sufficiently labeled as this 21 is it, I can't make a claim. But I'm confident they're in ,
22 that package.
23 DR. APOSTOLAKIS: The package we have here.
{
1
- 24 DR. BARTON
- It starts on page 116. l 1
25 MS. McKENNA: Right. The way that these things ,
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t
49 1 typically are done, you have kind of the background and
() 2 discussion of what led up to it, and then kind of here it 3 is, jump to page 116. 3 4 DR. WALLIS: Can we have before we write a letter, 5 please,.since I don't have that, a definitive package which 6 is the final rule as we are asked to sign off on it or 7 whatever we have to do?
I 8 MR. MATTHEWS: I just reassured you you have that.
, 9 DR. WALLIS: I don't, because it's not here.
i l
10 MR. MATTHEWS: Sorry, I can't make up for that 11 problem.
l l 12 DR. APOSTOLAKIS: 115? ,
i 13 DR. SHACK: 4-26-99 is the latest I have.
! 14 MR. MATTHEWS: Your colleagues have that.
15 DR. WALLIS: You have? I think this is a serious 16 thing. If you're asked to actually sign, we should have at l 17 this meeting, whether we brought it or not, a clear 18 definition of what it is we're asked to approve.
19 DR. POWERS: I think we can get that for you if we 20 need to, and in dafarance to the speaker, I think that it's 21 also worth mentioning that we have put this on a little 22 faster track than might normally be done, and it's proved to 23 be a minor bit more contentious than most. Only modestly.
24 MS. McKENNA: Just modestly, though.
25 DR. POWERS: So maybe if we can make sure that O ANN RILEY & ASSOCIATES, LTD.
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50 l 1 Graham has the exact language in front of him.
4
() 2 Yes, it's coming.
3 MS. McKENNA: Okay. Just to pick up on the last 4 bullet, which was referring to the final package, there is a 5 forwarding paper, it will be a SECY paper, that discusses 6 those areas where there may have been either some evolution 7 or change in the position, and primarily it's on the 8 criteria 7 and 8, which I will elaborate on shortly.
9 There is some -- you probably saw a section in 10 there where we talked about some of these other regulations 11 and how they fit together, in particular parts 52 and 54 and 12 71, which we're not actually changing through this 13 rulemaking, but we are noting some of the connections and 14 how they fit together, and then mention -- there will be a
() 15 section, exactly what it says, I think in the version we 16 talked about in 18 months or somewhat earlier, we're now 17 perhaps thinking of giving a flat 12 months' time frame, but 18 the Committee suggests that perhaps we could do it sooner 19 than the 18 months, and we've been looking at that.
20 I think the thinking is that 12 months is kind of 21 the right time frame to allow for the guidance to be 22 revised, for people to become familiar with what's going on 23 and to actually implement the changes.
24 DR. POWERS: Excuse me, just a little bit, between 25 the time of now --
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51 1 MS. McKENNA: Right.
() 2 3 6, DR. POWERS: And whenever the clock stops on this 12, or 18-month time period, this is not a large 4 uncertainty with respect to 50.59 --
5 MS. McKENNA: No. !
6 DR. POWERS: What are people using? j 7 MS. McKENNA: They're using the existing rule and 8 the existing processing.
9 DR. POWERS: Which is more restrictive -- i 10 MS. McKENNA: Correct. And that's safe.
11 DR. POWERS: Why aren't you willing to let them 12 take whatever time they want?
l 13 MS. McKENNA: Well, that's one of the l 14 considerations is they could take -- we're wrestling with I
() 15 whether to set a longer period of time and say if you want l
16- to follow the old rule, that's fine, because it is more 17 restrictive, and --
18 DR. BARTON: And it's worked for 30 years.
19 MS. McKENNA: And it's worked for 30 years. i 20 DR. POWERS: It seems to me that -- why do you 21 care?
22 DR. APOSTOLAKIS: The way I understood it was that 23 it was more restrictive on paper, not the way that it was 24 implemented.
25 MS. McKENNA: Well, I think --
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i 1
52 1 DR. APOSTOLAKIS: The idea of a minimum increase
()
,s 2 was actually implemented de facto.
3 MS. McKENNA: You're right in terms of the way 4 people implement and the way the words are written may not 5 have matched completely. I think the thinking is that with 6 the revised rule, there will be a better match between how 7 people generally do these things and what the rule says, and 8 for that reason, it may be better to have it sooner, so you 9 wouldn't have this, you know, perhaps this disconnect 10 between what people do and what the rule says.
11 MR. MATTHEWS: There is one additional advantage 12 to reaching to implementation under the new rule sooner 13 rather than later, and that's driven by the corrective 14 action for a violation of the existing rule is to submit an
) 15 amendment to get NRC approval of the change that you have 16 , made to the plant, and if you were to have a rule that was 1
17 more restrictive rather than less restrictive, you get more 18 of those amendments that under the new rule you wouldn't 19 have to process. So there's some motivation on the part of 20 the staff that we don't think it's --
21 DR. BARTON: You get an enormous number of those?
22 MR. MATTHEWS: We think there's an unnecessary 23 regulatory burden to submitting amendments that when the new 24 rule is implemented wouldn't have to be reviewed.
25 MS. McKENNA: It's not an enormous number. It's, ANN RILEY & ASSOCIATES, LTD.
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f ,
l l
- 1 53 )
1 you know, 10 over -- it's hard to estimate, because --
() 2 DR. POWERS: It's absolutely nothing compared to 3 the effort that you've gone to --
l 4 MS. McKENNA: That's true.
5 DR. POWERS: Develop this, i
6 MS. McKENNA: That's correct. Yes.
l l
7 DR. POWERS: Why do you care? I mean, if they l 8 want 18 months, fine, give them the 18 months. I mean, what 9 difference does it make.
l 10 MS, McKENNA: Okay. I 11 DR. APOSTOLAKIS: Done with that viewgraph?
l 12 MS. McKENNA: Yes, unless you had a question.
l 13 DR. APOSTOLAKIS: I have one. l 14 MS. McKENNA: Okay.
) 15 DR. APOSTOLAKIS- Okay. I understand the actual i 16 rule starts on page 115 l
17 MS. McKE?:s.. : Yes.
18 DR. APOSTOLAKIS: Now the first 115 pages will 19 become a public document.
20 MS. McKENNA: The whole thing is published in the !
l 21 Federal Register.
22 DR. APOSTOLAKIS: Okay. So we have to be careful 23 what we say.
24 MS. McKENNA: Yes.
25 DR. APOSTOLAKIS: Okay. On page 35 --
l
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l 54 1 MS. McKENNA: Okay.
() 2 DR. APOSTOLAKIS: I would beg you to delete the 3 sentence at the end of the top paragraph: For the final 4
rule the Commission has also substituted the term likelihood
- 5. for probability for clarity.
6 They're identical. They mean the same thing. We 7 don't want to embarrass our industry by putting statements 8 like that down. Even though it may have been done for that 9 purpose, I would delete it.
10 Page 35.
11 MS. McKENNA: Page 35, the top.
I 12 DR. APOSTOLAKIS: Page 35.
13 DR. WALLIS: Unintelligible.
1 14 DR. APOSTOLAKIS: It's unintelligible? No , it's l 15 typed.
16 [ Laughter.]
17 It says Nuclear Regulatory Commission -- are you 18 on page 35?
19 MS. McKENNA: No, I think he's looking at the rule )
20 language.
21 DR. WALLIS: I'm on page 3.
22 DR. APOSTOLAKIS: Well, you can make your comments l 23 afterwards, but what I'm proposing is that on page 35 that 24 sentence be deleted.
1 25 MS. McKENNA: Okay. We'd need to say that we're O ANN RILEY & ASSOCIATES, LTD.
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55 1 making the change. If your concern is that you don't like
() 2 the basis of clarity, we can look at that and see if we can 3 say something different.
i 4 DR. APOSTOLAKIS: I don't even know that you make l 5 the change --
l
- 6 MS. McKENNA: Yes, the change is made, f
7 DR. BARTON: On page 34, the change has already 8 been made, George.
9 DR. APOSTOLAKIS: Right. I understand that. But 10 that sentence by itself really leads to the wrong 11 conclusions and impressions, and I really don't want that.
l 12 I'm not saying don't change it.
I 13 DR. BARTON: What bothers you, the "for clarity"?
l i 14 How about they put a period after " probability"?
l 0(_j/
15 MS. McKENNA: Yes, that I can do, is put a period 16 after --
l 17 DR. BARTON: The Commission has also substituted 18 the term " likelihood" for " probability," period.
19 MS. McKENNA: Right.
) 20 DR. APOSTOLAKIS: It's much better -- I l 21 MS. McKENNA: I think that we have to state that l
22 we have made -- the change is being made, and if you don't l
l 23 like the basis, that's something we can deal with.
24 DR. WALLIS: What is the purpose of that change?
25 MS. McKENNA: I think the purpose was to try to
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56 1 get to, since we are looking at things in a qualitative O( j 2 sense, the " probability" perhaps has a suggestion of 3 numerics that " likelihood" did not, and that's --
4 DR. BONACA: That you use a PRA.
5 DR. WALLIS: Yes, but that's the ultimate in 6 quibbling. I agree with George, it's simply an attempt to 7 avoid a word which might be embarrassing.
8 DR. BONACA: Yes, and, you know, I want to say 9 that in fact you still have not solved the issue of 10 backfitting. If you go to page 36, top of the page, the 11 same issue there, look what it says: Changes that wculd 12 invalidate requirements for redundancy, adversity 13 separation, which is defense in depth, would be considered 14 as more than a minimal increase in likelihood of Q
(s,/ 15 malfunction. Which means you are dictating that.
16 Now an analyst may go in, demonstrate to you that 17 actually the probability is decreased or is maintained the 18 same. But here you're de facto ruling that there's going to 19 be an increase, and that's always a problem, because what 20 you're having, you're having a technical evaluation 21 concluding something, but you cannot conclude that, because 22 you have already prescribed that it is an increase.
23 And I can only say that by my experience it has 24 created more pain, okay, that issue, because you're asking 25 your engineer to tell you an answer to a probability ir) ANN RILEY & ASSOCIATES, LTD.
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I 57 1 increase, okay? Now, you want to call it likelihood. The
() 2 fact is, it's still a probability. So he's coming up with a 3 result. The result may be no increase. But by definition 4 it has to be an increase. And that still, that issue of 5 backfitting there is a problem.
6 MS. McKENNA: Let me see if I understand your 7 question, saying that you think it's possible that it could 8 make a change.that would perhaps remove the redundancy and 9 because of other reasons conclude that there has been no 10 change in the probability or likelihood of failure.
11 DR. BONACA: Maybe it would help me if Professor 12 Apostolakis suggested in fact that where you have 13 commitments you just create simply a verification that a j
14 commitment is maintained, okay, and you take away the I 15 reference from the probability, because what this is 16 creating is creating a conflict between verification of 17 existing commitments and a true engineering analysis that 18 you expect in a safety evaluation that will conclude 19 something, and you're saying it doesn't matter what you 20 conclude in the technical evaluation for those cases where 21 you have a commitment to this defense-in-depth criteria you 22 call it an increase. See, that doesn't go well with 23 engineers. You can't control the process inside a company.
24 MS. McKENNA: Okay. I guess what we were 25 indicating is that you felt that these principles of defense O ANN RILEY & ASSOCIATES, LTD.
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58 1 in depth were such that if you had them in your facility and p)
- 2 now you're removing them that that would be more than a j 3 minimal change in those parameters.
4 DR. BONACA: And I'm not saying removing, you may modify them, okay, and the fact is that when you modify i
5 i 6 them, for example, say that you have the separation and you l 7 change the distance between things, okay, why does it have 8 to be necessarily an increase in probability? In some cases 9 it's not because standards already exist for, you know, 10 reducing it.
11 So you see what I am trying say, there is still a 12 difficulty there in that you are using a technical language.
1 13 You are now changing the word to " likelihood," but it is 14 still probability.
Q
(_) 15 DR. APOSTOLAKIS: Yes, it is. i 16 DR. BONACA: And you have a conflict between the l
17 conclusion of a technical evaluation and what you want to l 18 backfit, which is you have to go back because you made some 19 change there in diversity, or separation, or redundancy. So 20 I don't know how we can -- you know, but, again, there was a l
21 suggestion here, Professor Apostolakis, that we would for 22 those cases simply say -- not these words, but say, in case 23 t.here are specific commitments to redundancy, diversity and 24 separation, okay, then NRC review is required. But not 25 because there is an increase in probability.
[)
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i 59
.1' DR. APOSTOLAKIS: Yeah, but that might, that
()
2 recommendation --
3 DR. BONACA: I know, but -- well, but the point is 4 that this backfitting issue is still here.
5 DR. WALLIS: Now, we must go. I am very sorry, we 6 must pursue this further because the rule is an important 7 document,_ right. Page 126, it says, " Result in more than a 8 minimal increase in the frequency of likelihood of a 9 malfunction." Not only have you changed probability to 10 frequency or likelihood, you have changed it to both 11 frequency of likelihood.
12 DR. APOSTOLAKIS: Which page are you on?
13 DR. WALLIS: 126.
14 DR. APOSTOLAKIS: 126.
() 15 DR. WALLIS: Now, what is frequency of likel.ihood?
16 MS. McKENNA: Okay. I was going to say that is --
l 17 DR. WALLIS: It is like frequency of probability.
18 MS. McKENNA: That is an administrative error and
- 19. I thank you for catching it.
20 DR. WALLIS: But it just shows the kind of --
21 DR. APOSTOLAKIS: So which one did you delete?
22 MS. McKENNA: Frequency.
23 DR. APOSTOLAKIS: Frequency of?
24 MS. McKENNA: Yes. In item 2.
25 DR. WALLIS: Oh.
J i
l l
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c.
60 1 MS. McKENNA: It is frequency for accidents and
() 2 likelihoods for malfunctions.
3 DR. APOSTOLAKIS: We are raising too many --
4 MS. McKENNA: Yes.
l
! 5 DR. APOSTOLAKIS: Let's come back to page 35, 6 MS. McKENNA: Okay.
l 7 SPEAKER: Let's stick with one item here.
l 8- DR. APOSTOLAKIS: Would you please delete then for )
i l
! 9 clarity -- ~
10 DR. WALLIS: It is all the same -- l l ,
11 DR. APOSTOLAKIS: Do you agree to do that? I I
12 MS. McKENNA: Yes, I agree to do that? ;
i 13 DR. APOSTOLAKIS: Okay. Because the other stuff
- 14 you have to leave there, so it will be a mystery to some
() 15 people why you substituted the term "likely" for l 16 " probability," but at least let them speculate.
17 Okay. Now, on page 29, you yourself seem to l 18: alternate between likelihood, probability and frequency.
l 19 Now, this is not official, I guess.
i l 20 MS. McKENNA: Well, this was kind of the L 21 discussion of how we got to minimal, and since probability 22 was the way things were being looked at, certainly as the 23 rule is presently written and in the way plants were 24 licensed, we were using that terminology.
25 DR. APOSTOLAKIS.: Listen to what you are saying l
I L
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61 1 here, 29. " System train failures were generally postulated
() 2 to gauge the robustness of the design without estimating l
3 their likelihood of occurrence. In this light, minimal 1
4 increases in probability would not significantly change the 5 licensing basis. Further, modest increases in frequency of ,
l 6 the postulated" -- so we are going back and forth. And that ]
7 is why I asked you, are you going to publish this document?
8 MS. McKENNA: Yes.
9 DR. APOSTOLAKIS: You will. So maybe a good 10 editing job would take care of this things. Because I mean 11 in probability theory, likelihood and probability are 12 identical concepts. They are the same thing. Now, if 13 engineers feel more comfortable with' likelihood or I 14 understand something different, let's not advertise that.
() 15 But when we say that we have substituted the term )
16 " likelihood" for " probability," at least let's do it 17 ourselves.
i 18 DR WALLIS: No, well, I object on principle. I 19 mean you have two words which mean the same thing, and you I 20 want to use one because you are afraid of the other one, and 21 this really is the wrong way to go about regulation, which 22 should be clear. l 23 DR. POWERS: Well, in deference to George, I l 24 happen to agree with him that likelihood and probability in 25 theory are identical concepts. But in the colloquial or the O ANN RILEY & ASSOCIATES, LTD.
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l l 62 i
1 vulgar, they are not. And the truth of the matter is that
() 2 when somebody asks me what the likelihood of something is, I 3 give them a qualitative answer. When somebody asks me the 4 probability of something, I give them a deliberately 5 quantitative answer. And it seems to me that there is a 6 distinction in the vulgar, and maybe you are drawing upon 7 that distinction here. And if so, it seems fine to me.
8 DR. SEALE: This is going to be a vulgar 9 regulation, is that what you are telling me?
10 DR. POWERS: Well, when I say vulgar, I mean in 11 the sense --
12 MS. McKENNA: In common terms, yes.
13 DR. POWERS: -- of the common.
14 DR. SEALE: I know what you mean.
(,,/ 15 DR. POWERS: Common usage.
16 MS. McKENNA: Yes.
17 DR. SHACK: Possibly not elegant.
18 DR. SEALE: Right.
19 DR. POWERS: We have a variety of words in the 20 mathematic field that have very, very specific meanings that 21 equally -- those same words get used in the common parlance 22 and don't carry that baggage with them.
23 DR. APOSTOLAKIS: Best estimate codes perhaps.
24 DR. POWERS: That might be a good -- though maybe 25 there it is the opposite, that in the common parlance, we
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63 l 1 think best estimate means something significant, whereas, in I i 2 the technical field it seems to mean anything at all.
V 3 MS. McKENNA: I think you are exactly right in 4 terms of the thinking that we were going into, because we 5 were reacting to comments and concerns about -- there was a 6 suggestion that by moving into minimal, we were looking for
- 7 numerics and we are saying, well, trying to make it --
8 DR. APOSTOLAKIS: So let's do it but not advertise 9 it.
10 MS. McKENNA: That's right.
11 DR..WALLIS: I still object. I mean if I grade 12 someone's work as incorrect or wrong, it doesn't make any 13 difference, they are same word. And if I use one because it 14 is slightly more polite than the other, it doesn't change
() 15 the substance. So you have not changed the substance by one 16 jot or tittle by changing this word " probability" to 17 " likelihood."
18 DR. SHACK: Well, then why worry about it?
19 MS. McKENNA: We are really not trying to change 20 how people go about doing their business with respect to 21 that.
22 DR. WALLIS: So why do it?
23 MR. BARTON: I think there was a suggestion that 24 came out in this committee to change that word.
25 DR. WALLIS: No, but we claimed to have fixed a
('
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l 64 1
1 problem by changing a word which makes no difference. I
, 2 DR. POWERS: It seems to me, Ellen, maybe you get i I 3 around this by bringing up this, the fact that when you use l
4 " likelihood," you are not looking for a quantitative 5 estimate that might be implied inadvertently by use of the 6 word " probability." And you get around Graham's legitimate 7 point that if you are making a change for no purpose, but, 8 in fact, I think you are making a change for a purpose here.
9 MS, McKENNA: Yes.
I 10 DR. POWERS: I mean I get the sense that you are, 11 and correct me if I am wrong.
12 MS. McKENNA: I think it is explaining a little 13 bit perhaps what we meant by the words, like on the clarity 1 14 of getting to the --
, 15 DR. POWERS: In fact, I would suggest that you l 16 draw upon what Professor Apostolakis said, that is 17 probability theory, likelihood and probability are identical 18 concepts, but in the common usage one might be considered to l
i 19 imply a quantitative estimate that is not looked for here l i
20 and, therefore, you have substituted likelihood for 21 probability.
22 MS. McKENNA: Yeah, I think that is exactly what 23 was the thinking in that.
24 DR. WALLIS: Well, I think you have to be clearer 25 than that. You have to say we have changed it because we tO ANN RILEY & ASSOCIATES, LTD.
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65 1 are not looking for a quantitative estimate, not to apply to
() 2 3
what some vulgar person might assume. That is the most preposterous way of trying to write a regulation, on the 4 basis of what some vulgar person might assume. You have got 5 to write it so it is clear to everybody, including a vulgar 6 person.
7 DR. APOSTJLAKIS: I think you can add something to 8 what Dana said, which I like to elaborate on that point, 9 that it is the intent.
10 DR. WALL!S: I will take a vow of silence on 11 frequency, probability and whatever the other word is.
12 DR. POWERS: Please don't. The chair denies you 13 the right to take a vow of silence, sir.
14 DR. APOSTOLAKIS: Okay. So you are taking out
() 15 those two words for clarity.
16 MS. McKENNA: Yes.
17 DR. APOSTOLAKIS: And you are adding -- did you 18 take all that down? Oh, the transcript.
19 MS. McKENNA: I hope so. We can get the 20 transcript, certainly.
21 DR. BONACA: ' The other thing, again, to close the 22 other issue, my suggestion was that, again, like in that i 23 statement, you would have -- on page 36, you would say i
24 changes within validated requirements, for redundancy, 25 diversity, separation, other such design characteristics
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66 1 would require prior NRC approval. You don't have to
() 2 3
identify the vehicle by which. Otherwise, you become technical and it creates problems. And I would suggest that 4 you look at other parts in this document of description 5 where you have the same thing.
6 So you are achieving what you have to achieve, but l 7 you do not call in the technical evaluation. Granted, now, 8 the likelihood word is helping there, but I think that would 9 be clarifying and helpful.
10 DR. APOSTOLAKIS: I really find those mental 11 acrobatics in --
12 DR. BONACA: Have you heard of conditional --
13 DR. APOSTOLAKIS.: Root cause, we are using 14 probability.
'( 15 DR. BONACA: Have you heard of conditional 16 likelihood? Can you say that? Conditional likelihood.
17- DR. APOSTOLAKIS: It is kind of distorting.
18 DR. POWERS: Moving right along.
19 MS. McKENNA: Yes, moving along. So what I wanted 20 to spend --
21 DR. POWERS: Wait till we get to the substantive 22 part of your discussion.
23 [ Laughter.]
1 24 MS. McKENNA: What I wanted to spend a few moments 25 was to go through what were called criteria 7 and 8 and that i
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67 1 .is if you look through the package, you see that we started
() 2 out with three criteria in the existing rule, some of which 3 are fairly complex in terms of their formulation, and we 4 split those into seven in the proposed rule, and the seventh 5 one was the criteria that was replacing the current 6 reduction in margin of safety as defined in the basis for 7 any tech spec.
8 And as it is discussed in the course of figuring 9 out what are we going to do instead of using that 10 phraseology, we came to having two criteria to try to deal 11 with kind of complementary aspects of margin, one being the 12 question of the limits that are established for which the 13 facility has to meet that, and the other being the margins 14 in how you demonstrate that you are meeting the analysis 15 piece of things. So we broke them into two pieces to be a 16 little more explicit rather than trying to back door it out 17 of whether it is a margin of safety and whether it is 18 defined in the basis for any tech spec.
19 Criterion 7 says that NRC is required for a l 20 change, test or experiment if it would result in a design 21 basis limit for a fission product barrier is exceeded or 22 altered --
23 DR. WALLIS: I'm sorry, on page 3 of the document, ;
24 the fat document, you defined design basis limit. Is it 25 defined in the rule?
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68 1 MS. McKENNA: It's not defined in the rule.
(* ) 2 DR. WALLIS: How do we know what it is if it is 3 not defined in the rule?
4 MS. McKENNA: It is discussed in the statement of 5 considerations and will be discussed in the guidance.
6 DR. WALLIS: Okay. It is discussed on page 3 and 7 it is defined on page 3 --
8 MS. McKENNA: In the paper?
9 DR. WALLIS: I am on the fat paper, page 3. My 10 notes refer to --
11 MS. McKENNA: Yes, there is -- I think you are in 12 the SECY paper, the Commission paper, page 3, I think is 13 what you are referring to. Yes, that's fine.
14 DR. WALLIS: It is a page 3 --
) 15 MS. McKENNA: Yes.
16 DR. WALLIS: And it says design basis limit -- the 17 numerical value of a parameter --
18 MS. McKENNA: Right.
19 DR. WALLIS: -- is set at a point at which 20 confidence in the capability of the barrier begins to 21 decrease. Now that to me doesn't mean anything. I mean if 22 something which is at some level and then it begins to 23 decrease, it's like being on top of a mountain and you begin 24 to go down the mountain --
25 MS. McKENNA: Yes.
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69 1 DR. WALLIS: How far do you have to go before you I~ l 2 have begun to go down the mountain?
V 3 MS. McKENNA: I think you need to back up to the 4 first sentence, which is that it's the controlling value 5 that has been defined, established for that particular 6 parameter, and that is what the limit is.
7 The second part is explaining how we usually get 8 to setting that value.
9 DR. WALLIS: A design basis limit if it is agreed 10 to by both parties that it is "x" then we know that that is 11 "x" and you don't go above that.
12 MS. McKENNA: Right.
13 DR. WALLIS: But if it is defined in this 14 wishy-washy way about it is a place where someone is I 15 confidence in some capability begins to decrease, that is 16 another one of these qualitative things that means nothing.
17 MS. McKENNA: But the sentence on the definition 18 is that it is the controlling numerical value for the 19 parameter established during the review -- exactly what you 20 said -- and it is presented in the FSAR, so the licensee 21 presents what it is.
22 DR. WALLIS: So there is agreement at some date 23 between two parties as to what it is --
24 MS. McKENNA: As to what the values are going to 25 be of how you determine for that particular parameter, f( ANN RILEY & ASSOCIATES, LTD.
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i 70 l 1 whether it is pressure or whatever the parameter is of
()
f 2 interest,.how you know that your barrier is going to be 3 maintained.
- 4. The sentence we're referring to was saying this is 5 how in concept you would get to that value as you set your 6 limit at a point --
7 DR. WALLIS: Yes, but you see, let's take an 8 analogy. It's like saying that, talking about the point at 9 which the confidence that the President of a country under 10 attack by the United States has -- begins to think that the 11 capability of his defensive barriers begin to decrease.
12 That is such a vague thing.
13 Those sorts of words should not be in regulations 14 or even as prefaces to regulations. The point of
() 15 regulations is clarity. Isn't it?
16 MS. McKENNA: What we were trying to indicate was 17 how.these values are typically developed and you develop 18 from the point of view of there's some condition or state 19 where you don't want to be and then you want to set your 20 limit at a place that you are well satisfied that you are 21 not going to be in that unacceptable condition.
22 DR. WALLIS: But we lack confidence that this had 23 been determined in a way that was not too equivocal and 24 vague.
25 DR. KRESS: Well, there's only three of these in f
i i
l l
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71 1 that first bullet.
() 2 3
MS. McKENNA: Well, I think, you know, that was only meant to be explaining how you get there. I think 4 establishing what the values are is very clear and the 5 values that we are talking about I think are also clear.
6 DR. KRESS: Everybudy knows what those are and how 7 they are established.
8l I DR. BONACA: And most of them are in tech specs.
3 DR. KRESS: They are in the tech specs.
10 MS. McKENNA: Many of them are. Yes, yes.
11 DR. BONACA: I agree that the fact that the tech 12 specs helps understand what the meaning of this phrase is.
13 [ Laughter.]
14 DR. BONACA: That would be somewhat obscure but --
() 15 DR. WALLIS: But to someone who reads it and 16 doesn't know just where to find it and finds a definition 17 like this, I find it is disconcerting.
18 MS. McKENNA: That sentence was not meant to be 19 part of the definition. The one sentence was --
20 DR. WALLIS: But it is part of the public record 21 now, isn't it?
22 MS. McKENNA: Yes. I am just saying that it was 23 not part of the definition. We can look at that as to 24 whether we think it is helping or hurting the explanation I 25 think perhaps would be the solution I would propose to make.
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72 1 DR. KRESS: You may just strike that sentence
() 2 down.
3 MS. McKENNA: Yes,- maybe if it is not helping it 4- would be worth just seeing whether we can live without it, 5 which we.may well be able to do.
1 6 DR. KRESS: I don't see that it helps anything. I 7 MS. McKENNA: Okay, we are tracking to Criteria 7
)
8 and I think I covered the first bullet. I mentioned the
)
9 second bullet.
10 DR. KRESS: Well, except the bullet, I am not sure 11 what you say in the rule, but the bullet doesn't specify by 12 whose calculational methodology.
13 MS. McKENNA: No. That's correct. That's why we 14 have Criteria 8, which is specific on the methods.
() 15 DR. KRESS: Criteria 8 is the one that does that.
16 MS. McKENNA: That's correct, and this is really 17 more looking at the changes to the facility and how do they 18 affect the parameters and the response to the barriers.
19 Generally when you are looking at these things, 20 you're right, there is some kind of analysis in there 21 somewhere, but the premise of applying Criteria 7 is that i 22 the analysis is maintained. You just say what is the change i 23 I am making and how does it propagate through my analysis.
24 DR. KRESS: It maintains the analysis --
25 MS. McKENNA: Correct.
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l 73 I i
1 DR. KRESS: -- that was originally used in the l i 2 FSAR.
I 3 MS. McKENNA: That's right. That's right.
I
( 4 DR. KRESS: In other words, this is basically 5 Commissioner Diaz's approach to margin, as I recall it? l 1
! 6 MS. McKENNA: I have to think through that one. I 7 think it is in the sense that you look at the results of the 8 analysis and if that is what you mean I think -- the reason 9 I was hesitating, I believe Commissioner Diaz had suggested 10 we drop the criteria altogether --
11 DR. KRESS: Yes, that was one of his suggestions.
12 MS. McKENNA: Yes.
13 MR. BARTON: Eileen, on Criterion 7 --
14 MS. McKENNA: Yes.
) 15 MR. BARTON: -- on page 59 of statement of !
l
' l 16 considerations package, you have got words in there that the 17 changes that involve alteration of design basis limit for l )
18 fission product barrier involve such a fundamental ;
I 19- alteration of the facility design that' change even in the l
20 conservative direction requires NRC approval.
21 MS. McKENNA: Yes.
22 MR. BARTON: Why even in a conservative direction?
23 Isn't this essentially a zero increase --
24 MS. McKENNA: This is changing the limit itself.
25 MR. BARTON: Okay.
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74 1 MS. McKENNA: It is not changing the facility and
( 2 how it propagates to the limit. It is if you are really 3 going in and saying, you know, that my reactor coolant 4 system pressure is not going to be 2500 anymore, it's going 5 to be 2300. The reasons you would do that, there's 6 something more fundamental happening and so we expect that 7 to be a very rare circumstance.
8 [ Laughter.]
9 MR. BARTON: I would think so.
10 DR. SHACK: That's why we have the exceeded or 11 altered --
i 12 MS. McKENNA: Yes. 1 l
13 DR. SHACK: It's for that extraordinarily rare 14 circumstance. l k 15 MS. McKENNA: Right, correct, right.
16 DR. BONACA: Usually you want to know why.
17 MS. McKENNA: That is exactly right, yes.
18 DR. APOSTOLAKIS: You are not going to deny it?
19 MS. McKENNA: Well, I mean it's --
20 DR. SHACK: We need to hear the reason first.
21 MS. McKENNA: I think the reason is the thing of 22 interest. Something has changed in our understanding of 23 where things are going so --
24 MR. BARTON: Okay. I understand that now.
25 MS. McKENNA: Okay.
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75 1 DR. WALLIS: Are you going to get sometime onto
) 2 the 10 percent of the remaining margin question?
3 MS. McKENNA: I wasn't planning to speak to that 4 in detail but if you have a question I certainly can do 5 that.
6 DR. WALLIS: Well, this seemed to be a definition 7 of minimal. Minimal starts off being vague and then there 8 is.a discussion about how well -- it's sort of compatible 9 with the negligible idea of NEI, and then there's a separate 10 definition about it being 10 percent of remaining margin.
11 MS. McKENNA: We were giving guidance in the rule 12 on how to apply the minimal increase to consequences.
13 DR. WALLIS: I like the idea of being specific.
14 MS. McKENNA: Yes.
I 15 DR. WALLIS: I like the idea of the examples you 16- have.
17 MS. McKENNA: Yes.
18 DR. WALLIS: Very helpful.
19 MS. McKENNA: Thank you. In the consequence areas 20 I think we felt we could do a better job of really getting 21 to specifics about how to deal with minimal because --
22 DR. WALLIS: What bothers me is there's a logical 23 problem between something which is negligible and something 24 which is 10 percent of a remaining margin.
25 If something is 10 percent of a remaining margin, ANN RILEY & ASSOCIATES, LTD.
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c 76 1 it's certainly measurable and certainly not negligible.
() 2 3 minimal.
MS. McKENNA: Well, the term we are using is 4 DR. WALLIS: It may be what you accept, but be 5 careful of things which aren't consistent. If at one point i
6 you are saying, well minimal and negligible are close enough l
7 that they are good enough --
8 MS. McKENNA: No, no , no --
9 MR. BARTON: No, no, no, no -- we said don't use 10 negligible, use minimal, and they are defining minimal and 11 then getting 10 percent of minimal.
12 DR. SHACK: Anything that is negligible is 13 minimal.
14 MS. McKENNA: Is minimal, right.
() 15 DR. POWERS: And I might just comment that there 16 is quite a lot of examples in law where 10 percent has been 17 declared a minimal sort of thing. I mean it arises several 18 times and in fact within the Department of Energy we got in 19 a judgment from GAO that 10 percent would be declared quite 20 small. ,
I 21 MR. BARTON: Right, correct. '
22 DR. WALLIS: Well, I think it's quite small, but 23 would like to have it specified rather than vague and of 24 course the criticism we have made is that minimal was too 25 vague a statement. I i
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r 77 1 It is just that was this NEI proposal and we urged
- ( ) 2 you to get together and sort of compare those and so on and 3 then we'd sort of say that well, because their negligible is 4 less than our minimal they are not proposing anything bigger 5 than we are going to allow, so it is okay, but that made j 6 it -- made me a bit troubled anyway about this 10 percent.
! 7 MR. BARTON: Do you still have that disagreement 8 with NEI?
9 MS, McKENNA: I am not sure I would characterize i
10 it as a disagreement.
11 MR. BARTON: Well, they use the negligible, which 12 they wanted to use, versus minimal. I think they have now 13 come on board -- ;
14 MS. McKENNA: Well, I think as Dr. Shack was
() 15 mentioning, we all agree that if you are meeting the i 16 negligible you will meet minimal. The issue has been can 17 you move beyond it and can we agree on what that means?
18 MR. BARTON: Have we agreed now on what that 19 means?
20 MS, McKENNA: Well, I think we have had some 21 discussions and we think there may be room for further 22 discussion and we may be able to in the guidance are 23 supplement with -- come up with four examples on how to deal 24 with malfunctions and things like that. That will help. I 25 think we may have to do it more that way rather than, you O ANN RILEY & ASSOCIATES, LTD.
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78 1 know, at 10 percent or something like that.
2 DR. SHACK: Yes, I think it was always in the 3 context of the existing guidance --
4 MS. McKENNA: That's correct.
5 DR. SHACK: -- to define negligible and therefore 6 you could use it within the context of the new rule.
7 MS. McKENNA: Exactly right, yes.
8 DR. SHACK: The question was how you were going to I
9 go further, but at least you had established you could use l 10 the existing guidance.
11 MS. McKENNA: Absolutely.
12 DR. BONACA: A comment I have on the design basis 13 limit. Words should be there to make sure that that barrier 14 is maintained I mean not only by maintaining the lower limit 15 but also the upper limit.
16 For example, containment design pressure ~ clearly 17 is the limit.
18 MS, McKENNA: Yes.
19 DR. BONACA: _ Internally. But you are going to 20 affect the barrier by changing -- for example, you put 21 rupture disk as we did on the Harden vent and you go down, 22 the failure of your containment at the design pressure or 23 just above that, so you have reduced really that barrier as 24 a margin of safety.
25 Is there a provision in there? ~Is the word ;
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79 1 " altered" referring only to the design basis limit or also
() 2 to the barrier?
3 MS. McKENNA: Well, I think if you were altering 4 the barrier such that the limit is no longer the right 5 limit, which I guess is maybe what you are saying, I think 6 that that would also fit in that.
7 DR. BONACA: Well, let me give you an example.
8 Suppose'that you did not mandate the Harden vent but I did 9 choose on own to put a Harden vent. That would cause the 10- pressure disk to rupture right above the design limit so 11 that pressure in the containment goes up to the limit, 50 12 psi for example, and then it goes just above that, the 13 rupture of the disk, and so now the barrier is gone.
14 I have literally eliminated a margin of 80 psi, 90 O
(,,/ 15 psi, something like that, in the barrier by affecting the 16- outer limit rather than the inner one.
17 MS. McKENNA: I think the way we had structured 18 it, we weren't trying to capture that kind of situation with 19 this criteria. I think you might have to look at other 20 criteria if you were in that situation where --
21 DR. BONACA: But I think all you have to do is to 22 make sure the word " altered" refers to the barrier rather 23 than the specific design limit that you are looking at, 24 because the way I read it, it doesn't do that and I am only 25 saying, you know, it doesn't happen often but that is an ANN RILEY & ASSOCIATES, LTD.
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80 1
exact example of where you may affect a barrier by simply
() 2 3
taking out this upper range of capability by design.
MS McKENNA:
I will have to think through that 4 one, but I understand what you are saying.
5 DR. BONACA: I mean that came from the NRC, 6 therefore you even have to do a 50.59, but normally --
7 DR. WALLIS: Now this minimal is in the rule.
8 MS. McKENNA: Yes.
9 DR. WALLIS: But the 10 percent part is in some 10 other document.
.11 MS. McKENNA: It is in the statement of 12 considerations which is published along with the rule.
13 DR. WALLIS: It needs to go with the rule 14 otherwise it doesn't make enough sense.
) 15 MS. McKENNA: Yes, and then it will also be in the 16 guidance.
17 DR. WALLIS: Now is 10 percent then the test which 18 the licensee will apply in determining whether or not the 19 change is minimal --
20 MS. McKENNA: Yes.
21 DR. WALLIS: -- or are there other tests that will 22 be applied?
23 MS McKENNA: The consequences, that would be the 24 test that would be applied.
25 DR. WALLIS: The one and only and sufficient test O ANN RILEY & ASSOCIATES, LTD.
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p;-
81 l 1 for all changes?
()
t 2 MS. McKENNA: As I said, when you are looking to 3 see whether the change you are making, how it has affected 4 the consequences, that would be the standard that you would 5 use to address.
i 6 DR. WALLIS: So why isn't something like 10 7 percent written into the rule instead of the minimal put 8 into the rule and then you have to go somewhere else to find 1
9 out what it means?
10 DR. KRESS: Because it's hard to change a rule and i 11 it's easy to change the reg guide.
12 DR. WALLIS: So what might happen is that minimal !
l 13 might be interpreted some other way in the future? Is that l 14 the idea?
() 15 MS. McKENNA: It's possible. I mean, I think the 16 thinking was to put --
1 1
17 DR. POWERS: When it's in the statement of 1
18 considerations it's very difficult to go back and change 19 that.
20 DR. KRESS: That's part of the rule. l 21 MS. McKENNA: I think that it is trying to keep 22 the thought process in the rule and then the specifics of 23 how you do it.
24 DR. WALLIS: Suppose somebody who is, say you're a 25 Member of ACRS, wants'to know what does minimal mean, read ANN RILEY & ASSOCIATES, LTD.
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82 1 the rule. Is there any way that that naive person knows
() 2 3
that he has to look somewhere else to find what minimal means?
4 DR. POWERS: I think anybody that is in the :
5 business of acting upon these rules knows enough to check l
6 the statement of considerations and the guidance. l i
! 7 DR. WALLIS: That may be true there, but it 8 wouldn't be true of this Member of the ACRS I'm referring I 9 to.
10 DR. POWERS: With our superb staff, he would be j i !
l 11 acquainted with it and supplied with more documents than he 12 would care to have to plow through.
13 DR. WALLIS: You see, that's what I'm trying to 14 avoid. I say it should be clear, if someone wants to know I
() 15 or some reasonably well informed person wants to know in 16 order to clarify something or work something out, what the 17 rule is, he shouldn't have to be an insider and know all the 18 tricks of the trade in order to be able to figure out what l 19 the words are supposed to mean. So that you have to look at 20 something which you have to know exists in order to find out 21 where the definition is. It seems to me much more 22 preferable to have it in the rule itself. That's again, 23 that's a naive relatively new junior, as George points out, 24 Member, trying to figure out why it's done this this way.
25 DR. POWERS: It is certainly an area of curiosity, ANN RILEY & ASSOCIATES, LTD.
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83 1 but it is also true of many, many of our rules that to
() 2 3
really understand them, you really have to go to the guidance, ar 4 sometimes to the standard review plan to 4 understand what it is that the staff is prepared to accept 5 to fulfill the words.
6 DR. WALLIS: Let me say that's my -- that's 7 followed me since I joined the ACRS, that something which 8 looks like a very simple principle or rule suddenly turns 9 into thousands of pages of documentation before it can be 10 used.
11 DR. POWERS: I think that's the -- 1 l
12 DR. WALLIS: That's very peculiar.
13 DR. POWERS: I understand exactly what you're I 14 wrestling with. I wrestle with a far more difficult set of l
/~ l (S) 15 rules myself. That's the 800 series of 10 CFR. And it has 16 always been my impression that the controversy you run into 17 here or the difficulties you run into here is that you have 18 a legal system with one set of language and you have an 19 engineering profession with a different set of language, and 20 the two have met here in these kinds of rules and the 21 decision has been that it's the legalese that makes it to 22 the rule and it's the engineerese that makes it to the 23 guidance and the standard review plan. That has been my 24 interpretation. I agree with you, it would sure be nice if 25 you had one set of language that we all can agree to. But 1
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i 84 1 it seems to be a challenge.
( 2 DR. WALLIS: Well, it's not just a question of 3 nice. If it's desirable that there should be less in the 1
4 way of reg guides, because the rules are so simple and I 5 clear, I think that's something we should work towards. We i 6 shouldn't just say it's always been this way, therefore it 7 should stay this way.
)
8 DR. POWERS: Well, I think what we find to the 9 contrary is that it is more useful to have more reg guides ;
i 10 and fewer rules. Like I say, my experience all comes from l 11 the 800 rules, and they are -- and we don't have reg guides. l 12 And so we invent lots of things that look like reg guides to 13 try to tell us what the rules mean. And I think that works 14 out to everyone's advantage. Few rules that are rather i 15 broad and the reg guides don't tell in our case here at the 16 NRC the licensees what they have to do. They tell them here 17 is one way to satisfy these rules the staff is prepared to 18 accept on face value, okay? You can do it any way you want 19 to, but if you do it this way, the staff is prepared to 20 accept this. And the standard review plan will review this 21 in the following way. And I think that's in comparison to 22 what we have in the 800, that's a very nice way of doing 23 things.
24 DR. KRESS: Yes, I think there's a better 25 explanation of why they're separate, too. It allows '
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85 1 flexibility. If.it were written into the rule, it would be
() 2 part of the rule.
3 DR. POWERS: Yes.
4 MR. MATTHEWS: One of the concerns the staff's 5 been trying to respond to is that we have been dealing in 6 the former rule with an interpretation that said may be 7 increased as a zero standard, and there's issues of 8 precision that come into play in establishing whether zero 9 has been established or reconfirmed, and our concern with i
10 putting a numerical value in the rule is just the same kind 11 of argument, which side of a very narrow line are you on, 12 and there was a desire for some flexibility. The.10-percent 13 value in guidance or in the statement of considerations is, 14 you know, on the order of 10 percent.
h 15 DR. BARTON: Right.
16 MR. MATTHEWS: Okay. To which we're not going to 17 apply a magnifying glass. If we were to put it in the rule, 18 trust me, a magnifying' glass would be applied. So, I mean, 19 it is an issue of philosophy, and I agree with the concern 20 that we ought to be as literal as we can, but in some areas, 21 there isn't a benefit to being that literal. ,
22 DR. POWERS: And I think the lawyers advise us 23 that we tread on dangerous ground when we put numbers in, 24 and experience shows us certainly the experience of the EPA 25 has shown us that the science gets better, the rule stays O ANN RILEY & ASSOCIATES, LTD.
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1
{
86 1 stagnant, you create real headaches when you've gone to
() 2 quantitative limits. I think that's been our experience.
3 DR. WALLIS: But the naive position of the public 4 would be that the rules ought to be simple and having huge j I
5 piles of paper and procedures is simply making work for )
6 regulators.
7 DR. POWERS: Well, I can appreciate that point of 8 view, but the truth of the matter is that what they're doing 9 is giving engineers the guidance they need to do their job.
l 10 DR. APOSTOLAKIS: Let me understand this. Is the l 11 rule similar to a law passed by Congress and the decisions 12 of the various courts are interpretations of the law --
13 DR. BARTON: Yes.
14 DR. POWERS: Exactly so. 1
) 15 DR. APOSTOLAKIS: And these are the regulatory 16 guides? ,
i 17
~
MR. MATTHEWS: That's my concept.
i 18 DR. BARTON:
~
That's it. And I don't think we're 19 going to change it as a result of this meeting, and I think 20 we need to push on so we can figure out what's changed in 21 this rule so we can prepare a letter.
22 Eileen, please.
23 MS. McKENNA: Okay. Thank you. So we're talking 24 about criteria 7 on the fission product barriers. In the 25 last bullet I just was indicating that in terms of for O ANN RILEY & ASSOCIATES, LTD.
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87 1 implementation, changes that are being looked at would be
) 2 changes to the_ facility, systems, structures, components, 3 and procedures, and that in applying these criteria you need 4 to look at how those changes are affecting the parameters 5 and then compare whether the limits continue to be met as a 6 result of the change that's being made.
7 DR. KRESS: That last bullet's to cover design 8 basis limits that are additional to the ones --
! 9 MS. McKENNA: It's to cover the fact that, you l
10 > know, your limits apply to let's say the reactor coolant i 11 system --
! 12 DR. KRESS: Yes.
l i 13 MS. McKENNA: But you may be changing something in 14 an entirely different system that may have an effect through
() 15 the way -- the function of that system on the reactor l
16 coolant system, that you need to look at how that effect 17 ends.up with respect to how the barrier performs.
l :
18 DR. KRESS: Well, you've already covered that --
19 MS. McKENNA: Yes.
20 DR. KRESS: In the first bullet, though. I 21 thought it had to do with --
22 MS. McKENNA: This'is not something in the rule.
23 This is just explaining in the guidance of how you would go 24 about starting from here's the change you're looking at and 25 how do you then move forward to --
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88 1 DR. KRESS: Oh, okay. I see. That's how you
() 2 would be sure -- '-
3 MS. McKENNA: You meet that. Correct.
4 DR. KRESS: Meet that first bullet. I got you.
5 MS. McKENNA: Right. That's all.
6 Okay. As I mentioned, the other criteria, 7 criterion 8, which is specifically looking at changes to the 8 evaluation methods themselves, and what -- the words in the 9 rule talk about departure from the methods in the FSAR used 10 in the design bases or in the safety analyses to try to 11 clarify which methods we're talking about that we feel this 12 criterion should apply to, and then we use the word 13 " departure" because we think there's a couple of attributes, 14 if you will, to when it is a departure, and there are really l) 15 two parts. One is if you're changing some part of the 16' method and how that affects the results of your method.
17 And the second is if you have one method and you 18 'want to change to another method that has already been 19 reviewed and approved for that particular use, that that 20 would be acceptable since it has already received the review 21 that this criteria in the rule is trying to look for. So 22 that there is really the two elements, that if you change it 23 and kind of -- you get the same answer or --
24 DR. POWERS: Is this asking for troubles for the 25 staff? When they approve a method for a particular plant ANN RILEY & ASSOCIATES, LTD.
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89 1 which may have unique features and whatnot, that they have Ih V
2 to bear in mind that this method, without proper -- their 3 approval, has to have with it the codicils of all the things 4 that led them to approve it for this plant and say and no 5 other plant, that there is an --
6 MS. McKENNA: There is an element there that we 7 have to be careful of. What we have said in the discussion 8 is that when the licensee is doing this evaluation and 9 looking to see, well, can I change from method A to method 10 B, they need to look at whether the method was -- I think we 11 used the word " generically approved" for, you know, whether 12 it is PWRs or for non-LOCA transients or whatever the usage 13 is, and do they fall within the terms of what that approval 14 was. And, yeah, there may well be cases where the staff
() 15 looked at it for plant X, and only for plant X, and that was 16 as far as the SER covered, and then plant Y may not be able 17 to use it under this criteria.
18 DR. POWERS: But I mean I guess -- I am not sure 19 who the burden falls on here. Is it the burden on the staff 20 to, when they approve a method, to say, and in the course of 21 developing this approval, we took recognition that this 22 plant is a 2 loop PWR manufactured by Babcock and Wilcox in 23 a subatmospheric containment, built on Wednesday, and no 24 other plant? Or is the burden upon the licensee to say, aw, 25 the staff approved this, but when doing so it was only for 2 O ANN RILEY & ASSOCIATES, LTD.
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i 1 90 1 loop subatmospheric B&W plants?
() 2 MS. McKENNA: Well, since the process we are 3 talking about is for a licensee making changes on their own, 4 the burden is on the licensee to establish that, if they are 5 using this new method, it is -- it meets the conditions that 6 were established for it. And if the only -- if all the SER 7 said was it is okay for plant X, that is not going to give a 8 licensee any basis necessarily for being able to say that it 9 is okay for me too, because you are not going to be able to 10 make that kind of conclusion.
11 MR. MATTHEWS: This was a point of discussion 12 between ourselves and the industry. They were hopeful that
.13 we could see our way clear to include a criteria that would 14 permit them to translate methods approved on one individual l
() 15 plant to methods approved for another similar plant, and the 16 technical staff was of the view that they didn't have that 17 kind of restriction, mindset, or didn't impose limitations 18 on their review that would permit the extension of one 19 plant's approval to another one. So the staff was reluctant 20 to allow the industry to, in effect, make liberal use of 21 approvals on similar plants.
22 So this did come up as a point of discussion. The 23 resulting outcome was that if the approval by the NRC on its l 24 face and in the literal wording of the staff's SER extended l
l 25 the method to the plant in question, then that method could l
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91 1 be used.
(O
%J
) 2 If it was silent, and it was a plant-specific .
\
3 approval, it couldn't be inferred to have generic 4 applicability, and the tech staff was very adamant about 5 that, because they didn't look at it for generic 6 applicability. And if they were to look at those individual 7 amendments with the expectation that somebody may use them 8 generically, the review on an individual plant's amendment 9 would be much more burdensome.
10 MS. McKENNA: I think we are recognizing that 11 there are cases where the staff does look at things topical, 12 that is generic and that that is what --
the kind of cases 13 we were talking about.
14 MR. MATTHEWS: So I think the burden, in summary, 15 the burden is on the licensee, in applying these rules, to 16 be able to demonstrate unequivocally that the method has 17 been approved for the plant in question. However, I think 18 the staff continues to need to be mindful when they make a 19 generic approval that they make sure and limit just the 20 extent of that approval in terms of types of plants and i
21 conditions under which it can be applied.
22 DR. POWERS: Well, I think when they do a generic, 23 they are pretty --
24 MS. McKENNA: They are careful to do that, yes.
l 25 DR. POWERS: They are pretty good, but they are
[)
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92 1 not -- when they do an individual plant, I don't think they
'2 'think about it.
3 MS. McKENNA: No.
4 MR. MATTHEWS: No.
5 DR. POWERS: And I don't think we could ask them 6 to.
7- MS. McKENNA: No.
8 MR. MATTHEWS: No. And I don't think we would to.
9 And I don't think individual licensees would want that 10 either because it would impose an additional regulatory 11 burden that would be undeserving on an individual applicant.
12 DR. POWERS: One of the things that you have to 13 recognize in writing this rule is that many of the FSARs 14 were written in the days of the slide rule.
) 15 MS. McKENNA: Yes.
16 DR. POWERS: And the changes are being made in the 17 days of the PC. And so if I come in and I have done an 18 analysis, say,.for example, the FSAR method, what has been 19 used and reproduced for years now was done, say, with an 20 Eulerian model for solving a differential equation. And now 21 because I have got a PC, I say, gee, I want to use a Runga 22 Kutta, much more accurate, much more refined. Is that one 23 of these -- is that considered a change in the method?
24 MS. McKENNA: It would really depend I think on --
25 as we indicated, you have to look at what is in the FSAR O
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r 93 1- and, therefore, what information was available. Now, l 2 whether that level of specificity would have been included 3 would.probably depend on the nature of the analysis that you l 4 are talking about. How important was it that it be --
5 whatever the indicated -- I am not familiar with the l
6 specific example you used, but if that was something that 7 would have really been significant with respect to the l 8 particular analysis and how it was being used, and, 9 therefore, was presented.
10 DR. POWERS: Well, it is an example out of a 11 specific FSAR, so --
12 MS. McKENNA: Okay, then --
]
13 DR. POWERS: I mean I just happened to notice that 14 they solved it by an Eulerian method.
15 DR. KRESS: What it likely will do is give you a 16 more precise calculation of the design limit.
17 MS. McKENNA: Yes.
l l 18 DR. KRESS: I mean how close you are coming to it.
1 19 MS. McKENNA: yes.
20 DR. KRESS: And in this case, it probably lowers i
l 21 the calculated value.
22 DR. POWERS: Yes.
23 DR. KRESS: So they could say they have more 24 margin now.
25 DR. POWERS: Yes. Yes, that would be --
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94 1 DR. KRESS: Yes. And I have a question about
() 2 that. Were you through, Dana?
3 DR. POWERS: I am pursuing this issue, and I guess 4 I don't have an answer.
5 MS. McKENNA: But that is exactly the reason why 6 this criteria was there, is that if you are saying, well, we 7 looked at --
the staff had looked at the facility and the 8 analysis in a particular way, and now you are saying under
.9 criteria 7 you are allowed to change a facility and now go 10 right up to what those limits are.
11 DR. KRESS: But I would have assumed -- you had a 12 criterion from here --
13 MS. McKENNA: Yes.
14 DR. KRESS: -- that would say if this change to
) 15 your calculational methodology makes a significant change in 16 your calculated answer that you had before, then we need to 17 look at it, whether it is up or down.
i 18 MS. McKENNA: And that is what we are talking 19 about, being that you either -- you are either the same --
20 basically, you have the same answer you had before.
21 DR. KRESS: Yes, but that is within some 22 percentage of something.
23 MS. McKENNA: Within, yeah. Within --
24 DR. KRESS: So that is the way they would view 25 that, I think, Dana, as -- did it change the answer very O ANN RILEY & ASSOCIATES, LTD.
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95 1 much? And, if so, we look at it.
r' C)
( 2 MS. McKENNA: Right. If it didn't change the 3 answer very much, then fine. But if it did change the 4 answer more than, well, a little bit --
5 MR. MATTHEWS: So it isn't essentially the same.
6 MS. McKENNA: Right.
7 DR. KRESS: Let me ask you an additional question 8 about that then.
9 MS. McKENNA: Yes.
10 DR. KRESS: What you have is you have these design 11 basis limits, and you have a calculated value.
12 MS. McKENNA: Right.
13 DR. KRESS: Based on some sort of a 14 plant-specific, licensee-specific code.
G 15 MS. McKENNA: Correct.
16 DR. KRESS: And you have reviewed these both and 17 approved this code and this design basis limit based on this 18 calculated value. And I guess you are calling that margin 19 now that can be -- that they can make changes. As long as 20 they don't change this code, they can make changes that 21 incrementally approach this limit.
22 MS. McKENNA: We are allowing -- what we are 23 saying is that we have reviewed how you show you meet the 24 limit and what the limit is, we will let you make changes to 25 a facility that bring you up to that limit, as long as you 1
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96 1 show that you are still meeting in the same way, so we
() 2 understand how, you know, what that --
3 DR. KRESS: But I assume the original approval of 4 the methodology had implicit in it the fact that you had 5 this margin as a result of the calculation, to account for 6 the uncertainties associated with that calculation 7 methodology. Now, you are going to let them eat it away all 8 the way up to the limit. And in my mind, that mee.ns you 9 have probably -- may have exceeded the limit as some 10 probability because the uncertainty is in both directions.
11 I don't know how you dealt with that in coming to 12 this type of --
13 MS. McKENNA: Well, I think the thinking was that 14 when these limits for the barriers were set, there was
) 15 account for uncertainties. You set them at a point that you 16 knew that that was not the point where the barrier was going 17 to fail. You set it some distance away so that you have 18 some accounting for variability.
19 DR. KRESS: Typically, 10 percent of the design 20 value.
21 MS. McKENNA: Well, I think -- when you say -- you 22 are talking about some of these parameters, I think there 23 are some times you are talking about factors, you know, l
24 orders of magnitude in some cases between where you set your i
25 don't exceed this and where you really think that the i
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l 97 l l
1 containment or your reactor coolant system is going to fail. l l
( 2 DR. BONACA: One thing that was typical, Tom, like 3 they were really surrogate analysis. They really were not 4 analysis. So wherever you got the point kinetics l l
5 calculation for reactivity transient, and you forced some 6 performance there where you would by far exceed any, you 7 know, steep slop, and the reason is 't hat you were trying to 8 set your RP set points up there, so you wanted to do them, 9 you know, as low and conservative as you could.
10 DR. KRESS- Yes.
11 DR. BONACA: So those are really artificial, and 12 they were all skewed in one direction, depending on what set 13 point you were setting. That was the concept behind --
14 DR. KRESS: Yes, that is the issue -- we did the 15 calculation in the first place in a conservative manner.
16 MS. McKENNA: Yes.
17 DR. KRESS: Therefore, the real answer is 18 somewhere down here. That doesn't address my question 19 because the uncertainties may be so large than there is a 20 high probability that answer could be still up here, even 21 though it is conservative. You know, that doesn't -- it 22 doesn't really address my question is the problem with it.
23 DR. BONACA: No, I was explaining why I was -- the 24 concept of --
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I' 98 1 Tom has. I think when you start eating away margins it
() 2 should be done based on some sort of better understanding of 3 what you are doing, because the margins were there 4 originally on the basis of someone's judgment because things 5 weren't definite, there were uncertainties, they were put in 6 to allow a margin. And if you can show that, because we 7 know how to do things better today, there are justifications 8 for not being so cautious, then there will be a more 9 reasonable explanation for why it is being allowed to eat 10 away the margin.
1 11 MS. McKENNA: Well, I think that is why we are I i
12 saying that -- we are not saying that using these other )
13 methods would be unacceptable. We are saying that the staff 14 would'want to have the opportunity to review those methods 15 for those reasons you are talking about.
16 DR. WALLIS: See, my suspicion is that 10 percent 17 .has just been pulled out of the air.
18 DR. KRESS: Yeah, we are addressing the 10 I l 19 percent.
20 MS. McKENNA: Oh, okay.
21 DR. WALLIS: The 10 percent is pulled is being 1
22 pulled out of the air as something politically acceptable 23 with no technical justification whatsoever.
24 MS. McKENNA: Okay. You are back on --
25 DR. WALLIS: Which is fine. That is probably how l'
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99 1 regulations get made.
1 7s
( ) 2 DR. KRESS: That is our issue, the justification 3 of the 10 percent.
4 MS. McKENNA: Okay. Well, the justification --
5 the 10 percent really is applying in the area of 6 consequences where we are saying there are -- these are 7 regulatory values that have been set and we want to approach 8 them in a step-wise point rather than going to --
l 9 DR. WALLIS: The way it has been derived is simply 10 -- correct me if I am wrong, by people sitting around and 11 saying, well, what shoulc we choose? Well, 5 percent, 10 12 percent, 20 percent, rhrat will people buy? What is 13 acceptable to all siden? Well, probably people will buy 10 14 percent, let's talk about it. And then it is accepted, but k_,s) 15 it is accepted, therefore, I would say in a political way.
16 It is not accepted on the basis of any rational decision 1
17 making, on the basis of better definition of what a margin l 18 is, under what grounds it is justifiable to erode it, how it 19 is really related to the effect on public safety. Because 20 it has been deduced. It is based more on just people 21 sitting down and saying let's choose 10 percent.
22 Now, if that is an acceptable way to make 1
23 decisions, that is perhaps the way to do it. But it seems 24 that perhaps there is a better way.
25 DR. BONACA: If I can give some insight on the
(
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l 100 1 point. If there was a tendency to increase -- to eat the
() 2 margin because it is useful for something, I would say I 3 completely share your feelings. The experience I have seen, 4 reviewing literally hundreds, if not thousands of safety 5 evaluations is you are dealing more with minor changes that 6 are resolved by a small input that you have somewhere, like, 7 you know, you have a temperature error, you assume your 8 calculation is 2 degrees Fahrenheit in that direction, and 9 now you have 3 degrees Fahrenheit and you want to see what 10 the sensitivity of the result may be. And you get a result 11 where you get maybe a couple of PSI higher pressure in, for 12 example, in transients.
13 And the issue is, should you go now and ask for us 14 to review a cycle, the whole process, or should you have O
( ,/ 15 that margin to allow for that?
16 Now, yes, we have to be sensitive about whether 17 that was a creeping effect that would go then into regions 18 where you shouldn't go. But, you know, pragmatically, that 19 has been the experience that I think --
20 MS. McKENNA: Yes, I would confirm that.
21 Certainly.
22 DR. BONACA: Under the NEI, I mean NEI came up in 23 1989 with -- 25, and, really, you haven't seen any erosion 24 or that sense, I mean because that is what has been 25 evaluated. In some cases you have changes, it will be down.
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l 101 1 In some cases the change is up. And so I, from that
.( ) 2 perspective, I think it is pragmatic. I realize that there 3 is always some vulnerability. But I think it is in the 1 4 right direction, just an opinion here.
5 MS. McKENNA: I think that is a fair statement.
6 DR. POWERS: Go ahead. l 7 DR. KRESS: I have an unwritten rule and that says 8 if a rule allows something, eventually it will happen.
9 MS. McKENNA: I mean that is -- we have to 10 approach it from that point of view, too. And I think that 11 is why we were trying to do this two-pronged approach of 12 saying, okay, continue to meet the limits and continue to 13 show that you did it in the same way, so you don't have, you 14 know, eating away at the limits and eating away at how you
() 15 did it, so there is a much greater chance that you are 16 above. Yes.
17 DR. KRESS: I see you have got your limit 18 controlled. I see you have got your calculational 19 methodology controlled. What I have seen is you have 20 lightened up on your margins and are going to let them eat 21 away at it.
22 MS. McKENNA: That's right.
23 DR. KRESS: And I haven't seen the justification 24 for that yet.
25 MR. MATTHEWS: To give them more flexibility to be I
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102 1 able to work within an arena that doesn't involve the NRC.
() 2 MS. McKENNA: And I think the other --
3 MR. MATTHEWS: And the NRC, in doing that, is 4 giving up some of the prior oversight and control for those 5 kind of changes. And that is -- I think we have to say 6 that, you know, across the board.
7 DR. KRESS: That is a reason, it is not a 8 justification.
9 MS. McKENNA: No, I think the justification is 10 that we have -- it was mentioned earlier, in certain things 11 that we have carved down, say, that we put in the tech 12 specs, and say these things, you don't have the flexibility 13 on, they are protected. Saying th9 limits, you have to meet 14 those limits. These were limits that were agreed upon as
) 15 being the appropriate values for those parameters and those 16 have to be maintained.
17 But those limits are being met when you make these 18 facility changes and if you then are still meeting those 19 limits that we have established in a conservative place, I 20 think that is the basis why --
21 DR. KRESS: Say you could give that flexibility a 22 number of ways. One -- 5 percent or 2 percent -- and you j 23 could have said oh, well, we are going to take the design 24 limit and we are going to drop below it 10 percent and let 25 you just go up to that. There have been a number of ways l
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103 1 you can give this flexibility and I don't see any 2 justification for any of them.
1 3 I mean you have to develop some sort of basis for '
4 why you went this way. Why 10 percent? Why going all the 5 way up to the limit itself? I don't know. I haven't seen 6 the reasons anywhere.
7 , DR. BONACA: What I want to say, there is this 8 performance indicators that are really an important measure.
9 For example, if you had seen -- for example, say that you 10 have issues with peak precsure in the RCS, okay? If you had 11 it creeping up, you would have two things happening.
12 One, you would have much more frequent opening up 13 PORVs. Second, you will have high pressure trips increasing 14 and third you would have safety valves being cycled.
15 Now instead we have seen in the past 20 years an 16 actual large. reduction in number of RPS trips, less PORV 17 actuation and really no safety valve actuation. I mean all 18 I am trying to say is that there are indicators there in the !
19 inspection program that will really come around, and if you 20 begin to see that kind of creeping up of those kind of 21 -parameters, that is going to be a flag and this is going to 22 come up right away because you are going to have -- so all I 23 am trying to say is the reason --
24 DR. KRESS: The justification might be it is 25 controlled by other things or something like that.
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104 1 DR. BONACA: Yes. All I am expressing here is
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2 more comfort that I have maybe than you do have, Tom, 3 nothing else.
4 DR. KRESS: I really am not concerned about it or 5 I would be raising some sort of stink.
6 DR. BONACA: Sure.
7 DR. KRESS: I think it is perfectly all right to 8 do this. I just haven't seen the justification.
9 DR. BONACA: I understand.
10 DR. KRESS: I think it is there. I think the 11 justification is there somewhere and I think they have been 12 sufficiently conservative anyway that let them go up to the 13 design limit --
14 DR. BONACA: The justification is not there. I do O.
(_,/ 15 it only for comfort because I've been tracking this issue of 16 performance indicators and seeing them actually going down 17 rather than up, and that is why I have some comfort there, 18 but you are right, there isn't a logic behind why 10.
19 DR. WALLIS: And not only justification -- how 20 about the consequences? I mean down the road what happens 21 when everyone has taken their 10 percents and the 10 22 percents and their 10 percents and there is no margin left?
23 What happens then?
24 DR. KRESS: You eventually get there, don't you?
25 DR. WALLIS: What happens then? Minimal becomes
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105 1 zero again. Is that your intent?
() 2 MS. McKENNA: It is not the intent. I think it 3 would be an outcome of if that was the way --
4 DR. WALLIS: So was it your intent to have a law 5 which after awhile goes back to the way it was before, which 6 means minimal becomes zero?
7 MS. McKENNA: Well, but I think that under the 8 circumstances you are talking about where they have moved 9 themselves up to now being at the limits of the regulatory 10 values in the course of the terms of the process of saying 11 should NRC be reviewing those changes, if that is where you 12 are, then NRC should be looking at those because as you just 13 said you have taken all the margins away.
14 I don't think that that is the situation we are 15 going to get to because I think Dr. Bonaca is right.
16 DR. SEALE: I think disposable margin.
17 MS. McKENNA: Disposable margin, that is correct, 18 yes.
19 MR. BARTON: Good point.
20 MS. McKENNA: That is a good point, yes.
21 MR. BARTON: Go ahead, Eileen.
22 MS. McKENNA: I was just trying to finish up on 23 Criteria 8 and I think we have covered pretty much all these 24 points.
25 MR. BARTON: Excuse me?
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106 1 MS. McKENNA: I'm sorry?
() 2 3
MR. BELL: Thank you. I am Russell Bell with NEI.
I think I just want to clarify a couple of things. j 4 In terms of the -- taking them in reverse order --
5 in terms of the 10 percent on 10 percent on 10 percent, we 6 are talking about increases, potential increases in dose i
7 consequences. In addition to the 10 percent of remaining (
8 margin, licensees would also be limited by the NRC's own -- ,
I i
9 what do we call them? --
10 MS. McKENNA: Acceptance guidelines?
11 MR. BELL: -- acceptance guidelines, which are 12 taken from the Standard Review Plan. These are already set 13 well below 10 CFR 100 kinds of regulatory limits.
14 For instance, for many scenarios the acceptance
) 15 guideline in the SRP that applies to many licensees is 30 16 rem thyroid, while the 10 CFR 100 limit is 300, and so I 17 just wanted to make the point that we can take 10 percent, i 18 10 percent but we have committed to the approach that we 19 would not -- that we would continue to honor these much 20 lower SRP guidelines. That was point number one.
21 Point number two, in terms of the -- and Dr.
22 Kress, I wasn't going to say anything because you are not 23 really raising an issue, but you seem uneasy about the 24 ability to go all the way up to a design basis limit and 25 that we are eating away margins and I just would clarify O ANN RILEY & ASSOCIATES, LTD.
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c 107 1 from an industry perspective there is really no difference
( 2 in that approach than we believe is currently existing in
)
3 the industry.
4 The NRC may perceive that they are giving 5 something up but we have identified perhaps a difference of 6 interpretation on this area but our view of the longstanding 7 guidance that was produced in 1989 by EPRI and now is 8 incorporated into the NEI 9607 document is margin of safety 9 begins above that design basis limit and we have always 10 maintained and again honored that line, but considered the 11 region below the line to be some other sort of margin --
1 12 operating margin -- that would be the purview of the utility 13 to use, and indeed that was typically practiced by 14 licensees.
(O,) 15 DR. KRESS: But why do you think that margin above 16 the line is there for? What above the line?
17 MR. BELL: Well, certainly the term " margin of 18 safety" implies that we would -- that describes that region. i 19 It is to ensure that we don't encroach on a failure point.
20 DR. KRESS: You don't want to get close to the 21 failure point because you are uncertain --
22 MR. BELL: Agreed.
23 DR. KRESS: -- in terms of your calculation and 24 your phenomenology so it is better to cover the fact that 25 you are really uncertain as to where you really are and you
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108 l 1 don't want to get up close with that kind of uncertainty.
[ 2 MR. BELL: I think as Eileen put it, I would have
(
3 given the very same answer. That was a consideration in 4 where those limits themselves were established, the 50 psi.
5 DR. KRESS: And all I was saying is that --
6 MR. BELL: Very conservatively.
7 DR. KRESS: -- when NRC looked at the 8 calculational methodology and approved it based on those 9 limits and approved jt because it calculated at a lower 10 number is because they perceived the uncertainty in that 11 particular code or the methodology to be more than they are 12 comfortable with with that design margin, so that in my mind 13 incorporates it into the margin above, and so you can view 14 that a lot of different ways.
/^T 15 is_) You know, I agree with you. There's probably more 16 margin. The reason I am not really concerns is there is 17 probably so much margin there because of this great distance 18 away from the actual limits and where you really have a 19 problem that that little bit of difference is almost like an 20 insignificant change. We're going on up to the limit -- or 21 I agree with you on that, but the problem I have with it, it 22 just doesn't technically hold together, see?
23 You know, if it had a good technical --
24 MR. BELL: Understood.
25 DR. KRESS: Yes.
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109 1 DR. WALLIS: Every time a margin is eaten away a es bit there is a consequence to public safety.
1 2
(v) 3 DR. KRESS: There's no doubt.
4 DR. WALLIS: And I think this committee probably 5 agrees that what you are doing is right, that there is no 6 significant change to public safety. The effect is minimal, 7 but there is nevertheless a change and it would I think in 8 this day and age of having measures for things be very good 9 to have a measure of what is the impact of this on public 10 safety.
11 I think that what's happened is the rule gets set 12 by what I have called this political process of negotiation, 13 people discussing. It would be good if some professional 14 person could look at it and say right -- what is now the
( ,/ 15 consequence of making this new law on the public safety, 16 because margins will be eaten away and that must have some 17 effect.
18 DR. POWERS: I am going to intercede here. We are 19 going to have scheduling difficulties otherwise. Can we l 20 finish up in the next two .uinutes?
21 MS. McKENNA: Yes. Actually I think I have pretty 22 much covered it. I had a slide here on the other 23 regulations but I think I covered that in the opening l 24 remarks other than I'll just comment back on your question 25 about Part 71.
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110 1 What you saw in the paper is that the agency is
() 2' planning to look at the, if you will, I'll give the 3 shorthand, the 7148 type of change process for Part 71 as 4 part of a larger rulemaking that they are doing on Part 71 5 to look at the compatibility with the latest IAEA standards.
6 They will look at that as part of that same rulemaking.
7 I have no other -- there's no other developments 8 on the Part 71 front.
9 The last slide I had was on the implementation. I 10 think we covered that in the beginning, that we are -- we 11 will make a proposal. Exactly what that number will be --
12 DR. POWERS: Let me make it clear that I think the 13 committee has expressed in the past its desire that the 14 Staff be capable of handling application or activities under
) 15 this revised rule quite promptly.
16 MS. McKENNA: Yes.
17 DR. POWERS: But I think they should be flexible 18 in allowing licensees, just because of the tremendous amount 19 of training burden that they will face at. a time they may 20 not be prepared to face it --
21 MS. McKENNA: Right.
22 DR. POWERS: -- they should be also flexible in 23 allowing them to move to the new system. Staff itself 24 should be very quickly able to handle licensees using this 25 new procedure.
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111 1 MS. McKENNA: Yes. I think the primary thing is l
() 2 3
we want, since it is the licensees that have to do the evaluations, they need to be comfortable. We thought about 4 since it is all relaxation, you could make it immediately 5 effective and then that raises the question of how quickly 6 we can get the word out to our own people that these are now 7 the ground rules, so we kind of steered away from immediate l
8 and at some time longer than that, and exactly how long it 1
9 is is still I think you could pick a lot of different 10 numbers. .
I 11 MR. BARTON: I've just got one question before we 12 break --
13 MS. McKENNA: Sure.
i 14 MR. BARTON: -- and hear from NEI. On page 99 on (k 15 the enforcement policy, I question the statement you make --
16 a failure to submit an amendment as required would be j 17 considered a Severity Level 3 violation if a substantial 18 review is needed by the NRC before it could conclude that a :
1 19 licensee's actions were acceptable. 1 20 And I think that's kind of revere. Can you explain that to 21 me? l 22 MS. McKENNA: Okay. The way the policy is written 23- now, and examples that are given for 50.59 violations, it 24 says a 50.59 violation where licensee failed to seek the 25 amendment is severity level 3. That's the way the policy is O ANN.RILEY & ASSOCIATES, LTD.
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112 1 now. Over the -- since the last year and a half when we set
() 2 up the panel I think it was kind of a recognition that not 1 3 all failures to seek licensee amendments are equally 1 4 significant, so this was a measure of trying to apply 5 saying, you know, the base idea would be that failure to 6 seek the amendment is a level 3, but if it was really not 7 that important an issue, it was one of these minimal 8 increases or, you know, something not -- the safety 9 significance of the issue was not_that great, that perhaps a I 10 severity level 3 was not warranted for that particular 11 instance, and that then we would exercise --
12 DR. BARTON: So why doesn't this say based on the 13 safety significance of the failure to apply for a change 14 rather than on the number of hours you're going to spend
() 15 reviewing --
16 MS. McKENNA: It's not the number of hours. I 17 think what we tried to clarify with the parenthetical is the 18 merits of the technical -- it's kind of if it's so simple 19 that you look at it and you say well, this clearly meets all 20 the requirements, it's a very straightforward type of thing 21 that would not warrant being treated as a 3. If it's a more 22 complex issue that the technical review of whether the 23 change is acceptable is more involved, it suggests that the 24 underlying significance of the issue is more involved, that 25 that would be a reason perhaps not to exercise the i' ANN RILEY & ASSOCIATES, LTD.
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I 113 1 discretion.
[
V) 2 DR. BARTON: Okay. Are there any other questions 3 of Eileen while she's here?
4 If not, let's take a break before we hear from 5 NEI. Fifteen minutes?
6 DR. POWERS: Fifteen minutes would be fine.
7 DR. BARTON: Be back at quarter to four.
8 [ Recess.)
9 DR. POWERS: Let's come back into session. I 10 think I have a quorum, though they may not be paying full.
11 attention.
12 DR. SEALE: Our chairman is going to roust us if 13 we're not careful.
14 DR. POWERS: Let's please go ahead.
() 15 MR. BELL: Well, I promise to be very brief, and 16 I --
17_ DR. POWERS: I would hope you would be complete.
18 MR. BELL: I intend to. Eileen always does an 19 excellent job we think in describing a situation on this 20 issue and the status, and at times representing the dialogue 21 that's been going on.
22 Now my simple message is that we believe we've 23 come to-a common understanding in particular on the last two 24 significant remaining items, which are, as Eileen was 25 talking about, criteria 7 and 8, 7 being the replacement for 4 ANN RILEY & ASSOCIATES, LTD.
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t 114 1 the margin-of-safety criterion, 8 being an entirely new
) 2 criterion, which has given us some pause, and staff has 3 paused with us to really try and roll up our sleeves and 4 anticipate the implications as best we can.
5 We've sent a letter last Friday, and I think it's 6 in your package. 1 It's an April 30 -- you may not have had {
7 time to absorb it. Basically there's a lot of agreement ;
i 8 reflected in there, as I'm saying. In addition, though, we 9 just sortoof underscored the need particularly with the 10 brand new criterion on methodology that there needs to be i
11 guidance that goes along with the guidance -- the devil's in 12 the details, as you know, the guidance will ime essential in i 13 helping people implement the new criteria. We propose --
14 DR. POWERS: I guess I'm surprised that you j
() 15 haven't asked'for more flexibility in that criterion 8.
16 MR. BELL: You're surprised?
17 DR. POWERS: Yes. I mean, it has -- it doesn't 1 18 seem to match with the language that goes more than a 19 minimal change elsewhere. It seems to be much more 20 restrictive. I'm surprised.
21 MR. BELL: I think it is more-restrictive, and it 22 concerned me certainly initial.ly that there did appear to be
'23 for lack of a better term a double standard for a certain 24 type of change versus other types of changes you could make l.
I 25 under this rule.
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115 1 We think that while the standard may be different
() 2 in terms of acceptable changes without prior NRC approval, I 3 guess we pulled the string on this enough and discussed it 4 with the staff and convinced ourselves that there will be 5 sufficient flexibility to not, you know, handcuff licensees.
6 A lot will have to do with the guidance that goes 7 along with well, what's essentially the same, okay, if a 8 change moves a result in a nonconservative direction. And 9 what is a departure, that's part of the question, what is a 10 departure. It's what I mean when I say the guidance on 11 implementing those words will be very important. So --
12 DR. MILLER: That's the guidance -- I'm on page 7 13 of the letter.
14 MR. BELL: Yes, h 15 DR. MILLER: You describe the guidance there that 16 you recommend. Has there been agreement on that guidance?
17 MR. BELL: It may be my page 5. Is that the three 18 bullets?
19 DR. MILLER: It starts on page 5.
20 MR. BELL: The following shall not be considered a 21 departure.
22 DR. MILLER: That's page 7 in the letter I have.
23 MR. BELL: Right. We have discussed those points l
24 with the staff. I'll not characterize their position on 25 them, but we think these reflect some discussions we've had O ANN RILEY & ASSOCIATES, LTD.
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l 116 1 with them, the heads nod, we think that this type of -- we
() 2 intend to put this type of guidance in our revision to l 3 96-07. I think it says here we think it would be very 4 valuable to put it right in the statements of consideration.
5 DR. BARTON: Yes, and it's not in there, but then 6 you said you were going to put it in your guidance anyhow.
7 MR. BELL: Yes. 'Ye s . And of course we'll need to 8 work with the staff on the guidance and drive that to -- I 9 DR. POWERS: In another context, the institution-10 you represent has worried when the interpretation of rules 11 depends on personalities, and the creeping of regulation.
12 That doesn't bother you here?
13 MR. BELL: I think we've struck the best balance 14 we can, to give you a political answer.
f 15 I think so. I think so. We've got a lot of 16 experience, both we and the NRC in dealing with these kinds 17 of things. These are not new kinds of things. In fact, 18 licensees have been controlling methods under 50.59 for 19 years, because that's been part of NSAC 125 guidance.
20 DR. POWERS: And it's worked well, so --
21 MR. BELL: We think so. We don't think there's 22 really anything broken here, and so the subject of licensee 23 burden came up, whose burden is it, you know, in particular 24 on this one, and I think it was you, Dr. Powers, said it's 25 the licensee's burden clearly. It's a 50.59 is their rule O
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I 117 l
1 to implement, and that's why we think it will be so l
( 2 important that there will be clear guidance on this.
3 I think the licensees are pretty confident. They 1
4 know when a new or modified methodology is appropriate to l 5 use in a particular application. I think they are very good 6 and adept and experienced at that. But we would not want a 7 new regulatory criterion to come up and now there would be, l
8 you know, we want there to be confidence as well for 9 licensees to understand when a change in a method of 10 evaluation requires prior NRC approval. They know what's i 11 appropriate from an engineering technical sense, and we will 12 need the rule and the guidance to be very clear to help them 13 make sure that they --
14 DR. POWERS: There clearly is a point where the
(^S I
( ,) 15 skills of the art have to come into play and you just have 16 to acknowledge that, and I guess what you're saying is that 17 the skills of the art of engineering, 50.59 evaluations are 18 such that you can live with this language.
19 MR. BELL: We think so. We'll work hard on the 20 guidance. I think examples will be very important. We'll 21 try and choose examples that typify the most commonly done 22 kinds of analyses and the kinds of analyses that are most 23 likely to change, and again drive those examples to 24 agreement with the NRC and get ultimately their endorsement 25 on the guidance.
i t
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118 1 DR. POWERS: I personally would appreciate any
() 2 3
chance you have to share with us the examples you're looking at. I think it would be enlightening for all of us.
4 MR. BELL: We can certainly talk about getting on i 1
5 the agenda in the future. Our plan is to revise this -- our 6 guidance document over the summer. When we have a product 7 ready for prime time, we'll share it with the industry for 8 wide review for NRC probably for information at that point.
9 At some point we'll of course send it over for endorsement.
10 And again'when it's ready for that kind of a -- at that 11 point we'll share it with the Committee as well.
12 The only other thing I was going to say in my 13 prepared remarks is the point about the implementation 14 period, 6 months, 18 months, 12 months, as we recommended in i
() 15 our letter of Friday, we think it's appropriate to tie the 16 implementation -- the effective date of the rule to the 17' day -- to a period after you've got approved guidance or 18 endorsed guidance.
19 Licensees cannot go on and adjust their programs, 20 processes, and procedures, retrain all their people, unless 21 they have the confidence they know what to train on, and 22 what to change their procedures to. So they absolutely have 23 to have that. And our sense is from a poll of our task 24 forces that they need about six months after they have that 25 confidence.
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119 1 So in any scheme that the staff proposes on
(. 2 implementation, I would like to see -- we would like to see 3 some kind of an interim milestone at which point there would 4 be at least staff approval or staff recommendation to 5 publish the NEI 96.07 for public comment similar to the 6 process that's been going on now in the FSAR area.
7 DR. WALLIS: Can I ask you about this 10 percent 8 of margin business?
9 MR. BELL: You bet.
10 DR. WALLIS: When you wish to make a change and 11 .some engineer has to decide how to approach the NRC or 12 whether or not, is your expectation that this person is 13 going to make some assessment and say ch, this is a 14 1-percent change of margin, therefore I don't need to --
() 15 that requires making the calculation that leads to that 16 1-percent figure?
17 MR. BELL: There is a point of clarification 18 that's needed, and it happens to us all the time, but we mix 19 our terminology. When we say 10 percent, whenever we're 20 talking about 10 percent, the only place that comes up in 21 the proposed rule is in the area of consequences. Ten 22 percent increase in --
23- DR. WALLIS: Everything you do has consequences.
24 MR. BELL: Dose, consequences as under the 25 criterion, j
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n 120 1 DR. WALLIS: So how do you decide when you have to
() 2 3
actually make this calculation about percentage of margin you're eroding?
4 MR. BELL: In the area of margin, we've avoided 5 the notion of margin.
6 DR. WALLIS: No, but this is the definition of 7 minimal, is it's 10 percent of the available margin.
i 8 MR. BELL: And in the new criterion on fission 9 product barrier integrity, I won't say margin of safety, 10 because it's not a margin-of-safety criterion anymore, it's 11 criterion 7 on fission product barrier integrity, the term 12 " minimal" doesn't appear, 10 percent, the term " margin" 13 doesn't appear.
14 What we really wanted to make the criterion very A)
(, 15 objective, very implementable, is an objective criterion, an 16 objective limit, and we selected design basis limits for 17 those fission product barriers. Those are hard, fast 18 numbers.
19 DR. WALLIS: There are all these minimal increase 20 in, there are three of these --
21 MR. BELL: Um-hum.
22 DR. WALLIS: And we learned -- I thought I learned 23 that minimal means less than 10 percent margin. And that 24 would seem to imply that every time you contemplate doing 25 anything, someone has to say are we or not going to violate O ANN RILEY & ASSOCIATES, LTD.
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p 121 1 this minimal increase requirement. Doesn't that require
() 2 doing the same kind of assessment that we're trying to avoid 3 having you to do?
4 MR. BELL: I think you're reading from something 5 that I don't have the benefit of, but again there's I guess 6 a total of eight criteria coming. The minimal increase in 7 likelihood or frequency -- :
)
8 DR. WALLIS: Likelihood of occurrence of l
9 malfunction of an SSC. Minimal increase in consequences of 10 an accident previously evaluated. Minimal increase in l
11 consequence of a malfunction of SSC. I 12 Now --
13 MR. BELL: What we need to do is divorce -- those 14 are distinct --
k 15 DR. WALLIS: Make an assessment of is it minimal 16 or not.
17 MR. BELL: Right.
18 DR. WALLIS: It's the same old problem we've had 19 all along.
20 MR. BELL: Right.
21 DR. WALLIS: And we learned today that's 10 22 percent at the margin. So doesn't someone have to make this 23 assessment and when do they have to calculate whether or not 24 it's 1 percent, 2 percent, 3 percent?
25 MS. McKENNA: Perhaps I could step in for a moment
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i 122 1 here.,
() 2 DR. WALLIS: Please.
3 MS. McKENNA: The 10 percent you're referring
{
4 to.-- arises in guidance on how to implement the minimal 5 increase in consequences, and you're looking at 10 percent 6 of the difference between where you are and what the limit 7 is that's established in the regulation. We're not trying 8 to view it -- we're not going to call it margin or whatever, 9 saying this is a way of judging minimal for consequences.
10 That's the only use of the 10 percent that we-have 11 DR. WALLIS: But that's what I'm saying, doesn't 12 the licensee have to always ask, " Don't I have to calculate
'13 that?"
14 MS. McKENNA: That's part of their evaluation of
() 15 what the change they're doing, how does that change affect 16 the facility and does it have an effect on consequences, and 17 if so --
18 DR. WALLIS: Why should they not have to calculate 19 that for every change, just as that was the problem we had 20 all along?
21 MR. BELL: And in fact we do. This is an exercise 22 I think was very effective when we went through it with the 23 staff. We had a series of examples. The focus of the 24 meeting was on the margin of safety, the replacement 25 criterion for the margin of safety. But what was very l
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123 1 effective is to take each example through all eight criteria l \
2 of 50.59.
\s-3 So you take a change, an aux feed water pump flow 4 change. Your as-found condition flow rate is less than 5 what's written in the SAR. Okay. So criterion 1 is does 6 that cause an increase in the frequency of an accident.
7 Okay. Ana -; 2nSwered in that case, and we had our panel of 8 experts, and discussed with the NRC. I think the answer was 9 no to that. We went to the next question.
10 DR. WALLIS: Minimal increase in the likelihood of 11 occurrence.
12 MR. BELL: Of a malfunction --
13 DR. WALLIS: Malfunction.
14 MR. BELL: In this case. Again --
A
( ,) 15 DR. WALLIS: To safety.
16 MR. BELL: Again we came up with no on that, and 17 we took --
18 DR. WALLIS: Well, suppose there is a change. You 19 have to assess it. Then eventually you're going to have to 20 use the 10-percent criterion.
21 DR. SHACK: Yes, he has to do the evaluation.
22 DR. WALLIS: So he has to evaluate --
23 DR. SHACK: He has to do the evaluation.
24 DR. WALLIS: So he has to do a PRA.
25 MS. McKENNA: No. No, I --
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124 1 DR. WALLIS: Why not?
() 2' 3
MS. McKENNA:
against each criterion.
They have to evaluate every change Now the answer may be for 4 particular changes, and for instance this aux feed may be a 5 case, that there is no change in consequences. You don't 6 have to try to quantify or to calculate it, because you 7 know, you understand the change you're making and how it 8 affects the plant.
9 By contrast, in some of the examples we have in 10 the notice, if you're changing something in the filtration 11 system of your fuel handling building, you may have to --
12 where you could be affecting consequences, you're going to 13 have to look at that and see whether that change is going to 14 be increasing the consequences more than minimally as laid
() 15 out in the criteria. So that does have -- all the criteria 16 have to be addressed, but the answer can be there is no 17 change in consequences because of what thing I'm doing.
18 DR. WALLIS: Yes, but if there's no change in 19 consequences, then that was never a problem anyway.
20 MS. McKENNA: Right.
21 DR. WALLIS: So we're only talking about when 22 there is a change in consequence. I'm just trying to 23 establish if the amount of work that has to be done has 24 changed in any way by saying 10 percent. You still have to 25 make all the evaluation.
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125 1 MR. BELL: That's right.
() 2 DR. WALLIS: Does the amount of work that's 3 required in order to allcw the licensee to make a change 4 change? l 5 MR. BELL: No, I don't think so, but what has been 6 improved is that 10 percent is a very clear line.
7 DR WALLIS: So there's no reduction in burden, 8 there's only --
9 MS. McKENNA: I would say characterize it this 10 way. The reduction in burden would arise from those 11 circumstances where if you looked at it and you said it 12 needs the 10 percent, and therefore I do not need to get NRC 13 approval for this change. I 14 DR. WALLIS: There is no reduction in burden in {
() 15 making the calculation. There is in what you have to do 16 afterwards.
c 17 MS. McKENNA: Correct. Right.
18' DR. BONACA: Yes. Because, I mean, what I'm 19 trying to say is that the USQ is a significant thing within 20 .the utility. Once you have that, you have all kind of 21 committees that now get involved in that kind of review, et 22 cetera.
23 DR. WALLIS: I was just trying to clarify.
24 DR. BONACA: It is --
25 DR. SEALE: And one other point. The number 1
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126 1 that's-changing was not born in a PRA. It was a licensing
() 2 calculation, before George ever thought of PRA.
3 .DR. KRESS: And it will stay that way.
4 DR. SEALE: Yes. Exactly.
5 DR WALLIS: You mean licensing calculations 6 involved likelihood?
7 DR. SEALE: No, they involve margin.
8 DR. WALLIS: But it says minimum increase in 9 likelihood. You've got to calculate --
10 MR. BELL: Of course back then the term was 11 probability.
12 DR. WALLIS: You've got to calculate the increase 13 in likelihood. Can you do that?
14 DR. APOSTOLAKIS: That was the problem all along.
15 DR. WALLIS: That's what the problem still is, 16 isn't it?
17 DR. APOSTOLAKIS: And it still is.
18 DR. WALLIS: Right. Okay, it still is the 19 problem.
20 DR. APOSTOLAKIS: But we will risk-inform it, 21 so --
22 DR. KRESS: Suppose your change in consequences 23 ended up being 10.3 percent. Is that the same thing as 10 24 percent?
25 MR. BELL: That's a good question. I think in the O ANN RILEY & ASSOCIATES, LTD.
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127 1 cuidance I think they've used the term in the ballpark or in
() 2 ene range of 10 percent, and I think the guidance we might 3 agree on with the staff is that, you know, round it off, you 4 know --
5 MR. MATTHEWS: That's the reason we didn't want to 6 put it in a regulation.
7 DR. KRESS: Is 11 percent probably the same thing 8 as 10 percent?
9 DR. WALLIS: Let me ask you, is calculating the
{
10 likelihood of occurrence less burden to you than calculating 11 the probability of occurrence?
12- MR ., BELL: No, George tells me it's exactly the ,
13 same.
l 14 DR. WALLIS: So it's exactly the same.
() 15 DR. POWERS: To be precise.
16 MR. BELL: Recognize that the assessment of 17 whether your likelihood of a malfunction is increased could 18 be a qualitative one, as it is today, and the rule does not 19 require you to now go off and perform, you know, a 20 probabilistic analysis to get first a baseline number, then i
21 an after-the-fact number, compare the two, it does not l 22 require that.
23 g In fact, the subject of the term " negligible" came 24 up earlier. The NEI guidance we don't expect this part of 25 the guidance to change because licensees have become O ANN RILEY & ASSOCIATES, LTD.
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128 1 accustomed and are quite used to the " negligible" standard
() 2 in terms of qualitatively assessing an increase, whether
~3 there's an increase in the probability of an accident or 4 malfunction.
5 So as the committee heard before, there has been a 6 stipulation that negligible is always less than minimal.
7 DR. WALLIS: No, but I say we believe that 8 negligible is fine, but now you are allowed minimal you will 9 'probably take minimal.
10 MR. BELL: The flexibility is there and we support 11 the term " minimal" in the rule and we think that given more 12 experience with risk-informed methods and techniques that 13 over time utilities will be able to make better use of the 14 additional flexibility afforded by the minimal standard.
() 15 I think we expect the rule in the SOC to build a 16 room on the back of the house for that purpose, that we can 17 furnish later on.
18 DR. WALLIS: But how soon will it be before the 19 margin is eaten up? Presumably there are some projections '
20 about how utilities will respond to this rule. They will 21 probably take advantage of it. I 22 At what rate will they eat up margin do you 23 anticipate?
24 MR. BELL: Well, you know, again it is really a 25 bridge we haven't crossed. We built that room on the back 1
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129 1 of the house and we will add pieces to it as we --
() 2 DR. WALLIS: We are making a change in the rule 3 without having the awareness of the likely consequences.
4 MR. BELL: The other problem is that there is 5 really no limit or singular acceptable number for accident 6 frequency, okay, so in terms of eating up the margin, it is 7 a difficult calculation.
8 DR. WALLIS: It would seem to me that one should 9 when making a rule anticipate what the consequences will be, 10 and if the consequences will be for a utility to come in the 11 next year with a whole lot of changes which eat up all the 12 margin, then we will be back where we were before this rule 13 was promulgated.
14 MR. BELL: Well, we have committed to work with
(, 15 the Staff based on what they are prepared to put in there --
16 DR. WALLIS: That's fine, but you don't have an 17 awareness of the likely consequences of the rule, except 18 that people will feel happier.
19 MR. BELL: In this area there is room for building 20 on in the future so -- they have been making minimal changes i
21 for 30 years.
22 DR. BONACA: One comment I have is this is really, 23 what you have here is what has happened for the past 40 24 years, except for the last three. ,
25 MR. BELL: That's right.
)
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130 l' DR. BONACA: I mean literally what this does, it
() 2 formalizes what has taken place and it hasn't been quick as 3 far as I_can see, so hopefully just because you codify it --
4 DR. APOSTOLAKIS: What we should do then is 5 publish this and probably something else that says keep 6 doing what you were doing -- don't interpret this new rule 7- in any different way, 8 [ Laughter.]
9 DR. APOSTOLAKIS: Is that the meaning of what we 10 are saying?
11 MR. BELL: That's part of my message to a number 12 of audience --
13 DR. APOSTOLAKIS: Please don't interpret the 10 14 percent in any different way, just keep doing what you were
() 15 doing the.past 30 years.
16 DR. POWERS: Well, I think that is 9607 or --
17 DR. WALLIS: Well, I don't understand it. If I 18 were a utility and I saw I could take 10 percent I would 19 want to take it and then I would want to take another 10 20 percent if I could take that. I wouldn't be restrained by 21 what I had been doing in the past years.
22 DR. POWERS: I think that it is also fair to say I 23 that at least in my experience engineers doing a 50.59 24 evaluation of anything have been far more conservative than 25 I would have been. I think as a general rule they do not O ANN RILEY & ASSOCIATES, LTD.
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131 l 1 . push the envelope on that -- as a general rule.
() 2 3'
Is that your experience?
MR. BELL: Absolutely. It's a conservative group.
l 4 DR. POWERS: I think we need to move along, just 5 because we have another presentation.
6 -MR. BELL: Yes, you do.
7 I thank you very much and I'll take you up on the 8 idea to come back and talk to you when the guidance ripens.
l
(-
9 We have some examples that we think could be extremely
! 10 useful.
! 11 DR. POWERS: Thank you alot. At this point I will 12 turn to you, Dr. F0ntana.
13 DR. FONTANA: The next topic we have here is on 14 license renewal and the purpose of the session.is to hear
() 15 presentations by representatives of the NRC and Baltimore 16 Gas & Electric Company concerning the Staff safety 17 evaluation report related to the Calvert Cliffs license 18 renewal application.
19 We held a subcommittee meeting with the Staff and 20 BG&E on April 28th and 29th, 1999, and in this presentation 21 to the full committee we intend to cover ground rules for 22 license renewal, the overview of the BG&E Calvert Cliffs 23 license renewal application, and a summary of the safety 24 evaluation report.
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132 1 meeting. At the end of the session we would like to discuss
() 2 3
what the contents of this letter might be.
The presentation will start with Mr. Chris Grimes, l 4 Chief of the License Renewal and Standardization Branch, and 5 Chris --
6 MR. GRIMES: Thank you, Dr. Fontana.
7 As Dr. Fontana mentioned, last week we briefed the 8 subcommittee in some detail on the Staff's review of the 9 Calvert Cliffs license renewal application and the content 10 of the safety evaluation report and for this afternoon's 11 briefing we are going to present a summary of the contents 12 of Part 54. BG&E is going to make a presentation on how 13 they prepared their application for the Calvert Cliffs 14 plant, and then we will present a summary of the Staff's
() 15 safety evaluation.
16 The Project Manager for the Calvert Cliffs license 17 renewal application, David Solorio, is not with us today. I 18 gave him a break. I told him to take some time off.
19 DR. POWERS: He's getting old fast, huh?
20 [ Laughter.] ,
I 21 MR. GRIMES: It's been a pretty aggressive review 22 schedule. The Part 54 presentation will be made by Steve 23 Hoffman, who is a Senior Project Manager in our organization 24 and we will entertain any questions about the Part 54 aspect j 25 of it.
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7 133 1 We did not intend no going into the Part 51, 2 environmental impact, aspects but we'll respond to any 3 questions you have in that arena if you so desire, then BG&E 4 will make their presentation and then finally Dr. Sam Lee 5 will present the safety evaluation contents, and we have 6 various members of the technical review staff who 7 contributed to that safety evaluation with us, and I am also 8 assisted ably by Dick Westman, who is the Deputy Direct in l
9 the Division of Engineering, and hopefully we will be able 10 to address any questions that you have about the scope and 11 conduct of this first license renewal review.
12 Unless there are any general questions, Steve?
13 MR. HOFFMAN: My understanding is that you guys 14 would like a quick overview of the license renewal rule and 15 more or less what the Staff is reviewing the application to.
16 I will tzy and go through it quickly. If you have any 17 questions, want more depth, let me know.
18 The Atomic Energy Act obviously licensed plants to 19 operate for 40 years and allowed for renewals and puts no 20 limit on the number of renewals that can be requested.
21 Part 54 was issued to provide the technical and 22- administrative requirements for a safety review. Part 51 23 was revised to provide the environmental requirements for 24 renewal. Part 54 provides for a new license that will be 25 issued. It will supersede the existing license. It will be O ANN RILEY & ASSOCIATES, LTD.
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p 134 1 ' granted for whatever remaining term is left on the Part 50 2 license plus up to 20 years extension for the extended 3 . period of. operation.
4 An application can't be submitted earlier than 20 5 years prior to expiration of the current license and must be 6 submitted at least five years prior to expiration if you 7 want the timely renewal provision to apply such that they 8 can continue to operate if for some reason the Staff hasn't 9 finished its-review,-and,the rule does require, as you are ,
l 10 aware, the ACRS review and report and also allows for public !
11 participation.
12 The License Renewal Rule is based on two 13 fundamental principles, which they are actually included as 14 slide 5. To help understand it, we have kind of broken it I
() 15 down this way,-because between the two principles and 16 significant determinations of the Commission, these are 17 pretty fundamental to the license renewal.
18 The first one is that the regulatory process is 19 adequate. It is the means by which the Commission 20 continually assesses the adequacy of and compliance of a 21 plant with its current licensing basis, ensures that an 22 . acceptable level of safety is maintained. The current 23 licensing basis is defined in Part 54 and it is through 24 plant operation through life. It does -- is continually 25 changed and updated.
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135 1 The Commission said that if an issue comes up that
() 2 is relevant to the current operation of the plant, it should 3 be taken on and addressed under the existing Part 50 4 license, using those processes, and that it is not subject 5 to carryover and review for renewal.
6 DR. KRESS: On that first bullet, do you have a l
7 definition in mind of what ensuring safety means? l 8 MR. HOFFMAN: The current licensing basis will be 9 maintained. Renewal is ensuring, you know, that --
10 DR. KRESS: So that means the regulatory process 11 is adequate to ensure that the current licensing basis is 12 maintained?
13 MR. HOFFMAN: And that it will continue.
14 DR. KRESS: And that that -- and you equate that
) 15 with ensuring safety?
16 MR. HOFFMAN: Well, and will continue to maintain l
17 safety.
18 DR. KRESS: Continue to maintain. l l
19 '
MR. HOFFMAN: As new issues are raised, the 20 Commission will take whatever action is necessary. Through 21 the years, you know, the TMI action plan items, that-is the l 22 regulatory process working. You know, if something is 23 identified, it will be, you know, imposed.
24 DR. WALLIS: That is an assertion really.
1 25 MR. HOFFMAN: That is a principle of licensing.
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136 1 DR. WALLIS: Whatever you do is sort of an
[O3- 2 assertion. That's fine. It doesn't require that you check 3 by defining all the time safety and then reevaluating the l l
4 process. You are saying the process is adequate and we will !
5 use it.
I 6 MR. HOFFMAN: Right, that is the principle of the 7 rule.
8 Concerning the current licensing basis, the l 9 Commission determined that you didn't need to compile it. 1 10 License renewal is not a re-review, it is not a verification 11 of compliance with the current licensing basis. License 12 applicants are not required to meet latest standards, they 13 have to continue to show compliance with their current l 14 licensing basis. l
) 15 However, license renewal is in addition to. The 16 current licensing basis carries forward, it has to be 17 maintained in the same manner, to the same extent as it 18 currently is. And so in a way, Part 54 is an addition to 19 the existing requirements.
j 20 License renewal is focused on passive, long-lived 21 components and time-limited aging analyses, which in the 22 following slides I will explain that more thoroughly. And 23 it is focused on managing the effects of aging during the 24 period of extended operation. We are looking at the 25 extended period, not the current operating license.
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137 l' DR. WALLIS: It should focus on what has changed,
() 2 presumably, that should be the guidance. Is it that the 3 long-lived structures have changed and that their ability to 4 crack and so on may have changed over the years? That is 5 what you are -- you are focusing what has changed, on what 6 has changed.
7 MR. HOFFMAN: Ph! are focusing on ensuring that the 8 licensing basis they have now, the requirements that they i 1
9 need to meet will continue to be maintained in that extended 10 period.
11 DR. WALLIS: That's right. So things like thermal I
.12 dynamics haven't changed over the years, but the nature of 13 the structures has changed by radiation and so on, isn't i
14 that what you mean? l O); -
t 15 MR. HOFFMAN: That would be evaluated. Look at 16 the effects of aging on the structures and components.
17 DR. WALLIS: Right. So I am asking the question, 18 so what other things might have changed? And one thing that 19 it seems has changed is people. The way human beings 20 respond today isn't the way they responded when the rules 21 were. written 40 years ago. So you might have to consider 22 the human changes.
23 MR. HOFFMAN: We aren't looking at human changes.
24 If there are changes in procedures, fitness for duty, that 25 is all written into the procedures and that is part of their i
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138 1 current licensing basis.
x 1 2 DR. WALLIS: I think, fortunately, the human 3 factor has improved, but you couldn't assume that a priori, 4 you would have to probably assess it. But if you can assure 5 us that the human factor is part of the equation that has 6 got better over the years, and there is no question about 7 license renewal, but if the general responsibility of people 8 in society deteriorated over a generation, then this would 9 be grounds for concern.
10 MR. GRIMES: I think if Steve could continue with 11 an explanation of the content of the rule, there is a 12 defined scope of the facility that we review to assess 13 whether or not there are adequate programs for managing 14 particular aging effects.
() 15 DR. WALLIS: You are looking at regulations. I am 16 just trying to look at the overall picture. That it seems 17 to me when you renew a license, you should ask what has 18 changed. I mean if nothing has changed, then it is just as 19 good as it was before.
20 MR. GRIMES: The rule was constructed in way to 21 look at -- that changes associated with aging effects on a 22 facility. There are aspects like -- other things that are 23 expected to change, associated with the current licensing 24 basis, for which the rule presumes that the regulatory 25 process will continue to make appropriate adjustments for IJW RILEY & ASSOCIATES, LTD.
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1 l
139 1 things like staff training, operator licensing, emergency
() 2 planning. And those are things that are not within the 3 scope of this particular rule.
4 DR. KRESS: Suppose a plant is built in a location 5 where the close-in population increases from the time it was 6 licensed up to the time -- thinking about relicensing it, by 7 a factor of three. Is that still a safe plant, or is that a 8 consideration in your -- what you are doing?
9 MR. HOFFMAN: We do not look at the siting 10 criteria in order to determine whether or not this is still 11 a suitable site. That part of the current licensing basis i
12 carries forward. You might reach a point where you would i i
13 say that you can no longer provide reasonable assurance the 14 emergency plan will achieve its appropriate protection of 15 public health and safety. But, otherwise, we did not 16 consider siting criteria to reassess whether or not license 17 renewal should be granted.
j 18 DR. FONTANA: Does the generic EIS cover some of
( 19 that?
'20 MR. HOFFMAN: The generic EIS does cover some of 21 those considerations in terms of what are the appropriate 22 changes associated with the environmental impacts.
23 DR. FONTANA: Okay. All right.
24 MR. HOFFMAN: Getting into what the world defines 25 as the scope, you have three criteria. The first ene is ANN RILEY & ASSOCIATES, LTD.
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140 1 safety-related. -That is the standard definition you have
() '2 used before for that.
l 3 The second one, non-safety-related systems, 4 structures and components whose failure could affect the 5 functionality of'the safety-related components. The 6 applicant is required to look at failures that are part of 7 their current licensing basis. They don't have to look at i 8 -hypothetical failures that are not part of their licensing. l 9 basis. But if their licensing basis goes down to second, 10 third, fourth level, they need to evaluate that.
11 And the last criterion is the systems, structures 12 and components relied upon for compliance with those five 13 regulations. i 14 DR. APOSTOLAKIS: So does this mean then that PRA l 15 calculations are excluded because you go beyond design basis 16 there?
17 MR. HOFFMAN: The Commission looked at use of risk 18 analysis when it was developing the rule, and it said that 19 -- its evaluation was that the current licensing basis is 20 founded primarily'on deterministic engineering criteria, and 21 so they decided that the scoping criteria should be 22 deterministic and not use a plant-specific PRA. But it went 23 on to say risk insights could be used in determining the 24; relative importance of structures and components, subject to 25 review, in determining the programs needed to manage it, so.
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[ 141 1 And then risk insights were always being used in developing l l
() 2 our inspection programs.when the teams go out. Okay.
3 Now, we will go to the contents of an application.
4 The rule requires the licensee to perform an integrated 5 plant assessment. And what that is -- now, let me back up 6 one thing. The integrated plant assessment. We started out 1
7 at the. systems structure, the big, the large structure level 8 and now the integrated plant assessment is going down to the 9 component level.
l 10 The structural subcomponent level -- aging 11 management'is at the component level. Now out of the 12 systems, structures and components, we are in scope. What we !
l 13 do now is what is called screening to identify the l 14 structures and components subject to review.
) 15 The IPA is that assessment by the licensee that 16 the effects of aging on functionality of structures and 3 17_ components will be managed for the period of extended 18 operation.
19 The first thing that is required in the 20 application is for the licensee to identify and list the 21 structures and components subject to an aging management 22 review and those are defined as those that perform their ,
23 intended function without moving parts, changing 24 configuration or properties -- what we call passive.
25 DR. WALLIS: Is that equivocal or not? Do you O' 7d04 RILEY & ASSOCIATES, LTD.
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142 1 have something which when you load it moves, like a piece of
() 2 pipe or something? That I think is a pascive component.
3 MR. HOFFMAN: That's passive.
4 DR WALLIS: And something which does or does not 5 carry electrons which are moving is passive and so --
6 MR. HOFFMAN: Right.
7 DR. WALLIS: -- this is something which is not 8 subject to misunderstanding.
9 DR. SEALE: He's got a list there.
10 DR. WALLIS: I am sure you know what they are.
11 MR. HOFFMAN: The second criterion it has to meet 12 is it is not subject to replacement based on qualified life 13 or specified time period. In other words, it is 14 short-lived. That replacement interval should be determined
) 15 based on its useful life and it will be replaced before 16 aging effects will have affected its functionality.
17 Now the active the Commission determined could be 18 generically excluded because they have determined that the 19 degradation of active components is more readily apparent.
20 It will be picked up through performance condition 21 monitoring that is ongoing and therefore they determined 22 that they could credit existing programs and in particular 23 the maintenance rule program for managing aging of the 24 active components.
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143 ;
1 functions will be maintained and those functions are as they
() 2 describe up'there, those functions that the component must 3 fulfill that forms the basis for including within the scope.
4 DR. WALLIS: Really the first definition of l 5 passive would be those components which are not already
)
6 assured because of maintenance and so on. It's anything l
7 that is not covered as an active component automatically 8 becomes a passive one.
9 MR. HOFFMAN: That is not the way we come in at 10 the scoping and screening. You want to look at the 11 component itself and determine if it performed its --
12 DR. WALLIS: And nothing falls between the cracks?
13 I am just worried you say that active components are already 14 taken care of so we only need to worry about the passive !
() 15 ones, and that means the passive ones are essentially those 16 which are not taken care of already by the maintenance rule.
17 MR. BARTON: The maintenance rule takes care 18 active --
19 MR. HOFFMAN: The maintenance rule --
20 DR. WALLIS: -- is your concern.
21 MR. HOFFMAN: Yes. The maintenance rule does not 22 exclude passive.
23 DR. WALLIS: Just want to be sure there is nothing 24 in between that doesn't get caught either way.
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144
'l that we have done a very close comparison of the maintenance
() ,2 rule against license renewal and we think that they are 3 complementary, but I would point out that the maintenance 4 rule puts an emphasis on risk insights in terms of 5 identifying what the importance is.
6 License renewal tries to keep the deterministic 7 approach so that there is a consistency across the licensing 8 basis and the programmatic aspects of how the plant is 9 maintained. I just want to make sure that there is not a 10 misimpression there. It isn't a perfect fit, but there's a 11 sufficient amount of overlap and distinction that we are 12 comfortable that the maintenance rule and license renewal 13 are complementary.
l
, 14 DR. WALLIS: Thank you.
(3
. (,j 15 MR. HOFFMAN.: The next two slides actually list 16 structures and components that the Commission actually 17 included in the rule as to what is considered to be passive 1
18 and active. Unless you have any questions I won't bother to 19 go into that.
20 DR. KRESS: Is this an inclusive list?
21 MR. HOFFMAN: No. That was just examples the 22 Commission wanted included to explain what was intended.
I 23 DR. POWERS: Isn't the language -- the language I 24 think is explicit on that.
25 MR. HOFFMAN: Yes.
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I 145 1 DR. POWERS: It includes but not limited to.
gs
( ) 2 MR. HOFFMAN: Yes. Yes. Now that you have your 3 list of structures and components subject to review, what l 4 the application then must include is a description of the 5 methodology that was used to identify those structures and 6 components and then the big part is the demonstration that 7 the effects of aging will be managed such that the intended 1
1 I
8 functions will be maintained consistent with the current 9 licensing basis for the period of extended operation. l 10 We are trying to ensure functionality in 1
11 accordance with the current licensing basis for the period '
l 12 of extended operation.
13 In addition to your integrated plant assessment, l 14 the rule also requires evaluatin of time limited aging
- (i
(_) 15 analyses -- TLAAs. To be a TLAA -- okay, the integrated 16 plant assessment was at the structure and component level.
17 The Commission believed that TLAAs could be at the system 18 level so TLAAs could involve systems as well as structures 19 and components and also could involved active as well as 20 passive, and to be a TLAA it has to meet all six of these 21 criteria, the important ones being obviously that the 22 systems, structures and components are within scope, involve 23 the effects of aging, and the key one is that it involves 24 time-limited assumptions based on the current operating term 25 of 40 years.
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146 1 Once you have identified those --
() 2 DR. SEALE: You say they involve systems and 3 structures and components that have been identified, but 4 that is not all structures, systems and components in that 5 system, is it? Your first bullet.
6 MR. HOFFMAN: Within the scope of the rule?
7 DR. SEALE: Yes.
8 MR. HOFFMAN: That gets back to the 9 safety-related, nonsafety-related requirements --
10 DR. SEALE: -- the time limiting aging analysis --
11 parts of the system that is involved might not be -- do you 12 see what I am saying?
13 MR. HOFFMAN: Within the scope?
14 DR. SEALE: Yes.
l (\s,/g 15 MR. HOFFMAN: Actually, when you do your scoping, l
16 that initial scoping, you may bring a whole system in and 17 the only reason it is in is maybe because it's got a 18 penetration in containment, so then when you go back and do 19 the screening it is only the penetration from that system 20 that is subject to review.
- 21 DR. SEALE
- But then it might, the system might i
22 get c tim?-limited aging analysis as a system, not as a 23 penetration?
24 MR. HOFFMAN: Correct.
25 DR. SEALE: Okay. l 1
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l 147 l i
1 DR. APOSTOLAKIS: So what is the difference
[V\ 2 between or the relationship between the aging management 3 review and the time-limited aging analysis?
1 4 MR. HOFFMAN: What happens is that the way you 5 evaluate and assess them, okay? What you do is for the 6 period of extended operation, the applicant has three 7 options. In some cases the analysis already may have gone 8 out to 60 years or greater so they don't need to do 9 anything. In other cases they may be able to go back, 10 re-analyze and extend the analysis out to 60 years or they 11 can choose to manage the effects of aging which in essence 12 puts it back into the same approach you used for the 13 integrated plant assessment.
14 DR. POWERS: I think that it is easy to get lost
(,,< 15 in the abstractions here. An example is useful.
16 For instance, in the original analysis someone, as 17 I understand it, someone may have said okay, over 40 years 18 this much corrosion could occur on this item.
19 He has put a time limit on his analysis that now 20 has to be revisited to make sure that analysis is still 21 valid now for 60 years.
22 DR. APOSTOLAKIS: And that is vader TLAA.
23 DR. POWERS: And that is a AA_
24 DR. SHACK: The TLAA would be the aging processes 25 that you anticipated during the design and you allowed for ANN RILEY & ASSOCIATES, LTD.
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l 148 1 for a specific period. Aging management will cover all the
[v} 2 other aging processes that you didn't think about during the 3 design.
4 DR. POWERS: The abstractions sometimes get a 5 little confusing here and a few examples make it clear.
6 DR. SHACK: I mean for example you knew that some 7 components were going to be subject to thermal cycling so 8 you designed them with a fatigue life that was long enough 9 to last the 40 years. You didn't expect them to be stress 10 corrosion cracking, and so you didn't have a time-limited 11 aging analysis for that but you certainly have to have an 12 aging management program to manage stress corrosion 13 cracking.
14 MR. HOFFMAN: Okay.
f)s q, 15 DR. SEALE: Now you start to spend real money.
16 MR. HOFFMAN: Okay. A subset of your TLAAs are an 17 exemption that may have been granted in accordance with 10 18 CFR 50.12 that may still be in effect during the period of 19 extended operation. If that is the case you need to list 20 and justify its continuation for the extended period of 21 operation.
22 So far the two first applicants have not 23 identified any exemptions that would meet this criteria.
24 In addition to the IPA and the evaluation of time-limited 25 aging analyses, the application is also required to include
[)
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149 1 an FSAR supplement that provides a summary description of
( ) 2 the programs and activities that manage aging as well as 3 evaluation of time-limited aging analyses. This is the 4 method by which once the license is issued, it then changes 5 to the process or control in accordance with 50.59.
l 6 Additionally if there's any tech spec changes, the 7 applicant's supposed to include those as well as the l 8 justification for.the change. That's no different than 9 today's requirements for a tech spec change. And then the 10 application should also contain an environmental report in 11 accordance with 10 CFR 51.
i 12 DR. APOSTOLAKIS: Let me come back to Dr. Shack's 1 13 example. We're not talking about the original license, we 14 are talking about the current license.
l f 15 MR. HOFFMAN: Correct.
16 DR. APOSTOLAKIS: So originally you didn't think 17 of intergranular stress corrosion cracking, but now you have 1 18 an augmented program.
19 MR. HOFFMAN: Right.
20 DR. APOSTOLAKIS: So what do I do now? I mean, do 21 I say --
22 DR. SHACK: The question is whether that program 23 is good enough to last for 40 years or for 60 years, and you 24 have to demonstrate --
l 25 DR. APOSTOLAKIS: But the program I have now ANN RILEY & ASSOCIATES, LTD.
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150 1 specifies that it's good enough for 40 years, or it doesn't
() 2 say anything about time?
3 DR. SHACK: It doesn't say anything about time.
4 DR. APOSTOLAKIS: So why then do I have to revisit 5 it? If it's good enough now, it's good enough in 20 years.
6 MR. HOFFMAN: An applicant is required to look at 7 operating experience, both their own and other relevant 8 industry experience, as well as -- and industry. And if an 9 aging effect has been identified that is credible for their 10 plant, okay, you need to ensure that either it's not 11 occurring, in some cases where it's possible but not 12 certain, they'll do an inspection. If it's something that 13 is ongoing, they will have a program that maybe will 14 continue to inspect for it. If they've got more experience 15 with it, they may have a program that's managing it.
16 DR. APOSTOLAKIS: So in the AMR then I can come 17 back and say yes, flow accelerated corrosion can occur, 18 IGSCC and the rest can occur --
19- MR. HOFFMAN: Um-hum. 1 i
20 DR. APOSTOLAKIS: But I have already programs in 21 place. I have managed it. Thank you. What else do I need I 22 to do?
23 MR. HOFFMAN: Okay.
24 DR. APOSTOLAKIS: I mean, this is my current 25 licensing basis.
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151 1 MR. HOFFMAN: Okay. We've seen approximately 80
() 2 to 90 percent of the aging-management programs that are 3 current existing programs.
4 DR. APOSTOLAKIS: Oh, okay. So what I'm saying is 5 happening.
6 MR. HOFFMAN: Another 5 to 10 percent are modified 7 programs, and maybe 5 to 10 percent new.
8 DR. APOSTOLAKIS: Okay. Good.
9 MR, GRIMES: BG&E is going to cover some of that 10 in their presentation when they talk about what has changed, 11 but, you know, Steve's point here is that to the extent that 12 anything does change, if they change the scope of 13 surveillance, if they introduce a new kind of maintenance 14 program to address a particular aging effect, that that now
/~~~N
( ,) 15 will be rolled into the licensing basis in the FSAR and the 16 technical specifications and the environmental impact will 17 be updated.
18 MR. HOFFMAN: You see, the Commission when it 19 excluded active said, you know, it's not that there aren't 20 existing programs for passive long-lived components, they 21 just -- they didn't have the assurance for the group as a 22 whole that existing programs existed, were in effect to 23 manage aging for passive long-lived, and so that's why we're 24 looking at those programs. And the Commission said, you 25 know, once we gain more experience, we may come back and l
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152 1 further narrow that review. But they needed to go out and
() 3 2 look the first time, you know, get that experience before they could narrow it.
l 4 DR. APOSTOLAKIS: That was part of defense in 5 depth, you think?
6 MR. HOFFMAN: Well, it was more the generic 7 determination at the time the rule was written that we 8 couldn't' generically state that all passive long-lived 9 structures and components had programs in place.
10 MR. GRIMES: I think I'd like to also point out 11 that we also have a recognition that plants have evolved and 12 they now have programs that differ, and so to the extent 13 that there is now an issue that's going forward to the 14 Commission in terms of how to give credit for existing
(/ 15 . programs, we are going to try to more directly confront the 16 nature of the staff's review in terms of where should we be 17 turning our attention to achieve appropriate effectiveness 18 and efficiency in the review.
19 For these first two applications, we have 20 essentially reviewed all the programs. We've looked across 21 all of the scope and all of the programs that are accredited 22 for aging management in order to come to a complete 23 determination to reach the conclusion that Steve is about to l
24 describe.
25 MR. HOFFMAN: Okay. This is the finding that the
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153 1 staff has to make in issuing the license.
That actions have I
() 2 been or will be taken such that the effects of aging will be 3 managed to ensure functionality of the systems, structures, 4 and components, and that all TLEAs have been evaluated, and 1 l
5 that the current licensing basis -- there's reasonable 6 assurance that the current licensing basis will be 7 maintained for the period of extended operation.
8 In addition to that, you know, the environmental 9 requirements of Part 51 have to be met, as well as any 10 hearing activities be completed. And in Calvert Cliffs case 11 there was a petition for hearing. It was denied by the 12 Atomic Safety Licensing Board. The Commission affirmed 13 that. However, that is under appeal with the D.C. courts at i 14 the moment.
() 15 DR. WALLIS: It seems to me you're going to be in l
16 good shape when you already have an understanding of aging 17 and it's being managed, some component. What I'm not sure 18 is how active you're going to be in discovering other 19 effects of aging which also really ought to be considered 20 which aren't yet on the radar screen of the aging managers.
21 That there are other effects -- you have to search for other 22 effects of aging than the ones you already know about. And 23 I'm not sure how you assure that you find them all.
24 MR. HOFFMAN: We are -- both the applicant and the 25 staff are looking at experience.
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154 1 DR. WALLIS: Right.
() 2 3
MR. HOFFMAN:
DR. WALLIS:
Okay.
I'm sure you will do it, but how do 4 you assure that you find enough of those?
l 5 MR. HOFFMAN: Okay. The other thing we rely on 6 again is the regulatory process. If a month from now we 7 discover a new aging effect, the Agency is going to take 8 whatever action is necessary. It might be a generic letter, 9 a bulletin, if it's appropriate. And that will then become 10 part.of the current licensing basis, j 11 MR. GRIMES: And I'd also like to add that as BG&E 12 goes through and describes the review that they did, the 13 scope of the review is generally conservative with respect 14 to what BG&E refers to as plausible aging effects, what
() 15 others refer to as applicable aging effects, even if they 16 have not yet been manifest on a particular system. If it's 17- possible that they might occur in the future, then 18 provisions are made for some kind of inspection or 19 maintenance practice. And so to that extent we have part I 20 of -- we have reasonable assurance that if things become 21 manifest in the future that we will find them.
22 DR. BONACA: I have a question. As a result of 23 this process, do we have any safety-related passive j 24 components that are not under an aging review or any one of 25 these particular reviews for which, for example, there are O ANN RILEY & ASSOCIATES, LTD.
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155 1 no commitments to inspections?
() 2 3
MR. HOFFMAN: All passive safety-related components generally are in scope.
4 DR. BONACA: Okay.
5 MR. HOFFMAN: The only exception might be, it came 6 up in discussion with the industry, is some applicants for 7 their own purposes may have included nonsafety with safety, 8 they've upgraded them to safety just for administrative 9 purposes on site. In those cases those, you know, they 10 would be allowed to exclude.
11 DR. BONACA: During the subcommittee presentation 12 we heard about some disagreement between the staff and the 13 applicant for inclusion of the internals in some inspection 14 program.
( 15 MR. HOFFMAN: Well, the reactor vessel internals 16 are definitely in scope.
17 DR. BONACA: But originally through the process, 18 the application of the applicant, through the process, did 19 not identify that. Is it true?
20 MR. GRIMES: Not that we're aware of.
21 MR. DOROSHUK: My name is Bart Doroshuk, and I'm 22 the project director for the Calvert Cliffs license renewal 23 project.
24 There was a particular shroud bolt in the reactor 25 vessel internals structure that there was a particular aging ANN RILEY & ASSOCIATES, LTD.
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156 1 effect, stress corrosion cracking of these particular bolts I
() 2 3
that are basically inside the internals themselves, and the discussion that is going on is whether or not that 4 particular aging effect is in fact something that we need to 5 manage. And if that is determined that we need to manage 6 that aging effect, then what are the options available to do 7 such. And I believe that was -- that is a subject of an 8 open item, that it's undergoing discussions, but the reactor I i
9 vessel internals has always been in scope.
10 It centered around whether or not the belts 11 .actually performed a function other than from a maintenance 12 perspective of being ab]e to lift the reactor internals out 13 of the assembly, out of t. reactor vessel.
14 MR. GRIMES: Dr. Bonaca, I would also like to
() 15 clarify that'during Dr. Lee's presentation of the safety 16 evaluation conclusions, we are going to identify a number of 17 areas where the applicant has proposed a one time inspection 18 to verify that t.here is no evidence of the need to manage a i 19 particular aging effect. !
20 We have looked across the whole scope of passive, 21 .long-lived systems, structures, and components and the 22 safety evaluation describes our conclusions relative to how 23 those aging effects are going to de managed, or whether they 24 .need to be managed. So that will be part of the back end of 25 the staff's presentation.
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157 1 DR. BONACA: Because that was really where I was
() 2 going. I mean there are 25 years of experience on this 3 plant and there is some proposal to just to do one time 4 inspection and that should cover all the remaining life of 5 the plant. The question is, how do you identify a new 6 failure mechanism? Maybe you have a radiologic to address 7 that.
8 MR. GRIMES: No, the safety evaluation went 9 through those proposed one time inspections and we have an 10 open item associated with -- we felt that there were some of l
11 those that should be periodic, and we are going to continue !
12 to pursue that with Baltimore Gas & Electric.
13 DR. BONACA: Okay.
14 MR. GRIMES: But we tried to be very careful about 15 making decisions about whether or not we felt a one time 16 inspection was appropriate to dismiss the need for an aging 17 -- to manage a particular aging effect. That we still have 18 the defense-in-depth if this, if the aging effect becomes 19 manifest in the future, the quality assurance program can 20 catch it, the NRC events assessment can catch it. We can 21 always come back later and discover that maybe the one time 22 inspection, you know, didn't work out. But we are 23 comfortable that that will manage itself.
24 DR. BONACA: Thank you.
25' DR. FONTANA: Any other questions? All right.
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158 l
1 Thank you. j 2 The next presentation is by Mr. Bart Doroshuk from 3 BG&E.
l 4 MR. DOROSHUK: Good afternoon, Mr. Chairman and 5 members of the ACRS. On behalf of Baltimore Gas & Electric, )
6 my name is Bart Doroshuk, and I am the Project Director of 7 the License Renewai Project at Calvert Cliffs. I would like 8 to extend our appreciation for the opportunity to provide 9 you our comments today.
10 The overall objective of my presentation is to 11 provide the ACRS with an overview of the integrated plant 12 results, which means the aging effects analysis, aging 13 management review and programs, as well as the time-limited 14 aging analysis results for the plant, and-to discuss the 15 . process we went through to determine the results. And then 16 I will spend a small amount of time, if it is available, to 17 discuss the implementation status of the findings submitted 18 in our application.
19 I would encourage the committee, feel free to 20 interrupt me and ask questions as we go. I think that is 21 the ground rules we have been observing.
22 I would like to just point out that Calvert Cliffs 23 is a two unit CE designed site built by Bechtel, and the 24 Unit 1 plant went into operation commercial, or got its OL
! 25 in 1974, Unit 2 in 1976. It is located about 60 miles ANN RILEY & ASSOCIATES, LTD.
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E l J
159 1 southwest of Washington, D.C. Each unit is 2300 megawatts l i
[))
2 thermal with an output of 860 approximately electric.
3 The site, which is shown here, is a 2300 acre 4 site, of which the plant itself, the facility, occupies only '
5 about 10 percent of that site. The rest is farmland and i 6 wooded areas and a wildlife habitat maintained by BGE and l
7 was subject of the environmental report as part of the 8 license renewal application.
l 9 The overall goals for Calvert Cliffs, the number l
10 one goal is nuclear safety. If that goal can't be achieved l 11 and maintained, license renewal will not be pursued as the l 12 option of choice. That is the number one goal we will have i
l l 13 to make whether it be license renewal or not. l 14 Another goal for the plant by BGE is to remain
/
l
( ),) 15 cost competitive as we approach deregulation, and 16 maintaining that careful balance between the safety goals 17 and the appropriate cost competitiveness. Along with that 18 is to mitigate the stranded assets, a timely topic, a: d I 19 guess the catchy phrase for the capital still on the books, 20 and establish a decommissioning fund by shutdown.
21 DR. WALLIS: Now, there is no balance between 22 safety goals and being competitive.
23 MR. DOROSHUK: That is correct, sir. You either 24 are safe or you are not operating.
25 DR. WALLIS: Right.
[]
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160 1 MR. DOROSHUK: Another goal is to continue to be
() 2 3
an asset to our customers and stockholders, as well as stakeholders in the Maryland area. And in achieving all 4 that, we also have to retain the ability to invest wisely in 5 the plant.
6 The approach that Calvert Cliffs has taken at the 7 plant has been a teaming approach. We have referred to it 8 as a life cycle management approach. It is, in our opinion, 9 broader than the focus of license renewal. It is an entire 10 evaluation of the facility from top to bottom, not just 11 addressing the technical environment issues, but all of the 12 surrounding issues involving al the state, local, political, 13 federal issues that you would have to look at for running a 14 facility.
() 15 The approach we have taken has been to establish 16 an engineering team. We did this in 1989. The staff of 17 that team has been approximately 25 full-time engineers for 18 the last ten years, and that has grown based on the amount 19 of work we have done, we are doing in the particular year, 20 and at some points, I think in 1997, we were up over 45 21 people for the entire year, just for the life cycle group at 22 the plant.
23 There have been other teams that we have 24 established throughout the company that have been 25 coordinated by this group to ensure all of the issues
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161 1 surrounding the life cycle of the plant. They are being
( ) 2 addressed appropriately. These integrated teams have been 3 there to evaluate the plant beyond the typical planning 4 horizon. The solutions and the recommendations that the 5 teams have come up with, depending upon the issue, have been I
6 used using decision analysis techniques showing both j 1
7 long-term and short-term benefits.
8 DR. APOSTOLAKIS: Do you mean formal decision 9 analysis?
10 MR. DOROSHUK: In some cases we have used formal 11 decision analysis, specifically when we looked at the 12 facility as a whole. And we modeled the plant from a 13 qualitative standpoint and then we quantitatively modeled in j 14 a cash flow model, various types of cash flow. ;
()
J 15 DR. APOSTOLAKIS: This is in your petition?
16 MR. DOROSHUK: No, this was not -- this would not 17 be part of the application itself. It is part of the 18 internal work we did looking at the entire life cycle of the 19 plant. And those types of models range from the standard 20 discounted cash flow type of looks to trying to model the 21 market place using probabilistic techniques. And then 22 trying to -- what we referred to as test the model giving 23 various stressors in the areas of concern, whether it be 24 long-term shutdowns, plant failures as a result of aging and 25 other types of drivers that might change the results.
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162 1 DR. APOSTOLAKIS: Thank you.
i[)
1 V 2 MR. DOROSHUK: The recommendations and actions 3 that came out of all of our analysis over the last 10 years l 4 have been through an integrated implementation and it is l
l 5 ongoing today. Our focus has been to ensure that the 6 customer, i.e., whether it be the plant engineer or the 1 7 maintenance engineer, or the inspector in the field, the end l
8 user was part of the problem definition, part of the 9 solution development, because that end user will be the one 10 who owns the findings 10 years from now. And it gets to Mr.
l 11 Wallis' discussion earlier on how do you deal with the human 12 factors issues and change.
13 We believe that we have a very knowledgeable team j 14 today and a very knowledge plant. We think that we have a l A
( ,) 15 very good handle on the recommendations and outputs and the 16 findings, and the findings in the SER, the knowledge of 17 license renewal, the knowledge of plant aging. Our focus it 18 to make sure that the individuals running the plant in 2010 19 and 2012 have the basis and the reasons as well. So we feel 20 that is a very important part, however, it is not a part of 21 the proper review, the actual formal review of the 22 application.
23 The status of our review was that the application 24 was completed in early '98 and then submitted to the NRC in 25 April. There was a series of reviews and docketing and then
(]
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c-l 163 1 questions were issued by the NRC in the fall. This is a i
- 2 very high level pass-through and which we responded to by
{
3 the end of 1998 both on the safety side and the '
4 environmental side.
- 5 The regional inspections, which were three that 6 were done it two actual site visits encompassing three 7 weeks, were conducted on the scoping part of the review, of 8 the application, to ensure that we had implemented the 9 scoping methodology and come to the results that we said we 10 came to and they verified that through their inspection 11 process in February and found that to have been an ef fective 12 and acceptable implementation of the scoping. I 13 In April a two-week review of the aging management l 14 reviews that were conducted as part of the application, that 15 team again returned and looked from the top to bottom, and 16 this has been -- this was a very extensive inspection, both 17 on scoping and aging -- and concluded after that inspection 18 that we had effectively and in an acceptable manner 19 developed an aging management program for the renewal period 20 and that inspection report is yet to be issued but we 21 believe those to be the conclusions.
22 Those were important -- that was a very important 23 set of milestones. The draft supplemental and environmental 24 impact statement was issued in March and the SER was issued l
25 in March as well. There are 28 open' items and 20 l
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164 1 confirmatory items in the safety evaluation report that BG&E 1
() 2 3
and the NRC are continuing to work and discuss and to go to closure on and those will be the subject of the second I
4 presentation -- third, I mean. l 5 With respect to the overall process, this is a new 6 process. We believe that the Part 54 and Part 51 revision 7 do work., We believe that you can execute both rules and you 8 can get to a set of results which we believe that the 9 finding in 54.29 can be drawn from. There are areas for 10 improvement but you expect that with a new process. It has i 11 not been an easy one but we think that overall we have been 12 making very good progress.
13 Now shifting to the actual --
14 DR. POWERS: You titillate us with this --
A
( ,) 15 MR. DOROSHUK: Excuse me, sir?
16 DR. POWERS: You titillate us with this "we think 17 there are areas of improvement" -- please don't dodge that I 18 bullet a little bit. l 19 MR. DOROSHUK: I didn't mean to dodge it.
20 You discussed it during the last presentation, 21 which is what do you do with these programs that you do the 22 components and you look at the aging effects and you find, 23 goodness, I have an EQ program that does all of this -- how l 24 much effort should it take a licensee to explain that to the 25 NRC, who regulates the program? And that is a very classic l
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165 1 example of an existing program and we trounced all over that
()
i 2- during this first time through and the licensee -- we got 3 nervous that they were maybe wandering into the areas they 4 shouldn't wander into and they were probably concerned about 5 the same thing -- would they have to do this for every l 6 licensee?
7 So there was some concern with regard to that, but 1
8 we did conclude that in fact the EQ program is an acceptable 9 aging management program, so being first we are expected to l 10 run through some of these ringers for a little longer time, L
11 but what about Plant Number 3, 4, 5 or when you have eight 12 plants in here at the same time? The industry wants to 13 ensure the process remains stable. The NRC wants to make 14 sure they can review them, so the existing program areas,
() 15 when you see some of the results, you are going to see that, l 16 yes, there is an area that is fertile for efficiencies.
17 Some of the other areas I guess, I don't know --
18 that is probably the big one, but I wasn't prepared to go j 19 down an entire list and I guess that would be a good 20 example.
21 MR. GRIMES: Clearly the NRC Staff agrees. As a 22 matter of fact, we want to get some efficiency and --
23 DR. POWERS: Well, I think that this issue of 24 -efficiency is an issue that the Commission is extremely 25 interested in and that-at some time we are going to have to
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166 l
1 discuss lessons learned here. I don't know when that is. J
() 2 MR. GRIMES: We will arrange to -- we can discuss
}
3 that separately after we get over, at least get through the 4 first two renewal applications, and I also -- we will be 5 sharing with you our Commission paper on credit for existing 6 programs, which is another area, and we have been sharing 7
with the committee the results of what we refer to as the 8 generic renewal issues where we try and dispose of some of 9 the questions about how to treat particular aging effects.
10 It took us some time to develop a position on the 11 treatment of fuses for the scope of license renewal. That 12 was difficult for us, but now that we are over that we can 13 move on. We can move forward and we are not going to spend 14 time worrying about that one.
() 15 Similarly we have gotten through some other areas 16 where there are questions about where is the component, what 17 appropriate component level, what are the appropriate aging 18 effects, and we intend that we would have a feedback 19 mechanism to continue to roll those into improvements to the 20 standard review plan.
21 I think it would be appropriate probably next fall 22 when we hope to start nailing down some of the details in 23 the license renewal process to take it to a production 24 level, and we probably want to bring the guidance l 25 improvements in the standard review plan to the advisory I
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167 l
)
1 committee and the CRGR and see if we can't put some more i l
2 stability into the process for the future.
l
(
l 3 MR. DOROSHUK: What I will do now is I want to go l
l 4 over how Baltimore Gas & Electric conducted the integrated 5 plan assessment, and what I've provided here is a very l 6 simple flow chart that illustrates a very complex process I 7 and a very detailed process. The rule itself only requires 1
8 us to tell you or put in the application, if you will, what l l
9 the answer is.
10 It says give us a list of structures and 11 components that are subject to an aging-management review 12 and describe the aging-malegement programs that are going to j 13 manage the aging. However, we recognized early on that this 14 truncated story needed some expansion, and so what was in r\
( j 15 the application itself is something developed between the 16 NRC and BGE, is what is the overall story. And we'll talk 17 about that a little bit.
18 But this process starts with the entire plant and 19 all of the systems and structures of the plant, and 20 determines using the rule criteria which systems and 21 structures of the overall plant are within the scope of 22 license renewal, meets one of those requirements. It does 23 this by looking at what functions the system and structure 24 perform against the rule criteria. Then it determines what 25 components contribute to those intended functions.
(}
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1 168 1 So I'll go back and forth to this particular --
( 2 the next slide, and what this tries to do is to show you 3 that we started out in the plant with 96 systems and 25 4 structures. That encompassed the entire facility. The 5 systems that had functions that met the rule requirements, 6 there were 59 of the 96 systems. And there were eight 7 structures of the 25 that met the requirements of the rule, 8 We then looked inside those systems and structures 9 and'took those functions that caused them to be in scope and 10 identified every single component that contributed to that 11 function, active or passive, we didn't care. Then to 12 determine the actual population of components requiring the 13 aging management review, we then took them through this 14 process that first asked were the components that
( 15 contributed to the intended functions, do they have a 16 passive or active function? And if they were active, they 17 were not subject to an AMR review. They were covered by the 18 maintenance rule. They were excluded by the statements of 19 consideration.
20 Then looked at the remaining, those passive 21 components both of systems and structures and asked 22- ourselves and determined whether they were periodically 23 replaced by a commitment in the licensing basis so that that 24 commitment would continue to carry forward. And if they 25 were, they became not subject, because they weren't going to
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169 1 be installed for longer than 40 years, and that was the 2 criteria.
3 Then we asked were there some parts of the plant 4 or some pieces of equipment that were excluded by the rule 5 specifically, and those were dropped out too, and that left 6 us with the residual parts of the plant that had to go into 7 an aging-management review. And that's the first part of 8 the integrated -- first deliverable, if you will, formal' 9 deliverable of the aging-management review. However, the i
10 rule required us to describe this and just report those 11 results.
12 Then we took the components and broke them into --
13 if you take a look from a -- you've got a system level, then )
14 from a system level you go to the components. Those 15 components were the valves, piping segments, cables, they 16 were with some grouping capability that we were able to 17 group them in, all hand valves, all check valves in a 18 particular system, determine the aging effects that we're 19 concerned about, and looked at were they managed by existing 20 activities or if they weren't, were we able to modify the 21 existing programs that were close but not quite there, or 22 did we have to develop a new program in its entirety.
23 What you see in the application is we broke it 24 down into system chapters, so out of these 59 systems, they 25 were' included in 21 chapters. There were eight chapters O ANN RILEY & ASSOCIATES, LTD.
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170 1 that dealt with commodities, and that would be like cables 2 or electrical panels, things that were system -- plantwide 3 in every system but we felt that we'd just discuss them once 4 instead of every single chapter. We discussed in five 5- sections the eight structures. And in each one of these 6 chapters you see the breakdown of the components.
7- So that is a quick overview of how we got to the 8 application from the aging-management review using this 9 process. I just want to pause here to see if there's any 10 process questions that the Committee may want to explore.
l 'll All through here is where you use your operating l l
12 experience, your plant experience, your program reviews, we l 13 worked with all the plant, like I said before, those 14 integrated teams.
15 DR. WALLIS: There were 96 systems and 59 were 16 scoped, and then there were 21 chapters on them.
l 17 MR. DOROSHUK: Right.
18 DR. WALLIS: Does this mean that you dropped l -19 certain systems at each stage?
20 MR. DOROSHUK: No , we combined some.
21 DR. WALLIS: Combined. Ah, But 96 got a 59 by l
l 22 what process?
23 MR. DOROSHUK: The process which is the step 1, 24 which is to look at the system functions itself.
25 DR. WALLIS: Ah, okay.
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I 1 i
171 1 MR. DOROSHUK: And the intended function to the
() 2 system said.were these intended functions met the three 3 categories of the rule, and those three categories, are they 4 safety-related or are they non-safety-related, that whose 5 failure could cause the safety-related failure, and then you 6 had the five regulated events of EQ. Notice there's no 7 active-passive division at this point. The active-passive I
l 8 division doesn't come until you're actually at -- '
l 9 DR. WALLIS: 96 went into active-passive?
! 10 MR. DOROSHUK: We had -- yes, 96 of the systems 11 were reviewed --
f 12 DR. WALLIS: And then 59 came out of where in that 13 diagram?
14 MR. DOROSHUK: It came right out of here.
(/ 15 DR. WALLIS: I'm just trying to relate it, 96 went 16 in --
17 MR. DOROSHUK: Right here. Assess is within J
18 scope. l 19 DR. WALLIS: And 59 came out of that box?
20 MR. DOROSHUK: 59 came out of this box, and then 21 we took the 59 systems and then broke them down into 22 components, all components that contributed to these i
23 functions. And.then we brought those function by function, 24 component by component, through.here.
25 Whether it was active or passive, you took the ANN RILEY & ASSOCIATES, LTD.
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172 l
1 feedwater system and determined the feedwater system within
/\ 2 scope for all sorts of different reasons.
1 U l
3 DR. WALLIS: Everything went through the whole 4 process or went through enough of the process before it was 5 dropped out.
6 MR. DOROSHUK: That's right.
7 DR. WALLIS: Okay. That's all.
8 MR. DOROSHUK: Any other questions on the process?
l 9 Okay.
10 DR. FONTANA: Yes.
11 MR. DOROSHUK: Yes, sir, i
12 DR. FONTANA: How long did that take?
l 13 MR. DOROSHUK: Several years. It's a very 14 manpower-intensive -- I've referred to it, you're really
() 15 performing surgery on your licensing basis from the hardware
)
16 perspective and from the licensing basis, and you're mapping 17 every single component to its --
18 DR. POWERS: You know your licensing basis better i
19 than anybody else --
20 MR. DOROSHUK: We know it now. If you didn't kncw 21 it before you started, you know it now. And the reason it 22 took us several years is because in the middle of it the 23 rule changed and we were originally scoping when the rule l 24 required us to include all active and passive, and so we 25 were taking actually the first seven systems had gone O ANN RILEY & ASSOCIATES, LTD.
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173 1 through this process without any active or passive 2 screening.
3 So -- which actually was a benefit to us in the 4 industry, because what it did allow us to show when the rule 5 was being considered changed in 1993 and 1994, because that 6 was when we were considering is active an important part, 7 when we took those seven systems through, we had like an 8 8,000 components as a sample population, and we looked at 9 the active components and determined actually with the plant 10 maintenance-procedures that over 95 percent of those active 11 components, whether or not they were in the maintenance rule 12 now, were being replaced before the 40-year period. And 13 they had a history of replacement. So that actually fell 14 into giving the industry confidence that that active
() 15 exclusion was reasonably sound. So it wasn't for nought.
16 We got the pleasure of doing it that way, though.
17 It's a lot of paper, but it ended up being a lot 18 of value.
19 The application itself sits on top of a 20 significant amount of information as we've kind of been 21 dancing around. What you see here is just an illustration, 22 and this is the best way we try to visualize it in our 23 mind's eye, the application sits on top of the aging 24 management reviews for each system and structure. Inside 25 those aging management reviews are either the direct results 0,
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174 1 or references throughout tne entire -- this pyramid, and I
() 2 just walked through it.
l 3 You see the active-passive screening, the actual 4 broad scoping of the plant, which is based on the licensing 5 basis of the plant, the Q-List, the safety analysis, 6 drawings, procedures, tests, inspections, the NRC documents.
- 7. When you get into the aging-management review, you 8 start digging into the plant experience and to external 9 documents and to all the way down to textbooks. And so what 10 this document that was reviewed by the staff incorporates is 11 a significant amount of references. And in fact almost I 12 every sentence in the application has a direct reference to 13 something in this pyramid, and you can trace it back to 14 whatever our conclusion was. !
O 15 And I'd like to at least acknowledge at this
( /
16 point, this is what that regional inspection did when after 17 the headquarters staff gets, at least this is the way we see 18 it, gets through reviewing the process and the results, the 19 region comes out and pulls a thread all the way down to 20 every one of these things, and it's quite a thorough 21 evaluation.
22 The goals of the aging management review are to 23 demonstrate that the effects of aging of structures and 24 components within the scope of license renewal, and subject 25 to an aging management review, are adequately managed.
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1 l
175 1 Calvert Cliffs ensures that this is accomplished by either
) 2 recognizing that there is a direct replacement refurbishment 3 or comprehensive performance and/or condition monitoring 4 program in place, or you could have an EQ program, or you 5 will go through a very detailed aging effect component by 6 component evaluation, looking at the effects on the 7 functions, and then individually mapping them to the 8 particular program that you are going to use.
9 This option here did not prove to be very useful.
10 There are some complex assemblies that I believe we applied 11 this to such as air compressors that ended up not being in 12 the scope of license renewal in the end, but you are not 13 going to take an air compressor down to every tube and wire.
14 We ended up realizing that those assemblies are performance k) m 15 tested by STPs, et cetera, like the maintenance rule 16 requires you to do. So this did not prove to very fertile 17 with respect to avoiding a complete aging meeting review, 18 but we thought it might.
19 The necessary elements that we are looking at when 20 we finally get to the component level, the environment, the 21 materials, the stressors, the operating experience, when we 22 finally get to that level, and this is at the component 23 level itself and its individual environment, we are looking 24 at -- does the program have a method, a periodicity, 25 acceptance criteria that is relative to the elements of
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Il 176 1
1 concern, the intended functions, the aging effects that 2 would tend to degrade the ability of the component to 3 perform its intended function? Was there reasonable 4 operating experience that exists that this program was and 5 will continue to perform its aging management?
6 And when we were -- when we structured this, we 7 were kind of going after it from a two-way strategy. One 8 for mitigation -- and most of our components, I stayed at 9 the component level, have a two-prong. strategy. We looked !
10 for mitigation. Is there an activity that we can put in l
11 place or is already in place that will mitigate the aging? .
l 12 -And then, can we come through and confirm it by doing 13 inspections? So we rely very little on analyzing things 14 away on paper. We are looking for direct measurements,
() 15 confirmation through direct measurements.
16 We also look at the continued technical l
i 17 effectiveness of the actual aging management program. Is it
! 18 a self-correcting or a learning activity? Is it -- what is l
19 the foundation of it? Is it based on industry standards, 20 acceptance standards, and is it administrative 1y controlled?
21 So that there is some configuration management issues, those 22 types of things are addressed a la the previous presentation l
! 23 on 50.59.
1 24 When we looked at the bottom line, these are the 25 statistics. The existing programs, modified programs and O ANN RILEY & ASSOCIATES, LTD.
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1 1
177 l 1 new programs. There are about 456 actual programs that we l
) 2 credited in the application, of which 329 existed and we 3 didn't feel need to be changed at all. 101 of these 456 had 4 to be modified slightly by either -- you either put the 5 inspector in the vicinity of the component to do a 6 particular activity, and we needed to turn that inspector 7 and look for a particular aging effect. That is the type of 8 modification. Or we were actually putting the component 9 into the population of the program, and then there were 16 10 new programs. So that gave us a lot of confidence that the 11 plant, in fact, the maintenance strategies were addressing 12 aging issues in an acceptable manner. It was good news.
13 These existing programs broke down into the 14 following categories. There were 54 surveillance tests or
) 15 STPs. There were five special test and inspection 16 activities that we were doing, that we will continue to do.
17 Maintenance procedures, engineering programs like fatigue 18 monitoring, operational procedures such as system walkdowns, 19 chemistry procedures. There were 10 maintenance programs 20 that are more formalized and then out of the PM program, 21 there were 309 activities that made up the 430 existing or 22 modified.
23 The new programs, there were three categories.
24 There were six that we were going to extend existing 25 engineering analysis on. There were new evaluations, three I' ANN RILEY & ASSOCIATES, LTD.
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178 1 new evaluations we were going to perform, and there were
<~
2 primarily -- this was the bulk of them. There were the new (N) 3 inspection programs which were really -- these are the areas 4 where we found that we typically, in the life of a plant you 5 typically don't go into the areas. These are digging up the 6 pipes underground. These are going into parts of a system 7 that you typically, you know, either you are looking for 8 aging effects that are way on the periphery, that these are 9 unlikely but we couldn't prove they weren't going to happen, 10 so we want to go in and confirm that those aging effects 11 through a one time inspection would be -- would confirm 12 either that it is not happening, or if it is, we would then 13 instigate an ongoing or periodic inspection activity.
14 I am going to shift gears quickly to the C\ 15
( ,/ time-limited aging analysis part, because that concludes the 16 aging management programs, and this is just a repeat of what 17 Steve talked about. These are the six criteria for an aging 18 -- for something to become a TLAA. These two, first two 19 involve assumptions, a 40 year assumption and incorporated 20 in the CLB are the process we -- these are two key things we 21 looked at in identifying, and then we used the bottom four 22 to actually refine a very large screen.
23 We have a docketed, an electronic docket which is 24 also OCR'ed, or it is word-searchable, and we created 25 several strings and categories of items to go through this 1
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179 1 large amount of information and we actually ended up
/~
l 2 reviewing over 1700 current licensing basis documents that
(
3 fell into these -- either had some time-limited issues on it 4 or met some of the other screening criteria we established.
5 Out of those 1700 documents, we ended up with six 6 areas needing review, six TLAAs plus EQ, which is a lot of 7 individual cales, right. And that was described in one 8 particular chapter of the application.
9 Now, recall that Part 54 requires us to ensure the 10 analysis remains valid. It has been or will be projected to 11 the end of the period of extended operation, or I have got 12 an aging -- or I can manage that TLAA by managing the aging 13 that was the fundamental assumption in the calculation.
14 DR. WALLIS: Can you give an example of analyses
/~%
(,/ 15 that do not remain valid?
16 MR. DOROSHUK: You might have a fatigue analysis j 17 of a surge line that looked at thermal stratification that 18 you might have done because it was an operational issue you 19 discovered. You would have done it to look at the 40 year 20 period, because that is what you -- when you discovered 21 things in 1982, you didn't think about 60 years. So we, in 22 fact, probably did one, I think we did one through the 23 Owners Group and so we had a 40 year calc. Is that right?
24 But, however, we are going to manage that 25 particular calculation that wasn't analyzed for a 60 year
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l 180 1 period, because we are going to manage that by counting the 2 actual cycles on that location.
3 DR. WALLIS: It might be that there is an equation 4 that is valid out-to 40 years but not to 60, so you have to 5 modify the analysis.
6 MR. DOROSHUK: Yes. In fact, here where the --
7 DR. POWERS: That is fairly -- it is a very common 8 thing for anything that is cycling, to have done the 9 analysis with a relatively conservative assumption on the 10 number of cycles per year. And that because of the 11 operational experience, you will find that you reduce the l 12 number of cycles. That is a very common thing.
13 MR. DOROSHUK: Yes, sir.
14 DR. POWERS: What kind of level of conservatism do 15 you think you have on those things?
16 MR. DOROSHUK Well, in the case of the class 2 17- piping in the feedwater system, which has got design cycles 18 of 7,000 cycles, that 7,000 cycles, we don't believe would 19 be -- even come close to, because it is limited to the 20 number of heat-ups and cool-downs we would have on the 21 primary side where the class 1 piping is adjacent. Now, the 22 only interesting thing about that particular set of piping 23 .was that we have a thermal stratification issue in a 24 particular run, so we are not worried about the 7,000 cycles 25 as much as we are worried about the damage occurring as a l
l l
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181 1 result of thermal stratification.
I ) 2 These are the TLAAs, EQ. We had a number of 3 irradiation embrittlement ones, pressurized thermal shock, 4 heat-up and cool-down curves, the L-top curves, fatigue.
5 There were several locations in the RCS that will need to be 6 addressed. Main steam piping had a location at the AFW 7 pump. There was an analysis of the containment liner plate 8 that we are updating with the staff. The containment --
9 DR. WALLIS: Why does that fatigue?
10 MR. DOROSHUK: Marv, do you recall that one?
11 MR. BOWMAN: I am Marvin Bowman with BGE. That 12 was a case where we found some discussion in the FSAR that 13 indicated that there might be fatigue as a result of the 14 temperature changes, seasonal and plant operation.
15 MR. DOROSHUK: Right. It assumed -- the FSAR says 16 that where there was 40 cycles of annual outdoor temperature 17 variations and so we will go back. But these are full range
- 18. cycles.
19 DR. WALLIS: Very few cycles.
20 MR. DOROSHUK: Right. But we talking probably 21 minus 30 to --
22 MR. BOWMAN: We couldn't conclude that it didn't 23 need to be looked at, and so we included it.
24 DR. UHRIG: Could there also be cycles associated 12 5 with new fuel going in?
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182 1 MR. DOROSHUK: Fuel would not stay in the plant rx !
( ) 2 greater than two years to three years, so it would be three 3 years -- four years. Do I hear five?
4 MR. BOWMAN: Six at most.
5 DR. UHRIG: I am talking about from the time it 6 came out to the next time you put fuel in. Thermal load.
7 MR. DOROSHUK: That would be part of the design on 8 the fuel and wouldn't be a 40 year issue, it would be more 9 of the actual fuel life for the particular assembly.
10 DR. UHRIG: I was talking about the liner.
11 Anyhow, go ahead.
12 DR. WALLIS: I guess you have intrigued me now.
13 You say seasonal variations. What is this time constant for 14 the containtant? Heating up, does it heat-up in a day or a b
( ,1 15 week or overnight? Because it does respond to seasonal 16 variations, but with what sort of a time response? !
17 MR. DOROSHUK: Well, I guess I didn't -- I didn't 18 want to intrigue you that much today on this topic.
19 DR. WALLIS: Well, it sounds like a yearly basis.
20 That is much too long, though. So I am kind of curious.
21 DR. KRESS: It has got a big surface area.
22 DR. WALLIS: A big surface area. Does it heat-up 23 when the sun shines on the containment?
l 24 MR. DOROSHUK: I don't have that information. l l
25 DR. POWERS: It definitely does. '
l i
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183 1 DR. KRESS: I would say the time constant is not
() 2 more than a day.
3 DR. WALLIS: So it is more than 46 cycles.
4 MR. DOROSHUK: Right.
5 DR. SHACK: It is diurnal probably, but I mean 6 they: are relatively small cycles, I mean by --
7 DR. KRESS: Those cycles are so small, you don't 8 know where --
9 DR. WALLIS: It is the'same way that the windows 10 crack in my house when the sun shines on them.
11 MR. DOROSHUK: Well, we would hope it would not be 12 the same way, right.
13 DR. POWERS: Phenomenologically, some of them are 14 not affected.
) 15 MR. DOROSHUK: And those -- EQ, those were the 16 TLAAs for Calvert Cliffs, and there is one particular open 17 item that, however, we I think worked to closure on on one 18 category of fatigue. It is not shown here, but it will 19 probably be shown in the staff presentation.
20 Where we are at is we are implementing these 21 activities. Either the existing programs are being captured 22 in our licensing commitment process, the modifications to 23 the programs are being initiated and changed as we speak. I 24 Me have been doing this for the last year or two, And the 25 new programs are under development or are already being ANN RILEY & ASSOCIATES, LTD.
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i 184 1 implemented. And what we are also at this point looking at
() 2 is how do we institutionalize these commitments inside the 3 normal site management, so that when the UF hardware 4 changes, when there might be a licensing basis change that 5 might come out of a new regulation? How do we then go back I 6 into and perform a mini-IPA, if you will, on what might used 7 to be non-safety-related equipment? You might end up having 8 that now come in scope. The programs, the basis of these l 9 programs capturing that.
10 And making sure that you've tied in these aging effects or 11 Aging Management Review findings, although we haven't 12 discovered anything new here with respect to aging. It's 13 been happening. It is a new focus and so you do have to 14 look at your operating experience units and making sure that O
\ ,/ 15 when they do get a hit either in the industry or on our own 16 site that when that aging. experience comes into the 17 engineering organizations it is-processed in a manner that l
)
18 takes into account the 60-year horizon, not the 40-year 19 horizon.
20 We have not found any aging that automatically 21 starts happening at year 40 or in fact changes in any way, 22 shape or form --
23 DR. SHACK: Was that a shock to you?
l l 24 MR. DOROSHUK: No. No --
l 25 DR. SEALE: Quite the contrary.
L l
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l
185 1 MR. DOROSHUK: It was anticlimactic, I guess.
()
- 2 (Laughter.)
3 MR. DOROSHUK: A lot of money to find that you are 4 doing a lot of good work.
5 DR. WALLIG: That question would seem to be are 6 there aging effects which become critical during the next 7 licensing period.
8 MR. DOROSHUK: We haven't found any aging 9 occurring in any components that would end up costing us --
10 we haven't identified any capital projects as a result of 11 this.
12 DR. WALLIS: So the horizon where these things 13 begin to become important is out to 90 or 100 years or so?
14 MR. DOROSHUK: Well, they are already here. For
() 15 example the steam generator -- ,
16 DR. WALLIS: And you know how to deal with them?
17 MR. DOROSHUK: Yes, but as a result of this 18 application, we -- you see some cables. We got like 67 19 cables we are going to replace. We will probably end up as 20 we get into some of these inspections we may find some stuff 21 but as a result of this evalustion and the operating 22 experience to date, we have not identified any capital 23 projects as replacing entire piping systems.
24 DR. POWERS: Did you in the course of coming to 25 this conclusion, you had no capital projects to go to ;
O
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186
- 1 60-year life? Look and see. Would you have any capital l
( j 2 projects if you went to 80 years life?
3 MR. DOROSHUK: The vessels themselves we believe 4 are good out beyond 80 and we have a 60-year SER.
5 DR. POWERS: Out beyond 80.
6 MR. DOROSHUK: There might be in the internals l
7 area, depending on how some of these inspections go, there
! 8 might be some areas that would need to be looked at, but we 9 didn't get there.
10 DR. POWERS: You didn't have any doubts about your 11 buried piping or anything like that?
12 MR. DOROSHUK: No. In fact, we have dug up a
! 13 number of feet of our buried piping already and inspected it 14 and it is amazing when you take off the wrap and it's brand
() 15 new. You can still see the stamps on it and it's shiny.
l 16 That's not to say that it's all of our piping system. We i
17 have replaced a lot of feet of pipe in the plant from 18 erosion corrosion. We have completely replaced our 19 saltwater system of piping above-ground.
20 DR. POWERS: That is a different set of issues 21 there. !
22 MR. DOROSHUK: Those were all aging issues.
23 DR. POWERS: Well --
24 MR. DOROSHUK: Well, vulcanized rubber wasn't 25 vulcanized very well in 1970 so --
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1 1
187 I
1 DR. POWERS: Yes, there is a big change in that. 1 f%
t
) 2 MR. DOROSHUK: But they are doing it better these 3 days.
4 DR. POWERS: Much better.
5 DR. SHACK: Just when you replace for erosion 6 corrosion, do you go to a Chrome Moly steel?
7 MR. DOROSHUK: Yes, and now in the feedwater 8 system we are using chrome -- we have gone to Chrome Moly. i l
9 That concludes -- I guess just one last thing is !
10 the schedule and where we are at and just to highlight that 11 we are, we do want to acknowledge the fact and appreciate l 12 the fact that the ACRS has moved their schedule up almost a 13 year and so we appreciate you agreeing to begin reviewing 14 the material and we certainly will be open to any more r3 i
N,,) 15 comments and questions that you have through the rest of the l 16 presentation.
l 17 DR. WALLIS: Well, everything sounds great, but l 18 are there certain issues that require more investigation or 19 more knowledge before they can be resolved?
20 MR. DOROSHUK: We have not discovered any. I 21 guess we have got a few areas that we still are trying to 22 develop the final inspection agreements with the Staff and 23 that is to refine -- for example, we said at one time 24 inspection for some areas of the saltwater and the Staff has 25 said no, but we would like to see you do it a couple of ANN RILEY & ASSOCIATES, LTD.
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'188 l 1 times so we are considering incorporating that change, but
() 2 we haven't -- we are not stuck on anything yet except for 3 maybe those --
)
I 4 DR. WALLIS: There's nothing you have identified l 5 that say the entire industry has to do research on or 6 something in order to resolve an issue?
7 MR. DOROSHUK: No, sir.
8 We have identified a number of issues that the i
9 industry is conducting research on. In the non-EQ cable 10 area there was a significant amount of research going on at 11 NRC and by the industry themselves. Clearly we are engaged 12 in that. That could result in us, if there is a condition 13 monitoring program that's developed we could implement that 14 as a result of a different set of conditions.
15 There is research in fatigue that is ongoing and 16 that has had to have been addressed. How do we adjust and 17 make sure that those issues are reviewed here on the Calvert i
18 Cliffs in lieu of a long-term generic solution, so we have i 19 come head to head with some of those.
20 DR. SEALE: The Staff made it clear that the PRA 21 and those kinds of considerations are not a fundamental part !
22 of the license renewal process itself but that PRA insights 23 could be useful in making certain value j udgments about l 24 alternative ways of doing things, inspection program timing 1
25 perhaps, and things like that.
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l l
l 189 1 Could you give us a brief idea of how you have 2 used PRAs so far?
3 MR. DOROSHUK: I think there's two areas where we 4 have used PRA. We were scoping the plant according to the 5 license renewal rule when the maintenance rule came into 6 effect, so Calvert Cliffs used the scoping results in all 7 those 0ctive components and provided the scoping for the 8 maintenance rule, and we basically married our engineering )
9 services with those of the PRA' Group to produce the 10 maintenance rule scope that is being used now, and of course 11 is in a living state. l 1
f 12 That didn't change the license renewal scope but 1 13 it allowed integration on site and so there wasn't in our i
14 mind a crack. We made sure there wasn't. 1
(~)%
(, 15 ,DR. SEALE: Yes.
16 MR. DOROSHUK: The second part, where we didn't 17 actually use PRA but.when we got into the aging effects you 18 used more of a qualitative risk assessment on, how 19 aggressive was the aging, what is the operational 20 experience. We didn't do an failure modes and effects 21 analysis in this area but you use more qualitative -- how 22 aggressive is my aging management program given the 23 aggressiveness of the aging?
24 So from the integrated plant assessment side, the 25 risk insights were more in what programs are you going to 4
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1 t
190 1 use and that was more qualitative risk assessment. On the
() 2 environmental side we did do a full severe accident 3 management analysis using our PRA. We do have a Level 3 4 PRA. We do not have the shutdown portion. We did identify 5 over 150 mitigation options which ballooned out of course 6 because they become separate and different options in and of 7 themselves and evaluated all of those, using the NRC 8 guidance for risk analysis and cost benefit procedures that 9 were used on Watts Bar, so we did the Watts Bar procedure.
10 We did identify one modification to the plant as a 11 result of that analysis and that is being implemented and 12 that is we are going to convert some doors to a watertight 13 door and that removes what percentage of the flooding risk. I 14 MR. BOWMAN: Two to three percent. )
() 15 MR. DOROSHUK: Two to three percent -- of core l 16 damage, and there were three SAMAs identified that were not 17 age related that are going to be considered by Calvert l 18 Cliffs outside of license renewal space but two of them I 19 believe are -- one is not realistic. One says get really 20 reliable batteries. Well, we just replaced our batteries 21 and we got the best you could buy so there are no better 22 batteries so this idea that you can get a 100 percent 23 reliable battery just doesn't exist so that particular SAMA 24 doesn't seem reasonable.
l 25 The second one, that we looked at was on the O ANN RILEY & ASSOCIATES, LTD.
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1 191 1 border of being cost-effective, was going in the ESFAS logic
() 2 3~
going from e two out of four to a three out of four logic, and we don't believe, even though we've looked at this and j
4 we think you could actually physically make the plant do 5 this, we don't necessarily believe that -- you might be able 6 to get analytical risks down, but from just general feeling, 7 waiting for another trip to get the real trip doesn't seem 8 logically correct to us. So we're taking a look at that, l 9 and we don't believe that that may necessarily be the right 10 thing to do.
11 And the third thing is -- I guess has to do with j 12 some fire hoses and being able to supply some fire water, 13' that's putting a truck with another hose, and so it's not a 14 big issue. So we did have a very significant look at the 15 plant from a probabilistic assessment in the EIS, which is 16 not part of this particular review, and that was reviewed by 17 the NRC. So it actually was done in a very extensive --
l 18 DR. APOSTOLAKIS: Do you remember what your core 1
l 19 damage frequency was?
20 MR. DOROSHUK: The overall CDF is 2.1 times 10 to l
21 the minus 4. And we've taken a look at the passive failures l
l 22 that are contained in the Calvert Cliffs PRA, and this is 23 literally a back-of-the-envelope, Mr. Apostolakis, because l
l 24' we were told you'd ask these questions. So let me try to 25 just -- we've taken a look at what different would this 1
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192 l 1 make. And we don't think it makes any.
()
i 2 DR. APOSTOLAKIS: This being?
3 MR. DOROSHUK: The passive failures inside the 4 PRA. And we don't think that it would result in any change i
5 in scope for our application. If you look at the passive 6 failures, they-are LOCAs, steam generator tube ruptures, 7 reactor coolant pump seal failures, pressurized thermal 8 shock, vessel failures, floods, fire' barriers, service water 9 and component coolant leakage, seismic challenges to our 10 condensate storage tanks, high-wind challenges to these 11 tanks that are all on the scope of license renewal already, 12 turbine missiles and barriers are all on the scope of 13 license renewal already, containment, instrument error 14 integrity, and the buses and power cables. They're all in i
j 15 the scope already. This is from a back-of-the-envelope 16 brainstorming session. .When you look at what passive 17 features of the plant have been modeled already, it doesn't l
18 go -- it's already included.
19 Now what gives us comfort from this is that the l 20 region inspection utilized a risk-informed approach to 21 verifying did we scope properly, and they came in and they 22 said okay, fine, we will look at some things you said were l 23 in scope, we will also look at some things that you said 24 were not in scope but are risk-significant. And they took 25 five systems and a structure or two, and they climbed I \ ANN RILEY & ASSOCIATES, LTD.
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i 193 1 through that pyramid from top to bottom in our licensing I
V) 2 basis and looked at the individual components of each of 3 those systems _or sampling and validated that in fact they 4 did not perform any of the functions required by Part 54.
5 There was one outbuilding, fire pump house where 6 we had a couple of fire pumps in it that there was a berm, a
'7 concrete berm, that was in between the two pumps, and the 8 berm is there to prevent an oil spillage contaminating and 9 catching fire to the second pump, and it was in an area of 10 50.48 or Appendix R that was gray enough to us that we said 11 fine, we'll put it in scope. So even though the rule is l 12 deterministic, I think that the Part 51 and the regional 13 inspection really did pull the string on was there 14 risk-informed information used in reviewing the application.
() 15 DR. APOSTOLAKIS: I just did a quick calculation l
16 that disturbs me.
Your core damage frequency is 2.1 10 to l 17 the minus 4 per year.
18 MR. DOROSHUK: Um-hum.
19 DR. APOSTOLAKIS: Which means according to the 20 Regulatory Guide 1.174 you would not be allowed to make a i 21 change that would be as high as 10 to the minus 5 in the 22 core damage frequency. That's what 1.174 says. You started 23 operating in 1974, so you have operated for 25 years, so if 24 there is no license renewal, you will have another 15.
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194 1 frequency is 1.5 10 to the minus 4 probability that the NRC g 2 staff has found unacceptable because your core damage V(~5 3 frequency is already above 10 to the minus 4. They wouldn't 4 allow any changes that will give you that.
5 If you are allowed to go to 60 years, and you 6 maintain your 2.1 10 to the minus 4 core damage frequency, 7 then the NRC is accepting an additional probability of core 8 damage of 4.2 10 to the minus 3, which is about 30 times 9 greater than what the NRC does not allow in 1.174. In other 10 words, if you work with probabilities, not core damage l
11 frequencies, you get a major inconsistency there, which is 12 not your problem, it's our problem. It may become yours, j 13 but right now it's ours.
14 [ Laughter.]
I~
-(j . 15 And I don't know what that means. I mean, in one-16 place we are not willing to accept an increase in the 17 probability of core damage for the remaining life of the 18 plant of about 10 to the minus 4, but we may'very well renew 19 the license of the plant for another 20 years, which means
.20 we have a probability of 4 10 to the minus 3 core damage. I 21 mean, does the total probability count for anything?
22 DR. KRESS: No.
23 DR. APOSTOLAKIS: Why not?
24 DR. KRESS: Time, these are random events, George.
25 DR. APOSTOLAKIS: Yes.
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p 195 1 DR. KRESS: It's like flipping a coin.
() 2 DR. APOSTOLAKIS:
DR. KRESS:
Yes.
3 How many heads and tails are you going 4 to get in the next 15 flips doesn't have any knowledge of 5 what happened during the last 15 flips. So you throw away 6 the 40 years, because it hasn't had the accident.
7 DR. APOSTOLAKIS: No. That is why I did the 8 calculation only for the remaining 15.
9 DR. KRESS: It's only for the remaining 15.
10 DR. APOSTOLAKIS: That's what I did.
11 DR. KRESS: Okay. Is that what you did?
12 DR. APOSTOLAKIS: Yes.
13 DR. KRESS: Okay. That's legitimate. Don't count 14 the past 40 years.
) 15 DR. APOSTOLAKIS: No. !
16 DR. KRESS: Okay.
i 17 DR. APOSTOLAKIS: So maybe we should discuss this ;
18 among ourselves at some point.
19 DR. FONTANA: I don't think we're going to solve 20 that right now, i 21 DR. APOSTOLAKIS: No, I know, and I'm sorry I 22 raised it.
23 DR. FONTANA: No, you're not.
24 DR. APOSTOLAKIS: I really am not.
25 DR. FONTANA: Any additional questions of Barth.
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L 196 1 Well, thank you very much. That's very 2 informative.
3 DR. POWERS: It was a very nice presentation.
1 4 DR. SEALE: I think you could write a book now, 5 couldn't you?
6 MR. GRIMES: While the staff is preparing to 7 discuss the safety evaluation, I will point out during the 1
8 stakeholders meeting yesterday it was Mr. Lochbaum from UCS '
9 who basically raised that same question about whether or not 20 a policy that recommends essentially increasing the risk by 11 a half again by extending the license and the Chairman's 12 response was that's not the way her statistics work. So I 13 think that there's going to be some more dialogue about what 14 the relative risk is.
{
) 15 In the meantime I would like to introduce Dr. Sam 16 Lee, who is going to chair a session that includes Barry 17 Elliott, Paul Symansky, and John Fair, who were principal 18 contributors to the staff's safety evaluation for Calvert 19 Cliffs.
20 MR. LEE: My name is Sam Lee. I'm from the 21 License Renewal and Standardization Branch, NRR. I'm going 22 to give you an overview of the staff review of the staff 23 review of the BG&E license renewal application.
24 Today, I have several in here to help me understand the 25 questions here.
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197 1 The staff review process. These are some of the
( -2 guidance documents that the staff considered when they were 3 reviewing the BG&E application. That is the draft standard 4 review plan for license renewal, which contains a lot of 5 information from the period staff review of the industry 6 reports. And we had the SOC for the license renewal rule, 7 which provides some guidance, and NEI document 95-10 8 provides guidance for the industry, and the staff has 9 proposed to endorse 95-10 in the Draft Reg Guide. And also, 10 there is an NRR office letter on the license renewal 11 process.
12 Here are additional related activities. There's a 13 lot of NRC industry management meetings. They are regular 14 meetings. And every month, the NRC division directors meet !
() 15 with the BG&E and also Oconee management to~ check up on the )
16 status of the review. And also every two months, the NRC 17 license renewal steering committee meets with the NEI 18 license renewal working group.
19 We have compiled a list of license renewal issues 20 and these are mostly NEI's comments on the draft standard 21 review plan. The objective is for the staff to work through 22 these license renewal issues and provide improvements to the 23 standard review plan.
24 The license renewal iscues are different from the 25 generic safety issues, the GSIs, which are documented in O ANN RILEY & ASSOCIATES, LTD.
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198 1 NUREG 0933. We also have a license renewal inspection
()
' ~
2 program. You heard a lot of that from the BG&E l 3 presentation. This is conducted by Region I, and they i
4 ' completed two inspections at BG&E. One is on scoping; one 5 is on aging management programs. I 6 Here is the table of content of the BG&E SER. It 7 basically follows the structure of the rule. Chapter 2 l 8 discusses the structures and components subject to aging L 9 management review. Chapter 3 discusses the aging 10 management, and Chapter 4 discusses the time-limited aging 11 analysis. And I'll go into this in a little more detail.
12 DR. WALLIS: Just to clarify, you're developing a 13 safety evaluation report without having a standard review l
14 plan because it's a draft?
' fN l ( ,) 15 MR. LEE: That's correct.
l 16 DR. WALLIS: So the two are happening at the same 17 time?
18 MR. LEE: Actually, the draft standard review plan i
l 19 has been out for like '97 -- two years. So it's a little 20 ahead of the BG&E. But it's still a draft.
21 Okay. Chapter 2 is the structures and components l 22 subject to aging management review. The staff had 23 previously approved the BG&E methodology for identifying 24 structures and components subject to aging-management 25 review. Subject to aging-management review means structures
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199
- 1- and components that are' passive, long-lived, and within the 2~ scope of. license renewal. The staff has verified the l 3 implementation of the methodology by, I guess, by a two-step 4 process. The first step is to review the systems and 5 structures and components within scope, and the second step 6 is to review whether the passive and long-lived portions l 7- have been identified.
8 After this review, we identify some open items, 9 and they generally include what we call the cascading issue,-
l 10 which is how much of the supporting non-safety related 11 structures and components should be subject to 12 aging-management review and the staff is working through I 13 this with BG&E, l 14 Chapter 3, that's aging-management review, and as 15 BG&E described earlier, the application is structured around l 16 systems. So we have twelve sections in Chapter 3 that go by 17' system by system evaluation, and because there are some i
18 programs that are common to many systems, we have pulled 19 them out and then we have a separate section that's called 20 the common aging-management program, and they range from 21 fatigue monitoring, chemistry, to walkdown, to this RD l 22 program, and I'll discuss two of these, I'll discuss the 23 fatigue and the RD, and I'll give you an example of a system 24 that we did.
25 MR. LEE: This is fatigue monitoring program.
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200 1 DR. SEALE: These are programs that currently
() 2 3.
exist that are to be incorporated into the aging management program presumably or --
4 MR. LEE: Some of these exist, like chemistry 5 program does exist, fatigue monitoring program exists, 6 corrective action --
7 DR. SEALE: Right. But the rest of them are 8 already there; you're just -- they're going to have to look 9 at 60 years now instead of 40, so to speak? !
l 10 MR. LEE. Well, actually, we look at all the I 11 programs for 60.
l 12 DR. SEALE: Yes. I understand. Okay.
i 13 DR. WALLIS: I thought they -- have they already 14 submitted this and your reviewing it or am I wrong?
l
) 15 MR. LEE: They submitted the application.
16 DR. WALLIS: It's already submitted.
17 MR. LEE: Yes, already submitted.
18 DR. WALLIS: Okay.
19 DR. SEALE: They get carried from the current 20 basis to the new basis.
21 MR. LEE: Okay. Section 3.1.1 is the fatigue 22 monitoring program. BG&E monitors the plant operation 23 parameters to track the number of transients so that they 24 can calculate the fatigue usage caused by transients at 25 limited locations.
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201 1 The fatigue usage is a term in the ASME code that
( 2 is used to quantify fatigue, and this -- and that's a design 3 limit in ASME code that the fatigue usage should be less 4 than 1, and BG&E's fatigue monitoring program would cause 5 corrective action before CUF gets to one.
6 DR. WALLIS: That makes it acceptable.
7 MR. LEE: That's correct.
8 DR. SEALE: I have an embarrassing question to 9 ask.
10 MR. LEE: Okay.
11 DR. SEALE: There is an outstanding generic issue 12 on fatigue. l 13 MR. LEE: I'll get into that in my next slide.
14 DR. SEALE: All right. l (f 15 MR. LEE: Okay.
16 DR. SEALE:
i All right. I won't embarrass you, 17 then; I'll let you embarrass you yourself. I 18 DR. MILLER: There are several outstanding --
19 there are several generic issues. J I
20 MR. LEE: This is the age-related degradation 21 inspection, ARDI. This is a new program. There are certain 22 aging effects that are unlikely except you cannot rule out 23 completely, so they're kind of a gray area, and so what BG&E 24 decided to do is they'll do a one-time inspection to confirm 25 that the aging effect is not there, and if they should find ANN RILEY & ASSOCIATES, LTD.
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202 1 it there, then the plant's corrective action program will
) 2 -kick in'and that will cause tnem to do corrective action, 3 like the regular inspection and such. And that's the 4 purpose of the ARDI. Okay.
5 Like we discussed earlier, there are open items in 6 the ARDI, and this relates to when is the one-time 7 inspection appropriate. We found places where the aging ]
l 8 effect should be subject-to regular inspections, and these '
9 are, I guess -- the two examples I put in here is the l
10 coating degradation and corrosion due to leakage. So this l 11 is going to be discussed with BG&E.
12 Here is an example of a system. Section 3.2 of 13 the SER is on the reactor vessel, the internals, and the 14 RCS. And here, we list the aging effect and the n( j 15 corresponding aging management program.
16 For example, corrosion, you get water chemistry 17 program, that's an existing program. And for the denting 18 and cracking of the steam generator, we have the eddy 19 current testing. That's an existing program. And for 20 various degradation here, we have the Section 11 ISI 21 program. That's also an existing program. And for Neutron 22 embrittlement of reactor vessel, that's a reactor vessel 23 material surveillance program. For BG&E, they have 24 additional capsules that they're irradiating for a period of 25 extended operation.
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203 1 Thermal aging of the cast austenitic steel, and
[]
L.)
2 BG&E propose a program and we reviewed that. That is 3 acceptable. It's a new program. Embrittlement of the 4 internals -- the program is a modified ISI program which 5 relies on an enhanced inspection. And for cracking of Alloy 6 600, there's an Alloy 600 program, and fatigue, there's a l 7 fatigue management program.
8 And here is the GSI-190. In the Section 3.2, 9 there is an item in the RC related to GSI-190 which relates 10 to the environmental effects on fatigue. The staff is 11 requesting a technical rationale to address the 12 environmental effect on fatigue for a period of extended 13 operation.
14 We have open items also in Chapter -- Section 3.2, F% 15 t j and some of these relate to the augmented inspection where i
16 the staff believe that additional inspections should be j i
17 performed based on operating experience such as cracking of I i
18 the pressurizer shell and small-bore piping.
19 The next chapter of the SER is on time-limited i 20 aging analysis, and here are some examples, and you have j 21 seen BG&E's list earlier. You have EQ, you have fatigue, !
22 you have prestress loss of the containment tendons and you I 23 have PTS of the reactor vessel.
24 For BG&E, the staff had previously issued an SER 25 indicating that PTS is acceptable for 60 years.
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204 1
1 DR. WALLIS: Prestress loss -- this is something i 2 that -- they've been creeping or something?
3 MR. LEE: That's correct, yes.
4 And here is the evaluation of a TREA. EQ is a 5 TREA and BG&E is proposing to use the 50.49 EQ program to ;
'6 manage the aging effects for EQ aquipment. And as BG&E 7 indicated earlier in their presentation, the staff reviewed ;
8 BG&E's 50.59 EQ program, and we have back-and-forth exchange 9 with BG&E. In the end, we found this acceptable to manage 10 aging of EQ equipment for license renewal, and that is one 11 example of the credit for existing program issue.
12 There are a lot of -- actually, most of the 13 programs for license renewal is existing programs.
14 Industry's position is that existing programs, they are h 15 acceptable for current term and they should be acceptable I 16 for license renewal before staff review, and we are going to 17 prepare a Commission paper and ask for guidance on how to 18 address that.
19 Here is the summary status. The staff issued the 20 SER on BG&E in March with open items and confirmatory items, 21 and like we said earlier, most of the programs are existing 22 programs. However, we do find places where existing 23 programs should be augmented, and we are preparing a 24 Commission paper on this credit for existing program issues, 25 which is due the end of May. And the final SER for BG&E is O,
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205 1 due in November.
(V) 2 That concludes my presentation, so if you have any 3 questions.
4 DR. WALLIS: Well, I've heard two presentations 5 which say everything is fine. I'm not quite sure what else 6 we need to do. Do we need to dig into anything in 7 particular? Is there anything that ACRS should pay 8 attention to besides saying that we were impressed with what 9 we've heard?
10 MR. GRIMES: I would like to suggest that we -- we 11 didn't mean to leave you with the impression that everything 12 is fine; we meant to leave you with the impression that 13 we've done a lot of work and we've developed a fairly 14 detailed safety evaluation that documents how aging effecte p
(,,) 15 are going to be managed, and as soon as we resolve 28 open 16 items and 20 confirmatory items, then we believe we will be 17 able to reach the conclusion that the applicant has !
18 satisfied 50.49 for which we can recommend that the 19 Commission grant this new license.
20 Sam covered the safety evaluation in terms of its 21 major areas and provided some illustrations. We were hoping 22 that you would be able to look at least across some of the 23 major programs and say that you're satisfied that we've 24 addressed it at the appropriate level or with the 25 appropriate standards. You can pick and choose amongst the
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r d 206
- 1 open items in terms of testing our decisionmaking processes.
() 3 2
There are a variety of different ways that you can develop a confidence in the work that we've done and we're prepared to 4 support you in any way that you wish to proceed.
5 DR. UHRIG: I have a question. This bullet on the 6 last slide, Commission paper on credit for existing 7 programs, is this -- what is the nature of the issue here?
l 8 MR. LEE: The nature is, I guess, like what we 9
discussed earlier about what we found from Oconee and BG&E's 10 application is about 80 or 90 percent of the programs are l
11 existing programs, programs to manage aging.
12 DR. UHRIG: Is there an implication here that the 13 Commission might not accept that?
14 MR. LEE: Well, we are asking for, I guess -- we
() 15 realize that we are trying to get some efficiency in the l 16 license renewal process. What we perceive the rule is 17 saying there is we need to review all the programs whether l 18 -they're existing or not. So a lot of resources ~are being 19 used to review 80 percent of programs. We don't want to
! 20- keep looking at Section 11 ISI over and over.
21 MR. GRIMES: Dr. Uhrig, this is Chris Grimes.
22 This issue about credit for existing programs is not germane 23 to Calvert Cliffs or Oconee because we have reviewed all of I
l 24 the programs to the level of detail we felt was appropriate L 25 to make a conclusion across the whole scope of passive 1
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1
- a. 1 1
207 l
1 long-lived systems, structures and components.
( 2 The question for the future is, will the next 3 applicants have to have their EQ program or their ISI 4 program tested the way we tested it on Calvert Cliffs and 5 Oconee, or can some things simply be taken for granted as 6 standard practices that are recognized as managing aging 7 effects.
8 So from that standpoint, this issue is one -- it's 9 forward-looking and addresses the effectiveness and the 10 efficiency --
11' DR. UHRIG: It doesn't relate to the Calvert 12 Cliffs.
l 13 MR. GRIMES: It will not result, in our view, in 14 the Commission being -- having anything to decide on Calvert (f 15 Cliffs or Oconee. i l
16 DR. UHRIG: Thank you.
l l 17 DR. FONTANA: If there are no immediate questions, 18 you have -- the committee has a draft version of a letter L 19 which I'm sure is going to go through quite a fev 20 metamorphoses before it goes through. Are there any 21 questions that you would like to ask the staff relating to 22 what you would like to put into that letter? That ia, while i
l 23 they're here.
{
24 DR. POWERS: Our attention on this letter says i 25 this is an interim report, is it not?
l l
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208 1 DR. FONTANA: Correct.
( -2 DR. POWERS: And we're going to come back --
3 there's going to be a final SER. Is our intention to write 4 on the final SER?
5 DR. FONTANA: Sure.
6 DR. POWERS: Okay. So this is simply a letter 7 that says we have not or we have identified a show stopper.
8 DR. FONTANA: That's right.
9 DR. MILLER: Staff is telling us they've seen no 10 show stoppers.
11 DR. POWERS: I know what they -- I know what 12 everybody hopes we write and I know what the draft says will 13 satisfy everybody's aspirations right now, but those drafts 14 do have a habit of evolving a tad.
() 15 DR. SEALE: Well, I think we all have to admit 16 that we're also interested in the issue that was raised 17 earlier about the risk over an additional 20-year period or 18 whatever the time may be, and we really -- if the Commission 19 is talking about looking at that issue anyway, I think it's 20 something we may want to comment in that context.
l 21 DR. POWERS: Well, we may comment on that, but I
)
22 think that's --
23 DR. SEALE: But that's not what we're talking -- l i
24 DR. POWERS: I guess my own view is that the --
l 25 right now is I presume the Commission in passing the license l 1
l i
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209 1 renewal rule did those elementary calculations themselves
() 2 3
.and the inconsistency lies not -- the difficulty and the lack of consistency, first of all, is not unusual in the 4 regulations, and second of all, it lies in another quarter, 5 not in this quarter. I would take that as not these guys' 6 problem, in other words.
.7 DR. UHRIG: Well, it's the same issue that came up 8 back in the glorious days when somebody projected 1,000 9 plants.
10 DR. POWERS: Oh, yeah. Uh-huh, 11 DR. UHRIG: You had to get the core damage 12 frequency if you're going to have 1,000 plants around --
13 have an accident every ten years. That was not acceptable.
14 MR. GRIMES: If we get a -- if we had our
( 15 druthera, I think that the staff would appreciate if you 16 would -- if you want to address the risk aspect, then 17 please, you know, write me a letter, because the renewal 18 program is my responsibility. And to the extent we 19 coordinate closely with the rest of the high priority 20 activities in NRR, we're involved in risk-informed -- risk 21 informing Part 50 to the extent that we maintain 22 compatibility across all of the licensing basis.
23 DR. KRESS: Does 50.54 right now tie your hands?
24 MR. GRIMES: Part 54,'the license renewal rule, 25 does not have a provision in it nor did the Commission OL ANN RILEY & ASSOCIATES, LTD.
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210 1 explicitly consider a risk aspect.
~2 DR. KRESS: .It doesn't prohibit it.
3 MR. GRIMES: It doesn't prohibit it, and we've 4 explained how we've tried to use risk insights to look at an 5 extension of a deterministic licensing basis, but -- in much 6 the same way that we've tried to give BG&E some closure to 7 where we're going with this issue. If I could get a letter 8 you basically says we're satisfied to a certain extent and 9 you want to pursue certain open items, at least we know then 10 what to plan for the future.
31 I want to emphasize that although the schedule 12 shows that the final safety evaluation -- actually, it will 13 be a revised safety evaluation -- will simply fold in 14 changes according to the resolution of the open and 15 confirmatory items and re-issue the SER in a complete form.
16 But to the extent that we can improve on that Noventer 17 schedule, we may be asking you for a decision sooner.
18 So to whatever extent that you can help us find 19 some closure in certain areas and attention or considaration 20 or open items or subject you want to pursue in other areas, 21 that would be very useful for us.
22 DR. POWERS: I think we're going to try to be 23 following our kinds of things that we did for AP600, which 24 essentially said, here are the topics we've looked at at 25 this particular meeting and we've -- here are our points of ANN RILEY & ASSOCIATES, LTD. l L Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l l
211
,n 1 view on those topics, and if history repeats itself, that's 2 kind of the end of it. We're not going to preclude 3 ourselves from re-raising issues, but in general, we don't.
4 They're are an awful lot of topics to cover here.
5 MR. GRIMES: T.lat's fair. That's about the rules 6 we have.
7 DR. POWERS: Yes.
8 DR. FONTANA: If there are not any additional 9 questions, I want to point out this is my last meeting with 10 the ACRS, and the new chairman or this committee will be Dr.
11 Mario Bonaca. We had to hunt around for someone with the 12 same first name so it wouldn't confuse you guys too much, 13 you know, make it eacier for the transition.
14 So again, thank you very much, and good luck to
) 15 you all and to Dr. Bonaca.
16 DR. POWERS: You're not going away. You don't get 17 out of letter writing for the next three days.
18 [ Laughter.]
19 DR. FONTANA: I take my speech back.
20 I'll turn it back to the Chairman.
21 DR. POWERS: I want to thank everyone for an 22 extraordinarily good set of presentations, well presented 23 and well thought out, very useful to the committee.
24 DR. SEALE: We have a comment over there from --
25 MR. DOROSHUK: Mr. Chairman, I would like -- my
[
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW. Suite 1014 2 84 - b3
212 1- name is Bart Doroshuk, BG&E, and I want to -- for our
() .2 clarification, did the committee agree today that the risk 3 question was not a part of the Calvert Cliffs application 4 and it was to be handled in a separate quarter?
5 DR. POWERS: I think that's a fair assumption.
6 We're not in the business of making agreements, but we're in 7 the business of advising the Commission, and we may advise 8 them that they need to think abcut risk.
i 9 MR. DOROSHUK: Bor it would not be part of the --
10 DR. POWERS: I don't think it's peculiar to 11 Calvert Cliffs.
12 DR. KRESS: That's an opinion, of course.
13 DR. POWERS: Yes.
14 DR. KRESS: The committee has not debated the
) 15 subject --
16 DR. POWERS: Yes.
17 DR. KRESS: -- or discussed it.
18 MR. DOROSHUK: Right. I appreciate your patience 19 with my inappropriate use of agreement.
20 [ Laughter.]
21 MR. DOROSHUK: We need to go back and explain to 22 our management the results of the meeting and I guess our 23 understanding is, is that the current thinking was that this 24 is an issue that would be separate from the application 25 review and will remain separate.
ANN RILEY & ASSOCIATES, LTD.
O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 213 1 DR. POWERS: Yes. What the Commission -- we can't
() 2 tell you what the Commission is going to do.
3 MR. DOROSHUK: Yes, sir. I understand. Thank 4 you.
5 DR. POWERS: We'will be writing a letter, maybe 6 two.
7 I think that brings the oral presentations to a 8 close and our need for transcription to a close.
9 Unfortunately, .it does not free the members up.
10 [Whereupon, at 6:12 p.m., the recorded portion of l 11 the meeting concluded.]
12 13
- 14
() 15 16 J
17 10 19 20 21-22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: MEETING: 462ND ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
CASE NUMBER:
PLACE OF PROCEEDING: Rockville, MD were held as herein appears, and that this is the original I transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to l
typewriting by me or under the direction of the court i
_ reporting company, and that the transcript is a true and accurate record of the foregoing proceedings, j fhD Mark Mahoney Official Reporter Ann Riley & Associates, Ltd.
A 4 V
/ o g UNITED STATES
)
8 NUCLEAR REGULATORY COMMISSION
$ ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
, o., wash NOTON, D. C. 20666 O *****
April 27,1999 U
SCHEDULE AND OUTLINE FOR DISCUSSION 462nd ACRS MEETING MAY 5-8,1999 l WEDNESDAY. MAY 5.1999. CONFERENCE ROOM 2B3. TWO WHITE FLINT NORTH.
ROCKVILLE. MARYLAND
{
- 1) 1:00 - 1:15 P.M. Ooenino Remarks by the ACRS Chairman (Open) 1.1) Opening statement (DAP/JTURPS) i 1.2) ltems of current interest (DAP/NFD/RPS) 1.3) Priorities for preparation of ACRS reports (DAP/JTL/RPS)
- 2) 1:15 - 1:45 P.M. Electric Power Research Institute (EPRI) Acolication of Risk-Informed Methods to inservice insoection (Open) (WJS/GA/MTM) 2.1) Remarks by the Cognizant ACRS Member 2.2) Briefing by and discussions with representatives of EPRI and the l NRC staff on the proposed application of risk-informed methods to inservice inspection of piping (ISI).
- 3) 1:45 - 2:45 P.M. Prooosed Final Revision to 10 CFR 50.59 (Chances. Tests and Experiments)(Open) (JJB/MTM)
O 3.1) 3.2)
Remarks by the Cognizant ACRS Member Briefing by and discussions with representatives of the NRC staff regarding the staffs proposed final revision to 10 CFR 50.59.
Representatives of the nuclear industry will provide their views, as appropriate.
2:45 - 3:00 P.M. " BREAK"
- 4) 3:00 - 4:30 P.M. Safety Evaluation for the Cp! vert Cliffs Nuclear Power Plant (CCNPP) l License Renewal Acolication (Open) (MHF/NFD) i 4.1) Remarks by the Cognizant ACRS Member l 4.2) Briefing by and discussions with representatives of the NRC staff I and of the Calvert Cliffs licensee on the CCNPP license renewal application.
5 ) 4:30 - 7:00 P.M. Preparation of ACRS Reports (Open)
Discussion of proposed ACRS reports:
5.1) Proposed ACRS report on the NRC Safety Research Program )
(REU/MME) !
5.2) EPRI Proposed Application of Risk-Informed ISI of Piping '
(WJS/GA/MTM) 5.3) Proposed final revisions to 10 CFR 50.59 (JJB/MTM)
~ ' ' ~ * -
l
2 5.4) Impact of High Bumup or Mixed Oxide Fuel on the Revised
' (~ Source Term (DAP/MME)
Relationship and Balance Between PRA Results and Defense-in-5 5.5)
Depth (TSK/PAB/JNS) l THURSDAY, MAY 6.1999. CONFERENCE ROOM 2B3. TWO WHITE FLINT NORTH. ROCKVILLE.
MARYLAND l
- 6) 8:30- 8:35 A.M. Ooenina Remarks by the ACRS Chairman (Open)(DAP/RPS)
- 7) 8:35- 9:15 A.M. Proposed Resolution of Generic Safety Issue (GSI) 158. " Performance ]
of Safety Related Power-Operated Valves Under Desian Bases i Conditions"(Open) (MVB/AS) 7.1) Remarks by the Cognizant ACRS Member 7.2) Briefing by and discussions with representatives of the NRC staff regarding the proposed resolution of GSI 158.
- 8) 9:15 - 10:00 A.M. Proposed Resolution of Generic Safety issue (GSI) 165. "Sorina-Actuated Safety Relief Valve Reliabilitv" (Open) (MVB/AS) 8.1) Remarks by the Cognizant ACRS Member 8.2) Briefing by and discussions with representatives of the NRC staff regarding the proposed resolution of GSI 165.
10:00 - 10:15 A.M. " BREAK" O 9) 10:15- 11:45 A.M. Fire Protection Functional Insoection Proaram (Open) (DAP/AS) 9.1) Remarks by the Cognizant ACRS Members 9.2) Briefing by and discussions with representatives of the NRC staff regarding the staff work on the fire protection functional inspection program.
Representatives of the nuclear industry will provide their views, as appropriate.
11:45 - 12:45 P.M. " LUNCH"
- 10) 12:45- 2:15 P.M. Westinahouse Owners Group (WOG) Prooosal for ModificMon of Core Damaae Assessment Guidelines (CDAG) and Post-Accident Samolina System (PASS) Reauirements (Open/ Closed) (TSK/PAB) 10.1) Remarks by the Cognizant ACRS Member l 10.2) Briefing by and discussions with representatives of the NRC staff and WOG to discuss the WOG proposal for modification of CDAG and PASS requirements.
[ Note: A portion of this session may be closed to discuss Westinghouse Electric Company proprietary information.]
O ,
i
3
- 11) 2:15- 6:30 P.M. Preparation of ACRS Reoorts (Open) f')
V (2:45 3:00 P.M. BREAK) Discussion of proposed ACRS reports:
11.1) ACRS Report on the NRC Safety Research Program (REU/MME) 11.2) Proposed Final Revision to 10 CFR 50.59 (JJB/MTM) 11.3) Interim Report on CCNPP License Renewal Application (MHF/NFD) 11.4) Proposed Resolutions of GSI 158 and GSI 165 (DWM/AS) 11.5) EPRI Proposed Application of Risk-Informed ISI of Piping (WJS/GA/MTM) 11.6) WOG Proposal for Modification of CDAG and PASS Requirements (TSK/PAB) 11.7) Impact of High Bumup or Mixed Oxide Fuel on the Revised Source Term (DAP/MME) 11.8) Relationship and Balance Between PRA Results and Defense-in-Depth (TSK/PAB/JNS) 11.9) Fire Protection Function Inspection Program (DAP/AS)
FRIDAY. MAY 7.1999. CONFERENCE ROOM 283. TWO WHITE FLINT NORTH. ROCKVILLE, MARYLAND
- 12) 8:30- 8:35 A M. Openina Remarks by the ACRS Chairman (Open) (DAP/RPS)
- 13) 8:35- 9:30 A.M. Tutorial on Instrument Setooints (Open) (DWM/AS)
( ACRS member, Dr. D. Miller, will provide a tutorial for the Committee on
. V] the issues and concems associated with instrument setpoints for safety systems at nuclear power plants.
- 14) 9:30 - 9:45 A.M. Reconciliation of ACRS Comments and Recommendations (Open)
(DAP, et allSD, et al.)
Discussion of the responses from the NRC Executive Director for Operations to comments and recommendations included in recent ACRS reports and letters.
- 15) 9:45 - 10:15 P.M. Report of the Plannino and Procedures Subcommittee (Open/ Closed)
(DAP/JTL)
Report of the Planning and Procedures Subcommittee on matters related to the conduct of ACRS business, and organizational and personnel matters relating to the ACRS. l
[ Note: A portion of this session may be closed to discuss organizational and personnel matters that relate solely to the internal personnel rules and practices of this Advisory Committee, and information the release of which would constitute a clearly unwarranted invasion of personal privacy.)
10:15 - 10:30 A.M. *"B R EAK***
4
- 16) 10:30 - 11:00 A.M. Future ACRS Activities (Open)(DAP/JTL/RPS)
O Discussion of the recommendations of the Planning and Procedures Subcommittee regarding items proposed for consideration by the full Committee during future meetings.
- 17) 11:00 - 7:30 P.M. Preoaration of ACRS Reports (Open)
(12:00-1:00 P.M.-LUNCH) Continue discussion of proposed ACRS reports:
17.1) ACRS Report on the NRC Safety Research Program (REU/MME) 17.2) Proposed Final Revision to 10 CFR 50.59 (JJB/MTM) 17.3) Interim Report on CCNPP License Renewal Application (MHF/NFD) 17.4) Proposed Resolutions of GSI 158 and GSI 165 (DWM/AS) 17.5) EPRI Proposed Application of Risk-Informed ISI(WJS/GA/MTM) 17.6) WOG Proposal for Modification of CDAG and PASS Requirements (TSK/PAB) 17.7) Impact of High Bumup or Mixed Oxide Fuel on the Revised Source Term (DAP/MME) 17.8) Relationship and Balance Between PRA Results and Defense-in-Depth (TSK/PAB/JNS) 17.9) Fire Protection Function Inspection Program (DAP/AS)
SATURDAY. MAY 8.1999. CONFERENCE ROOM 2B3. TWO WHITE FLINT NORTH. ROCKVILLE, Q MARYLAND -
- 18) 8:30 - 2:00 P.M. Preoaration of ACRS Reports (Open) {
(12:001:00 P.M. LUNCH) Continue discussion of proposed ACRS reports listed under item 17.
- 19) 2:00 - 2:30 P.M. Miscellaneous (Open) (DAP/JTL/RPS)
Discussion of matters related to the conduct of Committee activities and matters and specific issues that were not completed during previous meetings, as time and availability of information permit.
NOTE:
- Presentation time should not exceed 50 percent of the total time allocated for a specific item. The remaining 50 percent of the time is reserved for discussion.
- Number of copies of the presentation materials to be provided to the ACRS - 35.
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l i O i UNITED STATES NUCLEAR REGULATORY COMMISSION f EPRI METHODOLOGY FOR RISK-INFORMED INSERVICE INSPECTION PROGRAMS FOR PIPING PRESENTED TO: O THE ACRS JOINT SUBCOMMITTEES ON RELIABILITY AND PRA AND MATERIALS AND METALLURGY MAY 5,1999 Syed Ali, DE, NRR (415-2776) Steve Dinsmore, DSSA, NRR (415-8482) O i
l O i i I j UNITED STATES NUCLEAR REGULATORY COMMISSION _ STATUS OF EPRI TOPICAL REPORT EPRI Submitted Draft TR-106706 6/30/96 (C) Staff issued RAls 6/12/97 (C) l EPRI Responses to RAls 11/13/98 (C) Meeting to Discuss Responses 3/2/99 (C) EPRI Submitted Revised TR-112657 4/15/99 (C) A RC Subcommittees Meeting 5/5/99 O Follow-up Meeting with EPRI 7/12/99 i ACRS/CRGR Meetings 9/99 ; lssue Safety Evaluation Report 10/31/99 l 1 1 i O 2 ; j
- 1 i
l O ) I i j UNITED STATES NUCLEAR REGULATORY COMMISSION Schedule of EPRI BasedPilot Plant Applications Vermont Yankee 11/9/98 (C) l ANO Unit 2 12/29/98(C) ANO Unit 1 07/31/99 ) O I O 3
4 O f ..s,,
) UNITED STATES NUCLEAR REGULATORY COMMISSION Maior Changes in EPRI Topical Report Subsequent to Approval of Pilot Plants 1/2 The application of RI-ISI to Augmented Inspection Programs, e.g., IGSCC and Erosion / Corrosion has been addressed Proposed Submittal Template added O RI-ISI Methodology can be applied on a system-by-system basis.
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( j UNITED STATES NUCLEAR REGULATORY COMMISSION j Maior Changes in EPRI Topical Report Subsequent to Approval of Pilot Plants 2/2 Slight changes in matrix safety-significant categories Change in A Risk Calculations / Criteria l Q . No A risk calculations for Class 1 only (N-560) No A risk contribution from Low safety-significant segments Added screening criteria on A CDF/LERF 1E-07 CDF,1E-08 LERF 1E-08 CDF,1E-09 LERF system only scope Added Markov option to original qualitative and bounding options O s
f 1 O EPRI Risk Informed -ISI Program to ACRS May 5,1999 Vesna Dimitrijevic - DE&S Hamilton Fish - NYPA Karl Fleming - ERIN Jeff Mitman - EPRI Pat O'Regan - EPRI Pete Riccardella - SIA Glen Smith - NYPA ACRS 599W 6PrEl O Objectives & Agenda
. Facilitate ACRS review and concurrence of EPRI RI-ISI methodology to support SER in September 1999
. Agenda Topical report status Pilot plant status Overview of methodology Summary & conclusions EPral O
1
O Topical Status
. Submitted to NRC -June 1996
. RAI responses - November 19S8
. Revised topical sent to NRC April 15,1999 incorporating:
. Enhanced procedure and basis description Lessons learned from pilots Resolution of questions & comments from NRC RAls Related EPRI research
. Draft SER expected June 1999
. SER expected September 1999 EPel O
Code Cases
. N 560 Approved in 1996 Applies to BJ welds, excluding socket weld Inspection 10% of BJ welds selected by risk Revision started with approval expected in 1999
. N 578 l
. Approved in 1997 l
. Applies to class 1,2, & 3 piping (and may be used for non-code l elements) l Inspect 25% of high risk,10% of medium risk,0% of low risk welds Revision started with approval expected in 1999
. Risk assessment process is same for both code cases
. Element selection process is slightly different st* * . Comparable risk results spe:
O 2
1 O Pilot Plants
. Vermont Yankee (N-560) - SER Received
. ANO2 (N-578) - SER Received
. ANO1 (N-560) - Submitted
. Fitzpatrick (N-578)-Submittalin preparation
. Braidwood (N-560) - 80% complete
. STP (N-560)-75% complete
. Riverbend (N-560) -later !n 1999
. Waterford (N-560) -later in 1999 Erafal O
Methodology Overview Determine Scope
./ .
Perform Segment Perform Segment Damage Consequence Analysis Mechanism Analysis I
./
Perform Service Review l l Determine Segm nt Risk Category Adjust Select Elements for Inspection & Element - Element inspection Methods Performance
, Selection .
& Monitoring Perform Risk Impact Assessment l
- Finalize Program Er=ral
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O h IUSK MATRIX CONCEP RISK = (CCDP or CLERP given Pipe Rupture) vs (Potential for Pipe Rupture) Core Damaae or LER Potential Potential for PIDe Rupture
. PSA & Deterministic e Degradation Mechanisms e impact Groups e Service Experience a initiating Event e Rupture Potential
. Degraded SystemfTrain Ranking
. Degraded Containment . High
. Combination . Medium
. Consequence Ranking . Low
. High a Medium
. Low si.e io
. None
( h RISK EVALUATION Consequence Assessment CONSEQUENCE CATEGORY CCDP and CLERP Potential Failure Potential nowE tow Medium HiGH . Assessment ] (Oegradation > '{.y ,;%r,p .? .. , Afechanism) Ei HIGH
$jT ' cal 4:JCat. 5);
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o LJ PIPE SERVICE < 7 EXPERIENCE e Analysis of more than 2000 years experience by EPRI, SKI and others yloids database of 1145 pipe failures e 1076 Pipe leaks identified Most less than 5 gpm Most due to corrosion mechanisms l e 69 " Ruptures" loentified ( >50 gpm ) Failure mechanisms well understood and conditions necessary to produce failures generally known Some mechanisms not amenable to inspection One RCS event Several events in steam and feedwater systems e EPRI maintains program to periodically update the database sluse 12 ggg O ' t DM Attributes & Susceptible Regions - 3 Thermal Fatigue Degradauon Crtterla susceptible Mechanlem Reg 6ons TF TASCS
- NPS > 1 inch, and Nozzles,
- pipe segment has a slops < 45' from horizontal (includes elbow or tee into branch pipe e a vertical pipe), and connechons, e potential exists for low flow in a pipe section connected to a component safe ends, allowin0 mixing of hot and cold fluids, or welds, heat potential exists for leakage flow past a valve (i e., in-leakage, out4eakage, affected cross-leakage) allowin0 mixing of hot and cold fluids, or zones potential exists for convection hesun0 in dead-ended pipe sechons (HAZs), base connected to a source of hot fluid, or rnetal, and potential exists for two phase (steam / water) flow, or regions of potential exists for turbulent penetration in branch pipe connected to stress header piping containing hot fluid with turbulent flow, and concentration
- calculated or measured AT > 50*F, and
- Richardson number > 4.0
- operating temperature > 270'F for stainless steel, TT or operating temperature > 220*F for carbon steel, and
- potenbal for relauvely rapid temperature changes including:
cold fluid injection into hot pipe segment, or hot fluid injection into cold pipe segment, and
- AT > 200*F for stainless steel, or AT > 150*F for carbon steel, or shde ie AT > AT allowable (appiscable to both stainless and carbon)
O 5
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I O Degradation Mechanism 7 Category summum Pipe Expected Degradation Mechanisms To murammmme Rupture Leak Which The Segment is Potential Conditions susceptible HIGH Large Flow Accelerated Corrosion (FAC) Thermal Fatigue Stress Corrosion Cracking (IGSCC, l TGSCC, PWSCC, ECSCC) l MEDIUM Small Localized Corrosion (MIC, Crevice Corrosion and Pitting) Erosion-Cavitation LOW None No Degradation Mechanisms Present sa n ENI O Consequence Considerations
?
e initiate event l e Mitigating ability l
. Loss of system (s) or train (s) l
. Degradation of system (s) or train (s) e Containment effects
. Loss of containment integrity
. Degradation of containment integrity e Combination sm i. gg ,
O 6
l 'O l Consequence Ranking 7 Criteria
. HIGH CCDP >104or CLERP>104 Severe initiating Events Severe Loss of Mitigation High Risk of Containment Bypass
. MEDIUM 104< CCDP < 10d or 10 7 < CLERP < 104 Moderate initiators l Moderate Loss of Mitigation Moderate Risk of Containment Bypass
. LOW CCDP < 104 and CLERP < 10-7 Mild initiators Minimal Loss of Mitigation Full Containment Sie 19 gpg O
Remaining Tasks
. Determine segment risk category
. Selection of inspection locations
. Selection of appropriate inspection techniques
. Risk impact assessment
. Document & finalize project
. Submittal
. Performance monitoring 5'
- 22 ErsfEl O
7
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O RiskImpact Assessment
. EPRI Ri-ISI process was designed to maintain or decrease risk level e Risk impacts include:
allocation of inspections at high risk locations Inspection for cause impacts elimination of inspections at low risk locations
. Risk impacts assessed using: I qualitative analysis in most cases bounding estimates in some cases realistic estimates where appropriate age, O
EPRI RI-ISI Reports g'Ewluation of Pipe Failure Potential via 3 mas Degradation Mechanism Assessment TR-110157 sen Application of EPRI RI-ISIGuidelines to CE Plants TR-107531 Application of EPRI RI-fSI Ewfuation Procedure to B, _WR_ TR-107530 Piping Failures in U.S. Nuclear Power Plants: 1961-1997 TR-110102 Piping System Reliability Models and Database for used in Risk Informed inservice inspection Applications TR-110161 Use of Risk Informed inspection Methodology for BWR Class 1 Piping TR-110701 Piping System Failure Rates and Rupture Frequencies for Use in Risk informed in-Service inspection Applications _D_ RAFT _TR-111880_ Revised EPRI RI-ISI Methodology Procedure TR-11,2657 Ef=lE!I O 8
- j
l 4 t 'O Pilot Results Summary ,
-{ RISK RANKNG l Hign Med. l Low lotal V6rm6FilYanTee jDid5scX 37: 54 25 126 Gl.1 - 430 Welds :HHsi 33~ 10 0 43 ANO-1 OldSsEM so 53 17 100 Cl.T 394W6fds HHs! zu. 12 0 40 i
Eraidwood Old sec.M 35 93, 72 203 Cl.1 723 Wilds KhlSI 43 31 0 74 ANO7 0165e00 36 120j z30 436 Full Scope - 7906WsidsTRIlSi 7s i7oj 7 255 i > I 1 EEf=1!M O Summary & Conclusions
. Revised topical report submitted
. Addresses questions & comments raised by NRC
. It is in compliance with RG 1.174 & 1.178
. Methodology has been applied extensively
. GE, W, B&W & CE a Multiple AEs l
. Full / partial scopes
. Significant REM reduction
. Pilots & research supports conclusion of negligible '
risk impact SMs 30 pg O . 9
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Embedded Real-Time Safety-Critical Digital Systems Reliability and Safety Modeling Presented to: j Nuclear Regulatory Commission ! ACRS Subcommittee on NRC Safety Research Program Presented by: Barry W. Johnson Professor and Co-Director Center for Safety-Critical Systems University of Virginia May 4,1999
,. n ,, w Univeralty of Virginia Cone s for Safetycritical Sy. terns
. Outline
- Introduction s University of Virginia Center for Safety-Critical Systems e Embedded Real-Time Safety-Critical Digital Systems
- Research Objectives
- Digital System Reliability and Safety Assessment a Reliability and Safety Assessment Methodology a Reliabihty and Safety Modeling and Simulation Techniques a Application of the Assessment Methodology
- Conclusions
- Discussion
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'Research in safety-cntical digital systems has been on-going for the past 15 yoars within the University of V,rginia Center for Semicustom integrated Sys'. ems (CSIS) e CSIS founded in 1984 s CSIS esta'JIished as a statt. of V;rginia Center of Excellence in 1986 CC IS fneulty and staff have designed, implemented, and tested more than 20 experimental prototypes of sefcty-cr,tical digital systems Center for Safety-Critical Systems (CSCS) was established in July 1998
- 1998-1999 CSIS and CSCS research sponsors i
s Nuclear Regulatory Commission (NRC) a Federal Railroad Administration (FRA) ' e National Science Foundation (NSF) s NASA Langley Research Center m New York City Transit Authority a Air Force Research Laboratory m Navy Advanced Amphibious Assault Vehicle Technology Center a Virginia's Center for innovative Technology (CIT) e Defense Advanced Research Projects Agency (DARPA) e Four industrial organizations
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O University of V'. gin 6e g, Center for si,ety Catfcal Systems Embedded System StructLic-~ Outputs from Plant / Inputs to Plant / Inputs from flumans l Physical Plant l Outputs to llumans l Iluman l 8 u___________________________.. _____, 4 l sensors ^*'"*'" Embedded Controller l 3k h e I Analog Analog i l liardware ,,,,,,,....................... liardware l l t + _l
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Software Digital l l liardware f7 # llardware Ilardware l 1nterfaces .............................eh Processor 8 l !P_"_"T_'9 _____________________________l
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s l O V l University of Virginia Center for Safety 4rstical Systems Processor Model 13ata Path a sd Cantrol Path Output System m Functions & System F inputs F Outputs j m Next State ' 7 Functions l F Control
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Current State ( % ( g l Information N / N / Information l Registers l f l Cache l ]k j
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'b University of Virginia Center for Safety 4rttical Systems Hardware and Software are not Independent Entities Software rauiti : What happns when faults occur in both the hardware and Hardware rauitj softw are?
Software must execute on a hardware platform, and it is the operation of the integrated hardware / software unit that is ofinterest to us. A fault in software (Fault i)in combination with a fault in hardware (Fault j) can result in unsafe conditions and/or unreliable operation.
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i O R =mm- s.... Research Objectives
' Develop a reliability and safety assessment methodology for digital systems a Consider the integrated hardware / software system a Allow for the inclusion of commercial off the shelf (COTS) hardware and software components
- Develop modeling and simulation techniques that support the assessment methodology a Support the estimation of quantitative metrics a Support the evaluation of qualitative attributes
' Develop a set of tools that supports the assessment methodology m Use COTS software tools where feasible a Create new tools where needed
' Demonstrate the resulting approach and tools on real examples a Nuclear reactor protection systems (Virginia Power) m Railway systems (CSX and Federal Railroad Administration) m Aircraft flight control (NASA and Boeing) sm ,
O h MM.i.%., s,... Digital Systems Reliability and Safety Assessment What can go wrong? What is the likelihood? Embedded Embedded Fault 1 p(p ) Fault 2 Digital Digital p(7 )
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Systems N Fault m-1 N m Fault n+1 P(f.i) Fault m P(f}i) p(g n Fault m+1 .
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Fault z P(f[+i) P(f,) Fault n P(fn) , l
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What are the consequences?
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~ Reliability and Safety Assessment Process a[dk"e'j'n n l Reliability, Safety, etc.
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^,',*d str , d l rds Design Processes, etc.
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Ass s s o ions elected faults AM uusak, etc.
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h p'j*j,*[de s"'l Stuck-st-1, stuck-st-0 faults, etc. 4 h De op
,,m and, ,Assns l Ilierarchical modeling methudology 4
h 's"y',',*,' dets l Solve models, simulate models, etc.
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I, f,',"*7,',*de Calculate reliability, safety, etc. 4 V University of Virginia Center for Safety 4ntical Systems System Modeling Methodology Reliability, Safety, , System I MTBit E, etc. Aletrics l JL Markov, Fault , nalytical m Estimated Parameters Tree, Petri net, etc. , Models 1r Coverage Failure Critical Rates Latencies, etc. Parameters Parameter Estimation f i 1F t t Analytical Espert Worst Case Physical Simulation Niodels Opinion Estimates Prototy pes Niodels i I
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Statistical Models 1r 1r 1r
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O Un6versity of Virginia Center for Safety 4rttical Systeme l Concept of Fault Coverage i 1 l l
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l f 3 r i' C, C, C, C, oeSc" tion* tic'a" tion II a"tYon* neeovery 1-Co 1-C t, 1-C i 1-Ca , 1r 1r 1r 9P Coserage Failure Fault coverage is the probability that a system correctly handles a fault given that a fault has occurred ww si.* u 9 University of Virg6nia Center for Safety 4ritical Systems Coverage Example **
- in a Markov Model e
Operations i
- State Safe States --+..'
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Failed / Failed Safe - 1:nsafe State .' State Reliability = R(t) = e.u Safety = S(t) = C + (1 - C)e-h Mean Time To Unsafe Failure = MTTUF = [A(1 - C)]-1
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O) u University of Virginia Center for Safety 4rttical Systems Coverage Parameter Estimation Fault Set l l 1f l Sampling Strategy t t hariance Reductio Random l l 7 Sampled Fault Set if l tiardware/ Software l l Fault Simulation I h R y Fault Latency l Data yk [ ; Error Latency W Coverage nw sie u O University of Virginia Center for Safety 4retical Systems Hierarchical Modeling Methodology Faults that defeat Layers of allia> crs yiel System Failure .y, ,7 Desiggand Protection system failure f m ' gg Modeling
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Architectural Models Architecture Lesel Olarkov, Petri, FT) f
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Models tt tii '\ Faults defeat certain Possible Physical Faults layers of protection u, ca a O
1 Un:versity of Virginia Center for Safety 4rttical Systems l Characterization of Faulty Behavior Models are developed which describe the faulty behavior of hardware / software modules at the appropriate levels Possibly COTS Module Module Interface / iM liardware and inputs > Software 3 Outpats Module Module Interface 4 gw skn O g .n,_., _ n. Center for Safety 4rttical Systems Fault and Error Modeling Three Universe Mest: Operational faults -* -* Error Failure Design faults Physical Informational External Universe Universe Universe Fault - a defect or imperfection in either hardware or software Error - a deviation from accuracy or correctness in information Failure - non-performance of something due, required, or expected
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- Application of the Safety Assessment l Process
' Applied this process to a real-time, safety-critical digital system j e System in the field for more than a decade at 150 locations a System contains more than 30,000 lines of assembly code a 250 millisecond response time requirement I a System was designed as an event-driven system
' Simplex system with extensive software-based diagnostics a 80% of software written for diagnostic purposes
'Fa'. safe application (shut down is considered safe)
"Results of assessment process used as proof of safety for a public utility commission (California Public Utility Commission)
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e University of Virginia d Center for Safety 4rttical Systems Structure of the Processor Module Conditional Safety-Critical Output Power Power Circuit J
' Safety <ritical Watchdog Signal Processor p Safety-Critical Safety-Critical inputs Functional Outputs M nitor D ce
- Diagnostic jg Software
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University of Virginia Center for Safety Crlucal Systems System Safety Model System Operational O Q k,4 k,s 1-P,e P.m a St " # m Tr s nt P,e y Malicious p F$ub P,, 1 1 P,, y y1 -P,e U 9 2 , ei
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University of Virginia Center for Safety.Crtucal Systems Sensitivity to Permanent Fault Coverage 5 l t l i 4 - 1 I 3 . l l 2 . 1 1 0.0t. _ _ i 0.9 0.999 0.99999 0.9999999 j Pefmanent FauR Cowrage s+w m.* n A University of Virginia Center for Safety Crtucal Systems Sensitivit,/ to Transient Fault Coverage 8 . O c :) a 6 a
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0.0 L l 0.9 0.999 0.99999 0.9999999 i Transent Faut Coverage l
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O University of Virginia Center for Safety <,ritical Systems Two Levels of Simulation Models Used in the Safety Assessment Process Fault Dictionary Characterization 1/0 Circuits- pProc, Memory liardw are Analog & Digital Buses, etc. F:utuError D nian ' All Credible a Internal Faults ; p,$'babi'."es, Component Faults (s-a- 1, s-a-0) Esecution Times, Simulated Transient Execution Tables
* & Permanent
- ActualSoftware Design (Code)
System Architecture Tools used: Tools used:
- Analogy Saber - VIIDL
- Mentor Graphics -ADEPT
- Vantage uw su a O
Univers#ty of Virginia Center for Safety Critical Systems Hardware / Software Fault Space Considered in Safety Assessment System Faults
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Operational Design Random j
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Non-mal. .icious Algorithmically Randomly Selected Selected
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f e e university of Virg6nia Center for Safety 4rttical Systems Fault List Selection Problem i l Set of all Faults No Response Faults Set of all Faults ,
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4 Malicious Faults Set of all Faults that Produce Failures Set of Uncovered l 4 Faults that roduce Failures Unsafe Faults l ' l l
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U University of Virginia Center for Safety Crtucal Systems Malicious Fault List Generation Process Perform Generate Specify
-> Data Flow -> Gennate l Select Fault Fault-free Unsafe -t '""
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, Simulation Graph Outputs Fault Tree l t 3 t 3 t 1 t 1 L 1 T T T T T Samulase the Deveisp a Trace of Develop a use of Ussafe Rever,e Trece Through select the Det Hardware.httw are Competanens at Outputs from the Data Flow to Generate of Malinous Issegrated System lastructies Esecunea Apphcades Kee* ledge Faults that Create Faults for lejecties Level (with simieg) Lasafe Outputs in Hardware,hlteste (Mahciens Faults) Simulation Smith, D., Johnson, B., and Profeta,III,J.," System Dependability Evaluation Using a Fault List Generation Algorithm",lEEE Transactions on Conputers, Vol. 45, No. 8, Aug.1996, pp. 974-979.
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i O University of Virginia Center for Safsty Crttical Systems Illustration of Randomly Sampled Fault Space System Fault Space n k
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, University of Virginia Center for Safety 4rttical Systems Fault Expansion Concept System Fault Space n k
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, Smith, D., Johnson, B., Andrianos, N, and Profeta. !!!.J "A Vanance Redochen Techaque t mas Fault Ispaasson for Fault Coverage Esnmaties"./ ELE Treasections en Aslashihry, Val 44, No. 3, Sept.1997, pp. 366-374.
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F l l l l O lG l um. c.,,., , u., .m,. u - s,. Safety Assessment Results
' Discovered 3 latent design faults that were safety significant
" Demonstrated safety-critical operation of the system
'Results used as proof of safety for a public utility commission
' Identified design techniques to ensure meeting safety regtAcments and to ease the process of safety assessment f l
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U um..,. ., m, c . , .u ,sim. o- s,. Conclusions -- Lessons Learned from Research and Application l
- Evaluate the integrated hardware / software system
' Develop a higher level of modeling abstraction
' Create a new theory for integrated hardware and software modeling
- Develop a new theory to support integrated modeling of design and operational faults
' Develop techniques to prove the correctness of algorithms
' Provide integrated modeling tools and environments
' Develop techniques to establish confidence levels for safety estmates
- Exploit knowledge of the system in the assessment process
' Develop design principles which make assessment easier
' Create techniques for reliability modeling of hardware / software systems and integration of results into the PRA l
' Develop techniques to handle hardware / software common mode faults I ' Provide more experimental research to provide proof of the concept I \ .)}}