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Transcript of 990527 Public Workshop in Rockville,Md Re Suppl to Proposed Amend to 10CFR50.55A on Isi/Ist Program Update Requirement.Work Order ASB-300-800.Pp 1-172
	ML20207F007
Person / Time
Issue date:	05/27/1999
From:	; NRC
To:	;
References
	RULE-PR-50-MISC ASB-300-800, NUDOCS 9906080004
	Download: ML20207F007 (173)
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i 1 . OFFICIAL' TRANSCRIPT OF PROCEEDINGS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

Title:

PUBLIC WORKSIIOP ON SUPPLEMENT TO PROPOSED AMENDMENT TO 10 CFR 50.55A ON ISI/IST PROGRAM UPDATE REQUIREMENT Case No.: Work Order No.:- ASB-300-800 e LOCATION: Rockvlile, MD DATE: ^ Thursday, May 27,1999 PAGES: 1 - 172 p;0005 3 ) '[-l ) ANN RILEY & ASSOCIATES, LTD. 1025 Connecticut Avenue,NW, Suite 1014 Washington, D.C. 20036 .?> (202) 842-0034 l 60 004 990527 50 NISC PDR

1 1 , UNITED STATES OF AMERICA /' 2 NUCLEAR REGULATORY COMMISSION UN 3 4 5 PUBLIC WORKSHOP ON SUPPLEMENT TO 6 PROPOSED AMENDMENT TO 10 CFR 50.55A ON 7 ISI/IST PROGRAM UPDATE REQUIREMENT 8 i 9 USNRC i 10 Auditorium, TWFN Building ) 11 11545 Rockville Pike 12 Rockville, MD 3 13 14 Thursday, May 27,.1999 l 16 The above-entitled workshop commenced, pursuant to 17 notice, at 9:04 a.m. 1 18 l i 19 l 20 21 L 22 1 I 23 24 25 t 1-I (s ANN RILEY & ASSOCIATES, LTD. I t, ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 y (202) 842-0034

r~ 2 1 PROCEEDINGS .( 2 [9:04 a.m.) l l 3 MR. WESSMAN: Good morning. My name is Dick 4 Wessman. I'm the deputy director of the division of 5' engineering in the Office of Nuclear Reactor Regulation, and 6 I want to welcome you all to this public workshop to discuss 7 the proposal to eliminate code update requirements for ISI 8 and IST. 9 Before I make a couple of comments, I would point 10 out as you all came in and signed up, there was quite a pile 11 of paper and handouts available for you on the table. We j i 12 discovered one of the handouts, namely a letter from the l i 13 ACRS, deals with steam generator issues. That's not the l 14 subject of this meeting. If you want to talk about steam () 15 generators, you have to come back another time. 16 That letter actually -- the ACRS letter that we 17 want you to have is a document that actually deals with this 18 120-month update proposed rule activity. We're getting 19 copies made, and we'll get them circulated to you in the 20 next few minutes. 21 We're here today to discuss this proposed 22 rulemaking that deals with the elimination of the j 23 requirement for licensees to update ISI and IST programs 24 every 10 years to the latest edition of the ASME code. This 25 proposal also establishes the 1989 edition of the ASME code ANN RILEY & ASSOCIATES, LTD. Court Reporters ( ~ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 j / l )

l: 1 3 1 as a baseline. I'd like to introduce a few people to you 2 here before I make a couple of remarks, and many of them, I .g-ss E ' 3 think, are people that you know. Sort of in a center chair 1 4-in front of me here is Tom Scarborough. He is an engineer l 5 -- a senior engineer with the mechanical branch in NRR, and 6 he will actually sort of chair our meeting today. 7 Also, other staff members that are near the front t 8 of the room here.is Gene Imbro, his branch chief and Dave 9 Terao, his.section chief. I see Joe Colochino; I see Bob 10 Hermann; I see Gil Millman and other individuals whom many I l 11 of you may know, and many of these individuals have had a 12 very active participation in the code and standards 13 activities. l 14 Elizabeth, if you'd bring those copies down and tT 15 just put a few on each side of the front row, they'll i V 16 gradually get passed around. This is the ACRS letter that I l 17 . referred to. I would also recognize a couple of other 18 . individuals, because they will be involved in some of the -- 19 what I'll call invited prepared presentations that will be l-20-in the early part of our agenda. At the far end of the room 21 is Jim Ferguson. He is the new -- John,-I apologize, John [ 122- -- incoming chairman of the board of the Nuclear Codes and 23 ' Standards and vice president in ASME. With him is Jerry i l 24 Eisenberg, also of ASME. Over here on my right, t 25 representing NEI, is Alex Marion, and I think he has several fx ANN RILEY & ASSOCIATES, LTD. ( ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 l [ L

4 1 other NEI individuals with him. I see Kurc Cozens right f-2 beside him. N/ 3 A little bit of background to refresh our memory .4 and get ourselves started, if I may. You all' recall that in 5 December of 1997 -.it seems like a long time ago -- after a 6 number of years of staff work, we published a proposed 7 supplement to 10 CFR 50.55 (a). It was published for comment 8 and was put out for a 90-day public comment. This was a 9 major update to the 50.55(a) provisions of the rule. It 10 dealt with a number of rather challenging issues, ranging 11 from things like a mandatory imposition of the appendix 8 12 ISI requirements; it dealt with, for the first time, an 13 endorsement of the OEM code. It dealt with a' contentious 14 issue, somewhat known as engineering judgment. It endorsed r~N 15 the 1995 code through the 1996 addenda and dealt with a () ~ 16 number of other issues. 17 We had extensive public comments as a result of 18 that Federal Register notice and proposed rulemaking. Many 19 of them have been addressed, and I think some of the 20 potentially contentious issues have been satisfactorily 21 dealt with. 22 Late in 1998, the staff recognized that the 23 approach we were headed on with a package that was nearly 24 complete needed a pause and a little bit of reconsideration, f 25 and this reconsideration was with a focus on the potential L I' I ANN RILEY & ASSOCIATES, LTD. fI \\ Court Reporters f' 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I l 5 1 for unnecessary burden on the industry or licensees and on i (f"1 2 the staff of the existing provisions of the rule, and it %-) t 3 revolved around the concept of requiring, every 10 years, 4 the 120 month update to the latest endorsed versions of the I 5 code. ) 6 As a consequence, we prepared a policy paper to '7 our commissioners, copies of which you have. It's this 8 99-017, dated January 13, 1999,-and provided a proposed 9 policy issue and an approach to the commissioners and 10 ' identified the potential impact on the schedule. After 11 receiving direction from the commission to go forward and 12 publish a proposed supplement and seek public comments, we .13 did publish this proposed rule in April of this year and 14 announced the plans for today's workshop and pointed out our ' n () 15 desire for written public comments by June 28 of the year. 16 The next steps, of course, will involve hearing 17 and working with you all today regarding comments on the 18 proposed rulemaking; then, working on -- receiving and 19 working on the public comments that we would receive in 20 writing. We then have to develop a final rulemaking package 21 that would incorporate the decisions that come from our work 22 and discussion today as well as the decisions that come from 23 the work on that 1997 package and take that complete package 24 forward to the commission for their final approval, 25 following our normal regulatory processes of interaction l-ts ANN RILEY & ASSOCIATES, LTD. (,,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 i ( i 1

p l; 6 1 with the CRGR, the Committee for. Review of Generic l r) 2 Requirements and the ACRS with a general time line that i V 3 would lead us to hopefully publishing a final rule about the 4 end of the year. 5 Let me very briefly overview the agenda.

Marge, 6

if you.would put it up; again, I-think you have copies of 7. that. Our intent-is'to do some initial presentation by the 8 staff. Actually, it will be Tom and some presentations by 9 several of our invited guests, who are principal 10 stakeholders in this issue, and then, if there are others 11 who have identified themselves as part of the registration } 12 process that want to make some remarks at the front end of i 13 our. discussions, we want to allow that opportunity. 14 We then expect to kind of take a break and () 15 ' hopefully work ourselves more in what I'll call a roundtable 16 format. It was hard to decide whether to set up the room in 17 .a big U-shape-for starters or in the format that you see 18 here,'because you don't know whether you're going to have 25 19 people or 200 people. I'm glad we have a good crows,'and we 20 have a good crowd of interested people. i 21 We are here to hear your views today on the April 22 27 proposal on that Federal Register notice. We're not here 23 to discuss the proposed rulemaking package that was 24 . published in December of 1997. That process has gone its 25 way, and the public comments have been received, and the es ANN RILEY & ASSOCIATES, LTD. ,i ( Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

{" l 7 1 staff has worked the disposition on them, but we want to 2' ' V( S maintain our focus on the activity that we're working on 3 today, namely, this discussion of the proposal to eliminate 4 the 120-month update. 5 Again, I want to remind you: we want the written 6 comments by that June 28 date. We need a clear statement of { 7 your concerns and issues, and we do not want to just rely on l 1 8 the transcript of this meeting. We will prepare a summary 9 of the meeting, and we'll make it available to all of the 1 10 participants. If you've given your name and address as part 11 of registering this morning, we'll be sure that you get a 12 copy. 13 A couple observations on logistics, if I may. We 14 are being transcribed. I think you see the reporter in the I (s 15 corner over there. So I ask that when you come to make 3 \\_J 16 remarks or raise your hand to speak, it's a nuisance, but 17 please speak to the microphone and identify yourself and { l 18 your organization. It makes life easier for all of us. l 19 There are a lot of copies of the printed material 20 that's been in the back, and I think you've captured copies 21 of those as you came in. A reminder: please observe the o 22 NRC security requirements. If you need to go elsewhere into 23 the building or whatever, get one of the staff members to 24 escort you. And finally, of course, we will take breaks as 25 identified in the agenda. You can see it as far as lunch, ANN RILEY & ASSOCIATES, LTD. [ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 l

m ~ 1 8 .1 and you can flash up the second page, if you would, Marge. ' r's 2 There are restrooms in the lobby, and many of you have been b 3 here before and know about the' delicious hamburgers across 4 the street or the opportunity to walk down to White Flint. 5 Again, thanks for coming. It's an importanc 6 issue, and there are some strong views on it, both, you 7 know, among members of the staff, members of the public or B various stakeholders and even on the ACRS or the 9 commissioners themselves. There are pros and cons out 10 there, and we need to hear them, and that's what we want to 11 do. 12 At this point, let me introduce Tom Scarborough 13 from the mechanical branch, and he will summarize a little 14 bit of the history on current regulations and the details of (\\ 15 the rulemaking.

m,)

16 MR. SCARBOROUGH: Thanks, Dick. Good morning. 17 I would like to spend the next few minutes going 18 over briefly some of the background so we all are talking 19 about the same issue and starting off on the same page. 20 What I'd hoped to do is this is sort of a table of 21 contents, what I'd like to go over this morning briefly: 22 the introduction, sort of what the current 50.55 (a) 23 requirements say; what was proposed in December 1997; what 24 came out as to the proposed rule supplement; examples of the 25 implementation of the supplement; how it would sort of work u ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l

0 9 1 if it was implemented; discussion topics that were outlined r~N ' '2 in the Federal Register notice, as we're going to go through \\' -) 3 in the roundtable discussion and conclusion. 4 First, 50.55(a) references the ASME boiler and 5 pressure vessel code with certain conditions and limitations 6 .for construction, inspection and testing of nuclear power 7 plant components. In the past, the NRC has revised 50.55(a) 8 periodically to incorporate by reference the latest addition ) 9 of the ASME code, and if you look back at the statement 10 considerations back in 1971, they 'ndicated -- the 11' commission indicated the iraprovement expected in the code 12 over time, so that was part of the basis of that. 1 13 50.55(a) requires in'-service inspection, j 14 in-service testing programs to be updated every 120 tuonths, (J T 15 every 10 years. Then, the latest proposed amendment to that L 16 was in December 1997, which referenced more recent additions j 17 of the ASME boiler and pressure vessel and operation and 18 maintenanea codes. Basically, it was a 1995 edition and 19 also retained the ISI/IST update requirement. 20 But based on public comments and the maturity of 21 the code, and that is that the safety benefit of each 22 revision does not seem as significant as it was in the past, 23 it is being considered to eliminate that requirement to 24 update the ISI and IST programs every 10 years. So with 25 that, we issued a supplement to the proposed rule in April ANN RILEY & ASSOCIATES, LTD. (m Court Reporters ) 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I, i 1 10 1 1999 requesting public comment on the elimination of that /'. 2 update: requirement, and as Dick mentioned, the public ~' 3' comment period ends on June 28, and we're currently i_ l l 4 reviewing all the other public comments we received on the 5 December 1997 proposed rule, and we may revise that proposed 6 rule based on those comments, and as Dick mentioned, we're i 7 not going to talk about that today. l 8 okay; this is currently what's in 50.55 (a) : class 9 one, two and three components are to be constructed 10 according to the 1989 edition of the boiler and pressure 11 vessel code, section three, with certain limitations and 12 modifications. Now, section three will not be affected by 13 the proposal to eliminate the 10-year update for ISI and IST 14 programs. The class one, two and three components are to be 15 inspected according to the 1989 boiler and pressure vessel 16 code, section 11, to the extent practical within the l 17 limitations of design, geometry and materials construction. 18 I.didn't repeat that on each item, but that goes along with 19 each of these bullets. 20 Class MC, which is metal containments, and CC, 21 concrete containments, are to be inspected in accordance 22 with the 1992 edition, 1992 addenda, of the ASME boiler and i 23 pressure vessel code, section 11, and then, class one, two L 24 and three pumps and valves are to be tested according to the 25 1989' edition of the boiler and pressure vessel code, section fS ANN RILEY & ASSOCIATES, LTD. I\\j Court Reporters 1025 C0nnecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l

F t' 11 1 11. The ASME O&M code is cross-referenced but not formally 73 2 incorporated by reference. Essentially, it says that OEM ( ) 3 parts 4, 6 and 10 are meant to refer to OM A-1988 addenda to -4 the OM 1987 edition. 5 So, that's the current requirements. In 1997, we 6 proposed modifying those requirements, essentially to 7 incorporate the 1995 edition, 1996 addenda, of section 11 of 8 the boiler and pressure vessel code for ISI requirements for 9 class one, two and three components with certain limitations 10 and modifications; require pressurized water reactor 11 licensees to perform volumetric weld examinations of class 12 one portions of the high pressure safety injection systems; 13 also to expedite the implementation of appendix 8 of the 14 1996 addenda of the boiler and pressure vessel code for 15 performance demonstration of ultrasonic examinations. 16 Also to incorporate the 1995 edition; 1996 addenda 17 of the ASME O&M code for in-service testing requirements for 18 class one, two and three pumps and valves; there were a 19 couple of also additions into that proposed rule. One was 20 to require licensees to supplement their IST stroke time 21 testing of motor-operated valves with their design basis i 22 verification programs, and also, there was permission for 23 implementation of specific ASME code cases and portions of l 24 code editions for ISI and IST requirements. 25 So that's a summary. There are other parts to it, ANN RILEY & ASSOCIATES, LTD. -( ) Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 1 i

l f 12 1 too, but I tried to summarize the major parts that were in i 2 that 1997 proposed rule. Now, the supplement: the ~~' 3 supplements would establish a baseline edition of the ASME 4 boiler and pressure vessel code, section 11, for ISI and IST 5 requirements for operating plants as follows: the 1989 6 edition for ISI and IST. requirements for class one, two and l 7 three components with certain limitations and modifications; 8 the 1992 edition with 1992 addenda for subsections INE and 9 IWL for the class MC and CC components and the 1995 edition 10 with the 1996 addenda of appendix 8 for the ultrasound 11 examination performance demonstration. 12 Currently, there are about 15 te 20 licensees 13 implementing the older versions of the ASME code before the 14 description of the baseline, and the supplement would allow 15 5 years for those licensees to update to this baseline. 16 Now, the current schedule for updating is about 3 years for 17 the licensees that aren't up to the 1989 edition yet. It's 18 about 3 years. But we did not feel that there was a safety 19 impact for that slight extension for the update, so that's 20 where the 5 years came from. 21 Now, after the baseline code is achieved, then, l 22 that would eliminate the requirement to update periodically 23 the ISI.and IST programs; okay. And there's a little on the l 24 next page for the supplement. With the supplement, the NRC 25 would continue to review later code editions for 1 l l p ANN RILEY & ASSOCIATES, LTD. l Q-Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 1

r 13 1 incorporation by reference in 50.55(a) to allow voluntary 7g implementation subject to limitations and modifications that 2-b 3 would appear when those later code editions were referenced 4 in the rule. 5 The NRC would continue to evaluate provisions of 6 later code editions and determine whether implementation, as 7 a backfit, is required in accordance with 10 CFR 50.109, and C as you know, that includes things such as cost-benefit. 9 That's a test.of 50.109. There's also compliance with the 10 regulations, adequate protection and the redefinition of 11 adequacy. So there are several tests that are part of 109, 12 For future licensees, they would meet the latest 13 ASME code reference in the regulations when they were 14 licensed, but they would not be required to update their ISI /i 15 and IST programs except as specified according to 50'.109 Q~ 16 provisions. Also in the rule, the proposed rule, we grouped 17 -- you probably noticed we grouped several of the code cases 18 in portions of recent ASME code editions for voluntary use 11 9 without prior NRC approval. We tried to group those 20 together for easier reading as you went through the rule, so 21 we did that as more of a housekeeping measure with the rule. 22 okay; I have two examples that we've tried to set 23 up to kind of explain how this proposed rule would be i 24 implemented. The first example involves a licensee 25 currently implementing the baseline; that is, the 1989 q g-ANN RILEY & ASSOCIATES, LTD. (g) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 '(202) 842-0034 l l t

r; h l l 14 1 edition for class one, two and three components and the 1992 edition for the class MC and CC components, or they could be ,w 2 -( I ~~ 3-doing.it later, but basically, they're up to or beyond the 4 baseline. 5 First, they would implement the 1995 edition, 1996 6 addenda of appendix 8 according to the schedule in 7 50.55 (a) (g) (6) (2) (c), according to that schedule, and that's 8 basically 6 months after the date of final rule, as that was 9 indicated in the December rule and also our most recent 10 April rule -- supplement. They may voluntarily update to a 11 later edition of the ASME code incorporated by reference in 12 50.55 (a), and if they do, then, that referenced code edition 13 becomes the licensee's code of record. So it's voluntary in 14 the sense that you can update to it, but once you did, that /N 15 becomes your code of record. U 16, Now,l prior NRC approval would be needed if a later 17t edition of the code is not implemented in its entirety in 18 accordance with the limitations and modifications in 19 50.55 (a), and what the staff's intent there is that 20 licensees would incorporate the entire code rather than just 21 picking out certain portions of the test provisions and 22 incorporating those, and this is the cherry-picking issue, 23 which you'll probably hear more about today, but that's what 24 we mean when we're talking about the cherry-picking issue. 25 Now, this particular licensee would submit a n ANN RILEY & ASSOCIATES, LTD. t ( '# Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ) Washington, D.C. 20036 l (202) 842-0034 l t

15 i 1 relief request for any code requirements that are '.2 impractical within one year of determination of .g 3 impracticality or prior to the' start of a new program based I 4' on a voluntary commitment to a later-referenced code. So 5 that's how someone who is currently implementing the 6 . baseline or beyond would react and follow the new proposed 7 supplement. 8 Okay; for licensees who are currently implementing 9 a code edition earlier than the baseline, so this is 10 something earlier than the base, earlier than 1989, earlier 11 than the 1989 edition for class one, two and three 12 components.and the 1992 edition of the class MC and CC 13 components. You'd implement these licensees would 14 implement the 1989 or later edition of the class one, two p 15 and three components within 5 years -- this is the 5 year b 16 window -- of the final rule, and if they hadn't completed it i 17-yet, they would go ahead and implement the 1992 edition with 18 the 1992 addenda of the IWE and IWL sections for the class 19 MC and CC components under 50.55 (a) (g) (6) (2) (b), which is { 20 roughly the year 2001. You have to look at the particulars, 21 but that's roughly what we're talking about. 22 Implement also the 1995 edition, 1996 addenda, of 23 appendix 8 according to the schedule that's in the proposed 24 rule and submit any relief requests for code requirements 25 prior to the start of the updated program. We may have some ANN RILEY & ASSOCIATES, LTD. O(d. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

C: 16 1 more on the next page. This is more complicated for this l f-~g 2 licensee. \\,) 3 After implementing the baseline or a later ~4 edition, basically, now, they're up to the same level that 5 the licensee who already started from this position was. 6 The licensee can then voluntarily update to subsequent 7 editions of the code incorporated by reference in 50.55 (a), i 8 and that, once again, becomes their code of record; prior 9 NRC approval'is needed if a later code edition is not 10 implemented in its entirety, and thereafter, licensees would 11 submit relief requests for impractical code requirements 12 within one year of determining impracticality or prior to 13 the start of.the new program based on the voluntary l 14 commitment to the later-referenced code. ~ 15 So those are examples of how this proposal would 16 work. In the discussion topics for today's workshop, these 17 are the same as we outlined in the Federal Register notice 18 and the meeting notice itself. First, today, we want to 19 talk about the potential:effect on safety, including the 20 potential reductions in effectiveness of the ASME boiler and 21 pressure vessel code and the OEM codes. We want to talk 22 about the selection of the proper baseline edition. As in .23 our proposal, we have the 1989 edition. We want to talk 24 about what's the proper baseline in terms of the edition -- 25 in terms of safety, resources and efficiency. ANN RILEY & ASSOCIATES, LTD. { Court Reporters i k-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

P 17 1 We want to talk about the regulatory benefits or j3 2 hardships to licensees, industry suppliers, including t') 3 vendors,-nuclear insurers, states, standards organizations 4 and others that you can think of. We want to talk about the 5 reduction in burden on licensees to not update ISI and IST I 6 requirements and related procedures. We've heard various 7 views on the amount of that reduction in burden, and we'd 8 like to have a little bit more information on how that 9 really reflects the reduction in burden. 10 We also want to talk about the potential effect on 11 the reduction in the number of licensee submittals -- relief j 12 requests, in other words. We want to see how this proposal i 13 would effect futuste submittals. Next, we want to talk about 14 the consistency in the range of ASME code editions and tg 15 addenda applied by licensees. Is there going to be a much V 16-broader range or more narrow range, or how would this 17 proposal effect the range of additions and such that are 18 implemented in terms of on-site review and also 19. implementation by various licensees. 20 We want to talk about the potential effect on 21 risk-informed in-service inspection and in-service testing 22 initiatives. We want to know how this would effect those 23 initiatives. Those initiatives are very important, and we j 24 want to make sure that we understand what that effect will 25 be before we go too far down the road. We want to talk i ANN RILEY & ASSOCIATES, LTD. Court Reporters i (wd 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L-

m 18 1 about the potential effect on the states and other i 2 organizations that-rely on the code in interactions with 3' nuclear power plant' owners. How will this effect their 4 processes? We want to talk about the application of 5 portions of the ASME codes incorporated by reference in the 6 regulations subsequent to the baseline. Once again, this is 7 the cherry-picking assue. 8 And finally, we want to make sure that we're as 9 clear as possible in describing this approach so that the 10 people implementing it will understand it, and there won't 11 be any confusion. So that's very important, even though 12 it's the last bullet on that list. 13' In conclusion, basically, as Dick said, we're here 14 to listen to your input. You know, we're gathering i 15 information. We've been instructed by the commission to put 16 together all.of the pros and cons and come back to them with 17 the best recommendation in terms of how to go forward, and 18 that's what we intend to do today.to gather that 19 information. The closing date for public comments on the 20 proposed rule supplement is June 28. We are going to ask 21 that written comments be submitted as described in the 22 Federal Register notice. So if you make some comments here 23 today, we would like for you to go back and think about them 24 and put them down in writing to ensure they get specific 25 consideration, because as Dick mentioned, we're going to ANN RILEY & ASSOCIATES, LTD. s l I Court Reporters -/ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

n 19 1 prepare a summary of the workshop. It's going to be a 2 summary; it's not going to be a book. And we're going to V 3 give the highlights of the various positions and all of the 4 various. topics that we talk about to make sure that we 5 characterize the workshop and other information we receive 6 . properly, but it's not going to be the same as an individual 7 response to a specific question that you might want to make 8 sure that you have. 9 So we'll ask you to go back and prepare written 10 comments of your thoughts to make sure that we give very 11 specific consideration to them. So we will place that 12 summary -- we hope to have that summary done in the next few 13 weeks because of the more limited scope of the summary, but 14 we'll have to see how it goes through the review process, b(N. but we'll definitely try to get that out as quickly as 15 16 possible so that people will be able to see what we said and 17 how we characterized the workshop. 18 And finally, with the current schedule of the i 19 rulemaking effort, we hope to have it completed by February 20 2000. We hope to have the review process completed by the 21 end of this year and then have to go through an 22 administrative process to get it out the door by the 23 February 2000 time period. 50 that's the schedule. We're 24 on a pretty fast track, but we think we can do it in terms 25 of a lot of the resources we are applying to it. i( 3 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

cr i I i 20 '1 That basically.is my talk. If there are any /"N 2-questions on just sort of this overview, I'll be happy to t ~ 3 .take them now, or we can save those for when we get into 4' more of the roundtable discussion. 5 MR. MARION: One question on schedule: it's been 6 stated in some other forums and other meetings that the NRC 7 may be separating the initial December rule in its issuance 8 from the supplemental 1 proposed rule and its issuance. Is 9 that correct? Or will it all be issued at one time in 10 February 2000? 11 MR. SCARBOROUGH: The direction that we have from 12 the commission at this time is one of the documents that was 13 ' handed out in the back, the staff requirements memorandum, 14 which tells us to go forward with the proposal in SECY 99-17 (} 15 and to provide back to the commission at the end of the 1 45 process all of the advantages and disadvantages of the 17 - proposed approach regarding the 10-year update, and then, 18 they would make the final decision. So that's the path 19' we're going down at this time. That's the direction we have 20 from the commission at this time, right. 21 Anything else before we turn it over to John 22 Ferguson? 23 [No response.] j 24 MR. SCARBOROUGH: Okay; good. John Ferguson of 25 - ASME is going to give a talk on some of his views. Thank l L i 7-'g ANN RILEY & ASSOCIATES, LTD. ( ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i

p 21 1 you. i h s2 MR. FERGUSON: Good morning. I wanted to thank (s) 3 Dick Wessman and Tom Scarborough and the rest of the staff 4 'for setting this up. 5 You know, frankly, I believe this is just a very, 6 very important topic. In fact, as we got more into looking 7 at the topic, I didn't realize how important this 20-month 8 rule was to the stakeholders in the process. So I think 9 this is an important topic; I think this is a good forum to 10 discuss it. In fact, it reminds me a little bit of a code 11 committee meeting. You sit down; you think of your important points; you come together; you discuss them; you 12 l 13 debate them, and I think this will be a good forum, and 1 14 then, we sit down and come up with the best decision for 15 everybody. ,s 16 So we'll express our views; I think this will be i '1 17 like a code committee meeting. I talked to several of my 18 compatriots here, and that's how we feel. I would want to 19 say a couple of things on the ASME position, but before I 20 do, I want to say that the 120-month update is anique. It 21 works for everybody is the way we see it right now. It 22 works for the NRC; it works for the ASME, and frankly, I 23 think it works for the utilities. I want to just express a i 24 few views right now, and then, we'll go back and discuss it i 25 more. l l ANN RILEY & ASSOCIATES, LTD. T - Court Reporters /() 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 \\

22 1 The first is, frankly, the ASME feels that the f-2- endorsed proposal in the NRC supplement and the proposed \\- I 3 rule described, we do not support eliminating the 120-month 4: rule. The benefits gained in implementing the 120-month 5 update probably outweigh the costs of making this update. 6 The $200,000 mentioned in the rule, frankly, we think that 7 those costs could easily be overcome by additional relief 8 requests that would have to be submitted. 9 I would suggest that the ASME has found ways to -- 10 pardon me; I'm not that comfortable that speaking into this. 11 So if you don't mind, I'll step out a little bit. Is that 12 okay? 13 COURT REPORTER: You're off the record. 14 MR. FERGUSON: Then I will stay here. It would be r 15-helpful. 1 16 Frankly, we think that the relief requests that 17 are going to go in will cost more than the benefits that 18 will be gained by this rule. The relief requests probably 19 cost between $10,000 and $15,000 if you have a code case to 20 support it, and frankly, if you don't, it may cost you quite 21 a bit more. We think that the costs of implementing this 22 rule are really not substantiated; or the savings, I should 23 say. Also, I would scy that the ASME -- there are better 24 ways to save money. You know, we have worked hard on coming 25 up with a risk-based inspection program that we're working ANN RILEY & ASSOCIATES, LTD. ( Court Reporters \\- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034

c 23 1 on right now, and if that program goes through, there is a ,S 2 large potential savings to utilities that are using our 3 resources to do the right inspections and tests and frankly saving everybody money and doing a better job. 4 5 We think, frankly, that the cost-benefits, and the 6 point I want to'really make here,'are not really what they 7 seem to be. 8 The second comment I'd like to make is the code is 9 a living document. The code itself, although it's been in 10 existence for many years, 25 years, is a very difficult and 11 complex document. It has a lot of details in it, and these 12 details are very -- they're spread out over two books. I 13 mean, frankly, the two that we're talking about today; and 14 the code right now is going through a sea change. It's not ') 15 a mature code. Just the risk-based inspection I just talked 16 about is one of the examples I'm talking about. We have 17 operated on the code; it came from the petrochemical 18 industry, this ISI and IST program. We've learned to put it 19 in the nuclear industry, and I'm not helping you very much 20 right here. Help me out a little bit. 21 MR. FERGUSON: Thanx you; okay. 22 And that's one of the key points to make: the 23 code is a living document, and you have to -- it takes 24 operating experience; adds operating experience; it's 25 learned; it adds the experience by the plant's aging. You ANN RILEY & ASSOCIATES, LTD. s (--) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 x

(.. 24 1 know, frankly, the code cases -- the code is driven, m. 2 frankly, by operating experience and new technology. The 3 code does not drive operating experience and technology. We 4 have to have ways to deal with that, and I think this 5 120-month update is a very good way to incorporate the 6 lessons learned into the code and apply them for everybody. 7 Those are two key points I would make. Ite other 8 is -- I would want to make is that the ASME, the code 9 process really is kind of a multiplier effect. And what I'm 10 saying is that a broad-based group of experts come together, 11 deal with an issue, work it out, figure out the right set of 12 answers, and by expe'rts, I mean the regulatory people; the 13 ASME people; the users; the vendors; the AEs, all of the 14 people who are concerned and the research, and what happens /"'N 15 is we work this out together; we put it together; we come L) 16-out with one right answer to everybody, and everybody gets 17 to use it. 18 The 120-month update process helps us put this all 19 together in the streamlined basis where everybody gets the 20 benefit of this small group, and that multiplies the 21 industry experience. If you have to do that individually, l 22 that's a much more significant issue. We provide the l l 23 continuous addenda and updates; we provide user feedback, i 24 and I think that's one of the real key issues, and the other 25 thing that I would mention is that the impact on the code l I ANN RILEY & ASSOCIATES, LTD. [-~D Court Reporters A- / 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 fu

w 25 L 1 committee would be significant. You will not have this g-~s 2 collective group of experts. '"') t 3 I would estimate if we really make this change, l 4 there will be less. support for the code committees, and that 5 is very, very critical. These committees run on volunteers. 6 And without the volunteers, frankly, we're going to have an l 7 issue in being able to provide a quality product where we do 8 this type of work, work through this type of process and use 9 this multiplier effect to come up with a better product. 10 One last point that I would make, and it's 11 elimination of the 120-month update could be viewed as 12 eroding public confidence in our ability to assure an 13 adequate ISI and IST program. The bases, as I understand 14 it, for'eliminatingtheupdateareregulaboryburden, to (\\ - 15 minimize regulatory burden. Right now, the consequences of V 16 this are really a little bit unknown. This is still, as I 17 mentioned, an ongoing process; this could introduce some 18 ' uncertainty, and we're concerned about how that looks. 19 Right now, as I just heard, we'll be implementing three, 20 actually, different revisions of the code, and it will get 21 more confusing as you go forward. One of the nice things 22 about the 120-month update: it stabilizes everybody; puts 23 everybody on an even keel, and everybody is using 24 approximately the same program. 25 It's a very strong form of self-assessment when ANN RILEY & ASSOCIATES, LTD. (g j Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

p 26 'l people go through the 120-month update. The devil is in the l',g 2 details on all of.the ASME codes, and that allows you to do ' '/ i 3 a very good self-assessment when you do the update. 4 In closing, and again, I think we're going to get 5 to debate this in great detail over the 10 points today, and 6 I think that's worthwhile, in closing, I would just like to 7 say that the stakeholders, the utilities, the NRC and the 8 ASME all have a role. The role I'm trying to present today 9 specifically is the ASME's role. We are unicun in this, 10. because we have all of those players within the ASME. We 11 have the regulator; we have the utilities; and we have the 12 ASMF itself, and we have worked very well together over the 13 years, and it looks to me like this would introduce some 14 uncertainty in going forward. l ./^T 15 You know, it looks like it's a potential for not a LJ 16 win-win-win but a potential for a lose-lose-lose as we see 17 it, but we're here today to learn, to listen to all of the points and to present our unique ASME perspective as we go 18 19 forward. 20 I hope this has been helpful for you. I'm sorry 21 about the' microphone, but I did the best I could. Thank 22 you. 23 MR. SCARBOROUGH: Thank you. .24 Next is Alex Marion. 25 MR. MARION: Good morning; can you all hear me? i , 7-- ANN RILEY & ASSOCIATES, LTD. 1 4 Court Reporters \\ s' 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l

r 27 1 My name is Alex Marion. I'm the director of 2 programs at NEI, and for some reason or another, I've been 73 N-3 involved in interactions with the NRC on 50.55(a) and the 4 ASME code processes for several years, and I guess that's 5 why I'm here chatting before you. 6 I'd like to thank the NRC.for the opportunity to i 7 offer industry's perspectives on NRC's proposed supplemental ) 8 rulemaking. Many of you may not be aware of the fact that 9 'we've been working with the NRC for several years to'get to 10 this point, and I'll elaborate on that in a little more 11 detail. 12 We are very pleased and happy that the NRC has 13 chosen to hold this meeting to discuss issues.and hopefully 1 14 answer questions related to the proposed changes that are before us. I'm looking forward to an open, candid ) O 15 16 discussion of the 10 or so topics NRC identified relating to 17 the proposed elimination of the 120-month update, and I ~ 18 encourage all of you to participate as well. Now is the { 19 time, and this is the opportunity. 20 This is a significant opportunity before us. It's l 21 analogous to stakeholder meetings that have been held over 22 'the past year and a half or so where we have an opportunity 23 to express our opinions, what we think, good, bad or 24 indifferent about the topics before us, so let's take 25 advantage et it. I ANN RILEY & ASSOCIATES, LTD. -[^ - Court Reporters s_- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i

28 1. If my memory serves me well, and at my age, 7-_q 2' sometimes, I have to double-check, but I didn't double-check i \\ iss' 3 this morning, so bear with me: the genesis of what brings 4 us'here today was the cost-beneficial licensing action that 5 was submitted by Entergy back in the 1993-1994 time frame. 6 Simply put, the submittal requested that the 120-month '7 update be deleted from 50.55 (a) with no further mandatory 8 updates being imposed. The basis for the request was that 9 the burden associated with continuing updates was not 10 commensurate with the increase in safety. 11 The burden I'm talking about is the cost to 12 utilities in developing the program and implementing the 13 program, and I believe during the course of the discussions 14 later today, you'll get a better. sense of today's costs in 15 terms of that burden. The issue, the core of the issue was 16 baselining the 1989 addenda. Now, recognize this was 5 or 6 17-years ago. At the time NRC received this request from 18 Entergy, I have to give them a lot of credit that they 19 realized the significance of what was being propcsed. They 20 recognized the generic applicability, and they sent a letter 21 to NEI requesting NEI. participation in addressing this 22 issue, working it with Entergy and the NRC and trying to 23 . figure out what's the best approach to take industry-wide. 24 When we responded to that request, we formed a 25 task force comprised of about -- I think it was about eight ANN RILEY & ASSOCIATES, LTD. l I'D Court Reporters (. l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

? 29 1 utility personnel -- who were very knowledgeable in the I 2 ISI/IST area. Most;of.them were supervisors or managers of 3 the function area that had that responsibility at the i 4 utility plant, and we developed a series of positions or 5 thoughts or suggestions, recommendations, call them what you 6 will, but things to discuss with the NRC. We had a couple 7 of public meetings; we commented on the proposed rulemaking l 8 at the time,.and we encouraged, and we continue to encourage 9 over that time period, to create the opportunity in a forum 10 -such as this to discuss the issues with one straightforward, 11 fundamental objective, and the objective is to discuss all 12 of the issues, good, bad or indifferent, so that the NRC can 13 make the right decision, okay? 14 And the opportunity is here to put the information (' ' 15 before the NRC staff, because I have been given great ( 16 assurances by Dick Wessman that they are going to make the 17 right decision. Well, here we are. NRC believes that the 18 overall level of safety significance achieved by adherence 19 to the 1989 baseline edition of the code would be sufficient 20 and adequate. We concur and support appropriate regulatory j 21 action to revise 50.55 (a) accordingly. 22 Each plant that has been licensed to operate has a 23 code of record that NRC reviewed and determined to be 24 adequate and sufficient. So it seems that over a period of 25 time, you would get to a point where demonstrated plant f-~ ANN RILEY & ASSOCIATES, LTD. ( )g Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

K-l 30 t i safety. system performance and safety component performance -g3 2 and reliability would raise the question of whether or not ~ Q E 3 it makes sense to continue a periodic update of this 4 ' program. 5 Well, here we are. I' keep coming back to the same 6 thing. Is this the right or wrong regulatory action? '7 That's one of the questions I think we have to come to grips 8 with. What will be the impact of this proposed action on 9 utility licensees, the ASME, and, of course, we need to 10 think about the impact on the NRC, because the NRC has to 11 continue with inspection activity as a result of whatever 12 decision they make on this rulemaking. 13 Is this the right thing to do in terms of 14 . practical, reasonable and fundamentally sound decision .(~) 15 making? I think the opportunity is here that the NRC can V 16 gather the information and make tne decision based upon what 17 makes sense, what's in the greatest interest of public 18 health and safety and what's_important from a regulatory 19 point of view and with that, get an understanding of the 20 burden associated with what's been done in the past and the 21' improvements that will be achieved as we move into the 22 future. 23 And again, one of the things that we need to think 24 about, and this was somewhat touched on by John Fergu on 25 from ASME, is baselining the 1989 code adequate and ANN RILEY & ASSOCIATES, LTD. i (f~s) Court Reporters \\ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

p p 31 ( 1-sufficient, or do we need to-maintain a continuing 120-month es-2 update? The NRC has already determined that it is adequate 1 \\',1 l 3 and sufficient; they've already determined that prior 1 4 editions of the codes of record at utilities are adequate 5 and sufficient. That's a very important theme and concept 6-to keep in mind as we go through the rest of the discussion. 7 I look forward to today's meeting, in which all of 8 you will participate, and I really encourage you to do so, 9 so that we may provide the NRC answers.to these and other 10' questions. 11 I'd like to make a comment in response to John 12 Ferguson's statements, if I can. The idea or the perception 13- -- now, maybe this is the wrong observation, but I'll bring 14 this up again during the discussion session, but I want to AN 15 plant the seed so we all have an opportunity to think about N._ 4 16 it, but the suggestion that a continuing NRC mandate, if you 17 will, through 50.55 (a) requirements is necessary to ensure .18 continued participation in ASME committee activities I find 19 very troubling, okay? 20 We had a meeting yesterday that was set up by the 21 NRC in this very auditorium that involved about -- what? 22 8 to 10 standard organizations, and NRC research was led by 23 John Craig to basically talk about NRC's role in i 24- -participation in the standard development activities and 25 endorsement of the products that come out of SDOs, and one 73 . ANN RILEY & ASSOCIATES, LTD. A--} t Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

32 1 of the points that came out was that the standard 7-~3 2 development organizations need to maintain independence, t /- 3 focus on developing technically objective documents, et 4 cetera; ensure that what they do proceeds with due process; 5 ensure that what they do provides value to their membership, 6 and the problem we keep running into is when you take 7 . fundamentally sound technical principles that are integrated 8 into codes and standards and try to apply them in a 9 regulatory environment. 10 Okay; that's what we talked about yesterday. It 11 had some really interesting discussions and topics, and we 12 basically agreed yesterday that we're going to continue 13 these meetings at 6-month intervals for probably the next 14 few years. But here we are today, where we have a proposed (/)' action by the NRC that's suggesting elimination of what is a 15 '~' 16 technically sound document from the standpoint of a code or 17 standard in 1989 baseline from the regulatory process. And 18 oh, my God, we don't know what to do. We don't know what 19 this means; we don't know what the impact is going to be. 20 Well, I suggest we think about it and again take 21 advantage of the opportunity to address all of the issues 22 and questions, and that's the end of my closing remarks -- 23 opening remarks; I'm sorry. Does anybody have any 24 questions? 25 [No response.] l l ANN RILEY & ASSOCIATES, LTD. (7s) Court Reporters x/ 1025 Connecticut Avenue, NW, Suite 1014 ( Washington, D.C. 20036 l (202) 842-0034 l 1

l. 33 1 MR. MARION: Okay; thank you very much. 2 MR. SCARBOROUGH: Okay; we had Mr. Ray West call fs 3 me yesterday and indicate he'd like to make an opening 4 remark. Is Ray here? I don't know Ray. Is Ray here? 5 MR. WEST: I had a presentation. 6' MR. SCARBOROUGH: Yes; who are, you sir? 7 MR. WEST: Ray West. 8 MR. SCARBOROUGH: Oh, come on down. 9 Yes, Mr. West is going to give a presentation as a 10 private citizen, and is there anyone else here who would 11 like to make a presentation after Mr. West? Anybody else? '12 We're going to have a roundtable discussion, but we could 13 have some comments, you know,.right after Mr. West finishes, 14 see what time it is, and we'll work that in if we can. S 15 MR. WEST: My name is Raymond West, and I've been ' (~-] 16 here many times in thic building, usually wearing an ASME 17-hat or a Northeast Utilities hat, the company I'm employed l i 18 with or a Westinghouse Owners Group hat, but my company has 19. not formed a position on this issue yet, and it would be 20 unfair for me to speak for them, and I'm concerned about 21' this amendment change, and as a member of the public and an 22 individual who has over 20 years' experience with ISI, I 23 want to get my points across before there is any discussion, 24 and hopefully, there's some good discussion after those 25 points. ANN RILEY & ASSOCIATES, LTD. (N Court Reporters \\- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

p L 34 1 I've got four basic concerns with this action. I ,p 2 - think change is good, and you've got to believe that today 3-if you want to stay employed in this environment. This 4 change doesn't hit the mark. The first issue with what I l 5 saw in the proposed amendment, and I missed the earlier 6 discussions; I had a. late plane this morning, dealt with the '7 baseline additions and addenda of the code that's being 8 applied. This is a maturity issue, and the 1989 edition is 9 being billed as the acceptable' edition and addenda for 10 , general ISI; the 1992 edition, with the 1992 addenda of section 11 for containment ISI; and the 1995 edition with 11 12 the 1996 addenda for appendix 8. 13 In general, the code is a living document, and you 14 can't baseline an edition and addenda as an acceptable level /N 15 of quality from day to day, because it changes, and an 16 example for the 1989 edition is at Millstone Unit 2, we just 17 updated our 10-year program at the end of 1998. With that l 18 update came 17 relief requests. Fifteen of.those were to 19 use code cases that are alternatives to the rules in the 20 1989 edition, to make that program practical. Seventeen 21 were plant specific. 22 When you get into the next version of the code l 23 that's in the amendment for containment ISI, it's the 1992 24 edition with the 1992 addenda. The industry, for a long 25 time, paid no attention to those code rules for containment ANN RILEY & ASSOCIATES, LTD. V) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 i (202) 842-0034 I 1.

F 35 1 until they were put into the regulations. When they got l- !, s 2 into the regulations, there was significant code committee lf 3 action to. change those rules, because people had to look at 4 it from an implementation standpoint. EPRI took the ball, 5 and as a result of committee work under the EPRI 6 organization, they recommended seven to nine relief requests 7 just to write the program, not to implement it, to make it l 8 practical to use. 1 9 Now, we've taken the position at Northeast 10 -Utilities to submit a request to use the 1998 edition, 11 because it's ridiculous to have to write seven to nine 12 relief requests just to write a program. Once that program 13 gets implemented, there are going to be a number of relief 14 requests having to be written to implement it. /~T 15 The next item is the appendix 8 criteria b 16 requirements. Once again, because it's coming down to the 17 wire that we have to implement those requirements in this 18 industry, action was taken, and the people came to the 19' committees, and they worked together through-the ASME 20 process, and they created a code case: N622. That code 21 case is going to be used by every licensee in lieu of the 22 code requirements. I don't picture any licensee doing that. 23 So from a timeline basis, I don't know how you can fix a 24 code edition and addenda as an acceptable level of quality 25 and safety because it changes. And I do have a recommended ANN RILEY & ASSOCIATES, LTD. ,[s Court Reporters !-} ' k 1025 Connecticut Avenue, NW, Suite 1014 ) Washington, D.C. 20036 (202) 842-0034

{ l 36 l' alternative at the end to address that. (~']3 '2 The next issue is focus. When you look at ISI ~ ' 3 programs, and I'm speaking strictly from ISI, because that's ( where my experience is, the programs at our plants range 4 5 from 4,500 to 7,000 items per plant, and you're constantly 6 in an implementation phase of that program, from outage to 7 outage. You plan your inspections; you do your inspections; 8 -you plan your~inspectionsi_you do your inspections, try to-9 get.the feedback in there. Everyone's configuration and 10 control program is not perfect. The only time those i il programs get looked at in detail is for the 120-month i 12 tipdate, and when that happens, it's an. extensive effort for 13 the utility, but it identifies things that were missing; 14 sometimes' safety significant, sometimes not; things that - (} 15 need to be deleted based on the new requirements; new %.J 16-examinations; a whole gamut of changes. 17 If you take away the update, you take away the 18 focus. The priority of the program will be a low-priority 19 program, and that's not going to get looked at. 20 My next point is cost. This action is billed as a 21 burden reduction. We're talking $200,000 to $300,000 every 22. 10 years to upgrade the programs. It may be a little less 23 than that depending on your contractor support. But what's 24 not talked about is the additional cost that you're going to 25 incur trying to.make the 1989 edition practical to use. g--) ANN RILEY & ASSOCIATES, LTD. ( j Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

37 l 1 You're going to need relief requests. You want to take i 2' advantage of what the industry produces that's better. It L ('T s / 3 just so happens that at this point in time, for about the 4 last 8 years, most of the code cases that have been issued, l l 5 and rightly so, are reductions in requirements. So you want 6 to take those. 7 But there may be plant-specific issues that you 8 want to deal with. If you take a code case, and you back 9 that, and you take a relief request, and you back it up with 10 a code case or some kind of industry generated document, it 11 only costs you $10,000 to $15,000 to process that. If you 12 try to do it on your own, which I.believe this amendment, if 13 implemented, will force, it's going to cost you anywhere 14 from $50,000 to $500,000, depending on the complexity of the ) 15 issue, so it's not right. 16 The next point I want to cover is the state 17 requirements. I don't know what the state requirements are 18 going to be as a result of this. Some states are code ~ 19 states for section 11, and some states aren't. But if they 20 object strong enough, they may implement their own 21 regulatory requirements. And how is that going to look in a 22 national picture, a national level, to have one state 23 requiring something that the other one doesn't for nuclear 24 power? We don't need that. 25 So in my handout, I looked at this and thought l l ' ANN RILEY & ASSOCIATES, LTD. . A) ( Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I

1 l 38 about it and tried to come up with norae kind of proposal 1 (~] 2 that could be used that would help. I'm not.always right, \\.J' 3 but I like'to get my opinion out there, and I think I've got 4-enough experience to at least present that. First, I'd like 5 to see the code editions and addenda as published be used, 6 because they represent the best we'know today. Second, the 7 emphasis right now is that you update to a code edition and .8 addenda that the NRC has approved. Their process of 9 approving a code edition and addenda takes forever. We're 10 up to the 1998 edition now, and under this amendment we're 11 talking the 1989 edition. There is a big disparity in those 12 requirements. They may be good, they may be bad, but they 13 are better. 14 And the next point is how does the regulatory () 15 agency control these updates? I would suggest that if they %.J 16 have an objection to a code change that they publish it in 17 tho' Federal Register and no one use that part of the code, 18 paragraph, edition, code case, whatever it is, until they've 19 had a year to evaluate it to the back-fit rule. If it comes 20 out that it's definitely anforceable as an objection under 21 the back-fit rule, then fine, nobody uses it. If not, after 22 a year, use it. Make people accountable and responsible for 23 what they have to do. 24 And the other point that I forgot here and I need 25 to mention, and it's very important, is that you need to rw ANN RILEY & ASSOCIATES, LTD. l l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 l

{ 39 1 maintain this update, and the update, as a minimum, should 2 U(' apply to a code edition and addenda that's no more than 10 7 3 years old, and that's only an arbitrary time. It could be 4 less; it'could be more. But you certainly, with~all of the 5 changes that have occurred within ASME and the code, do not 6 want to use a code that's more than 10 years old, and I 7 _ venture to say there is no ISI people in this room who have 8 a 1989 edition program that doesn't have significant numbers 9 of relief requests against it. 10 So, in summary, I think this amendment is a 11 mistake, and it should not be approved. Burden reduction 12 will not be a result of this amendment; it's going to cost 13 us more in the long run. 'The quality of the in-service 14-inspection programs are going to go down, because we don't ! }/) 15 have focus, and the use of new technology will become %-) \\ 16 cost-prohibitive, because we're going to have to address it i 17 as an individual plan, and that can be very difficult. i 18 And that's all I have to say; thank you very much. 19 MR. SCARBOROUGH: We have a little bit of time 20 before our first break. Come up and introduce yourself and 21 make a couple comments. 22 MR. SWANN: My name is Dennis Swann. I'm here 23 representing Southern Nuclear Operating Company and also a 24 concerned individual for the livelihood of nucledr power. ~ 25 So far, I've heard two very good presentations, one from Mr. j l ANN RILEY & ASSOCIATES, LTD. ,s ( )' Court Reportels V 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I l L_

C 40 1 Ferguson, one from Mr. West, and I, too, share both of your f~3 2 concerns, but I have a couple of counterpoints to some of 3 the issues that you raised. 4 Mr. Ferguson, you used the fact that you're afraid 5-that this rule change will affect the risk informed 6 application as it applies to the code. You stated that one 7 of-that reasons was that by not having the 10-year update, i 4 8 you think it will degrade the process. I represent three 9 nuclear plants that have six units. Over the period of the 10 next 3 to 4 years, we've already budgeted money to move all 11 of our programs to risk-informed ISI. If I'm wrong, please 12 correct me, Mr. Roley, but all of the emphasis in 13 risk-informed, one of the major aspects of it was that it 14

a. lowed for continuous feedback; in other words, the (G~'g 15 risk-informed process is automatically updating.

Once you 16 go to a risk-informed program, and basically, what edition 17 Jof the code you're using doesn't'really matter. 18 I mean, your emphasis is to determine what's 19 safety significant and'what's not safety significant and do 20 the appropriate testing for each. So whether you have a 21 10-year update or not shouldn't really matter, because 22 you're going to use the feedback; you're going to use the 23 implementation of risk-informed to constantly update your 24 program. 25 I also heard a couple of comments about you're 1 -l ANN RILEY & ASSOCIATES, LTD. 7s Court Reporters \\~ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l-l L

e 41 1 afraid that industry. participation in the codes will ,r~} 2 decrease. I believe industry participation in the codes V 3 will increase. The justification'for that or my logic behind that is the fact that people keep saying oh, it's i 4 5 $200,000 to $300,000 for an update; oh, it's X numbers of 6 thousands of dollars to process a relief request. Mr. West y 7 used the example that his present ISI program contains 17 8 relief requests, 15 of which are simply to apply code cases 9 that have not been incorporated in the regulations. It 10 -seems to me that the proper approach is for the NRC and ASME 11 and everybody to work together and come up with an 12 expeditious process for approving code cases and later 13 editions of the code and make those available for people to 14 use. 15 Mr. West, if these code cases had been approved,. s 16 the best I can tell, you would have only had two relief i 17 requests. 18 MR. WEST: That's right. 19 MR. SWANN: Okay; so, it looked to me like the 20 problem is not really the update; the problem is the 21 administration of how the ASME and the NRC and us licensees 22 all work together. 23 I think part of the comment is that people keep 24 saying that well, the licensees pay for what they want. I 25 think that's very true. I think that's going to be true in 7-ANN RILEY & ASSOCIATES, LTD. .t Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l i L

r-1 e 42 1 the future. So if the code is working on code cases that i (~T 2 are enhancements to aid licensees and so forth, then, their 'i s 3 participation should actually increase if they believe that 4 there is a possibility that these code cases will~be 5 _ approved, will be endorsed by the NRC and be'available for 6 automatic use as opposed to the licensing process and the 7 review process and the relief request process. 8 I've heard some very good comments. I agree with 9 both.of you. I'm very concerned. But my standpoint is that I 10 I believe that.there's far better use for the money and the ~ 11 time and the effort of not only licensees but ASME and NRC 12 to eliminate the 120-month automatic update, and let's 13 concentrate on doing what's right and doing what's best for 14 everybody. ( 15 Thank you very much for your time. 16 MR. SCARBOROUGH: Thank you. I 17 Anyone else like to make an advance comment? I 18 know Mr. Brent Metro from the Illinois Department of Nuclear { 19 Safety was going to' join us. Is he here? 20 Would you like to make brief remarks? 21 MR. METROW: I do. I have a few things to say. 22 Thank you; I'm Brent Metrow from the State of 23 Illinois, and I work with Larry Sage, and we both are 24 involved with the ASME code process, and unfortunately, t 25-though, my comments today are not as a state agency's 1 n ANN RILEY & ASSOCIATES, LTD. l \\" Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

p I 43 1 comments, because we haven't formulated them yet, so these '"} 2 just represent Larry Sage's and my comments. I j 3 Firstly, I agree that the updates to the code 4 process have been useful in allowing users an opportunity to 5 look back over their 10 years, picking up changes in the 6 plan, picking up changes in the plant that will result in 7 changes in the plan and finding mistakes, and to eliminate 8 this would not be a benefit. Although, for those who work 9 with the code, they realize that any one particular edition 10 or addenda of the code may not have significant impact as to 11 their -- as to any one particular change, but if you view 12 them, if you view the changes that occur over a large enough 13 period, say 5 or 6 years, there are significant changes in 14 the code, taken together, that cumulatively are of benefit [ 15 to the users and have a great effect. 16 I have to question the $200,000 to $300,000 update 17 cost, because -- as not being a realistic estimate, some of 18 'this money has to be spent on modifications to the plant, 19 plant configuration, code case application, so that 20 particular figure, I think, is overestimated. 21 It was mentioned earlier about state concerns. 22 Some states automatically, 6 months after a code comes out, 23 have an update process and incorporate code updates into 24 their state laws. This could run into legal problems with '25 where an edition and addenda are faced for the 10-year plan, j ANN RILEY & ASSOCIATES, LTD. -\\- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034

44 1-and the state, on the other hand,. requires a newer edition /3 2. and addenda. 'b 3 I missed an earlier presentation, and this may I } 4 have been covered, but the main committee chairman has 5., . hinted that they may not wish to keep old code cases active 6 'and may annul them. This would not have a. good effect on 7 plants that are using the 1989 code edition. We agree that 8-membership in Section 11 may wane from the utilities' 9 perspective. This will have a definite effect on emerging 10 technology. The interest will focus on code cases and j 11 interpretations and not on current changes to the code, and .12 we'think that no one or that there will be a reduction in 13-the bringing forth of new technology. 14 I can only think that forcing three different h 15 versions of the code, 1989 and, for the main body, 1992 for G 16-containments and 1995 will only force confusion on the 17 ~ administration aspects of a program, of implementing 18 multiple programs. It would be better to require one code i 19 edition and addenda for all these activities and one that 20 would be more current than the 1989 codo. i 21 One thing to consider, one thing for the NRC to 22 consider that maybe it would be easier if the NRC only 23 requires approval of relief requests and not necessarily 24 approval of the plans, and perhaps more flexibility with the 25 update selection; now, there is a -- the NRC requires to I i (^ ANN RILEY & ASSOCIATES, LTD. Court Reporters i l' 1025 Connecticut Avenue, NW, Suite 1014 4 Washington, D.C. 20036 (202) 842-0034 L

b 45

1 select'a code one year before the end of the interval and h 7-c.

2 -submit the new plan 6 months before; perhaps this can be E;!" L 3 Lloosened'somewhat to make it more flexible. 4. .I think my biggest point is going to be that -- my 5 final point, and that's that if you come to Illinois and any 6 other state, and you want to build'a boiler, or you want to 7 build a pressure vessel, you build it to the latest code. 8 Why wouldn't you want to use a more later code than the 1989 9 code for nuclear power plants? 10 Thank you. 11~ MR. SCARBOROUGH: Thank you, Brent. 12. Anyone'else? 13 Yes. I-14 MR. ROWLEY: I'm Wes Rowley, a member of the ASME l I /~ 15 board of nuclear codes and standards with John Ferguson, l v] 16 Jerry Eisenberg, also a member of the ASME O&M committee, l 17 consultant; been in our industry for 25 years here, and I'd 18 just like to maku a' couple of comments as an individual. 19 I have come-to' realize that this whole ASME code l 20 development process, whether it's fci 4.SI or IST or any of 21 the other many committees that the.jME has, has a real 22 value added for the industry in that JLt really gets all of 23 the people who are interested in a particular technical 24 issue'together talking about it, and each one of us probably 25 starts out with a. position, and when we start' talking to our ANN RILEY & ASSOCIATES, LTD. ~( /I Court Reporters ' A-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 1 (202) 842-0034 u

l 46 1 peers on the subject and working out those differences, a g3 2 lot of times, our position will change. 3 And so, these technical requirements that appear in the various code editions and code addenda really reflect 4 5 the best knowledge that the industry has at that moment in time, and to freeze that in 1989 or 1992 or 1995 is just 6 it's just not really taking advantage of our body of 7 8 knowledge that we have today, in 1989, and we will have 9 better knowledge in the future. 10 So the point is that these are living code j 11 documents; they really evolved, and we really have to come 12 up with a way to figure out how to use these things. In my 13 mind, the slow, official endorsement of these codes by the i 14 NRC is probably the real root cause of the whole question /T 15 we're really talking about here today, and it really kind of U 16 comes down to the administrative side. The technical 17 requirements are evolving. They're being improved. So 18 we've got to figure out a way that whatever the obstacles 19 are to having these codes endorsed by the NRC for ISI and 20 IST, we need to figure out a way to figure out, you know, 21 how to solve that problem; you know, being 10 years behind 22 is really totally unsatisfactory for the nuclear industry. 23 And the last point I want to make is a little bit 24 about the risk issue. I think this really applies to both 25 in-service inspection and in-service testing. The ASME is ANN RILEY & ASSOCIATES, LTD. t Court Reporters \\-- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l~ 47 very interested in applying risk to these two programs. The 1 1! risk that we've done to date is certainly-not perfect. You 3 know, it's still evolving; it's still improving. 4 Performance is another aspect that we're trying to put into 5' our codes. That's also evolving. So, as I think Dennis 6 said earlier, yes, we want to apply risk and performance to 7 our plants, but the code hasn't got that perfect yet. It's 8 still evolving. So we really need to figure out a way to l 9 make that happen in the future. 10 And as this becomes better and better, plants will 11 want to use it more and more. So anyway, the point I just 12 want to finalize and say is that it seems like the paradigm 13 that we've been using for the last, you know, several 14 decades, we're proposing to change drastically here with ,/ ) 15 this revision, ar ' I said before we really get into it, and 16 I accept this rulemaking, let's really carefully think out 17 what is the pros and cons of what is happening here, because 18 it is really drastically changing what has worked well in l 19 the past. 20 So, thank you. 1!1 MR. SCARBOROUGH: Okay; any other comments? l 22 Yes, sir. 23 MR. SHAW: Good morning. My name is Shern Shaw. i l 24 I'm a supervisor for the ISI program at Southern California l l 25 Edison at the San Onofre Nuclear Power Station, and I'd just i ANN RILEY & ASSOCIATES, LTD. i Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

r 48 1 like t'o represent our plant and the people who run the ISI (']' 2 program at that site today. R-3 With over 25 years of experience there and with 20 4 years of experience in the plant itself, we don't believe 5 that the 120-month update adds that much safety margin, 6 increases the safety margin to the program. We've gone 7 through the program individually, point by point.

Sure, 8

that update'does provide us a method to review the program, 9 but prior to each outage, my staff goes through the entire i 10 program again and provides that assurance that we're doing 11 the right thing. 12 So having a burden to update the program to a 13 newer edition doesn't provide us anything except a cost to 14 the plant. As far as the cost estimate, before we came to h) 15 .this meeting, we sat down, and we believe for both ISI and %/ 16 IST, the eventual cost of updating in about 2003, when our 17 next 10-year update is due, will approach $1 million for our l 18 plant, and there is no increase in safety that we can think 19 of. I 20 We've been attuned to the ASME and the NRC and ] 21 what's good for our plant all along. The update itself does 22 not mean we can't update the program. When a new code case 23-comes out or a change in the code for better technology 24 comes along, and it shows a cost benefit to us, we'll be the 25 first in line to support that, to support it with our I (7 ANN RILEY & ASSOCIATES, LTD. ) Court Reporters -\\ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 j (202) 842-0034

b 49 1 resources, and to attend the code case or the code committee ! ) 2 meetings and provide our support to that. ~ 3 But the code committee itself has to realize that 4 if they do something, the end result has to be a cost 1 5 benefit for the utility. They just can't go off on their { 6 own and say this'is brand new technology, and we don't have 7 any benefit for you. 8 So if they choose to update the code with new 9 technology, then, the utility, especially my utility, would 10 support that. Our risk-based ISI is a case in point. That 11 needs a constant update. That's not relying on a 10-year or 12 a 120-month update, but it needs a constant feedback. So I 13 think the current rule as proposed is a win-win situation 14 for'the ASME, for the NRC and for the utility. (~T 15 Thank you. 3 LJ 16 MR. SCARBOROUGH: I saw one more hand over here. 17 Yes? 18 MR. HERMANN: Hi; I'm Bob Hermann of the staff, 19 and I'm speaking in behalf of myself rather than as a 20 position for the agency and really not commenting as to 21 whether the update is appropriate or not appropriate but 22 maybe to put on the table a couple of issues that might be 23 related that haven't been discussed so far. 24 One of the things that we haven't talked about in 25 terms of the discussion so far is the effect of relief 73 ANN RILEY & ASSOCIATES, LTD. ' ( Court Reporters 1 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 i

fi i l 50 1 requests and how they may be affected as part of the update, 2 Normally, they've been good for like a 10-year term. I'm t a v i ~ '3-not sure that we quite understand where they would be right 4 now if'we didn't update. 5 Some of the other things in terms of technology is 6 if there were no program updates, there might be some things 7 like if,you had an instance where relief were granted 8 before, say, for a. vessel inspection, which is very 9 important for life extension; technology like the more 10 mobile type inspection units wouldn't be considered in terms 11 of whether the practicality of being able to do inrpections, 12 say, of a vessel. 13 The other thing is code cases. I don't one of 14 the things I think the NRC was trying to do generally over ) 15 the years was to regulate by incorporating code editions and 16 addenda and to use code cases alternatives to try to get 17 uniformity, and I don't think the expectation was that the 18 basis of the rule would be all alternatives based on a large 19 number of code cases, which is where things might end up if 20 you froze.a code edition and went to an instant where there 21 were a large reliance on the use of code cases to -- in lieu 22 of the basic code. 23 In the past, there's been certainly a desire for 24 - uniformity, and what gets done by various people in trying -25 to make evenhanded requirements among the people and -- just )s ANN RILEY & ASSOCIATES, LTD. ['(' }- Court Reporters '1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034 t L ~

? I 51 1 'those are some_ issues that I think need to be discussed. ,f% 2 MR. SCARBOROUGH: Thanks, Bob. [ () \\ 3 We had one other person. 4 4 Come on down. 5 MR. HEDDEN: Yes; my name is Owen Hedden. I I 6 arrived a little late, so I didn't get the ground rules on 1 7 the meeting this morning, but I did want to talk a little 8 bit about it. I'm coming here with, I guess, 40 years in 9 the nuclear power plant business, 30 years with ASME Section ) 10 11. 1 j 11 The Section 11 committee had a meeting last week. 12 I had another commitment and wasn't able to attend, but one 13 of our members, this topic was discussed there, and one of 14 our members did compile the comments that he heard at that 15 meeting, and I'd like to very briefly just present a little 16 bit of that and give the secretary his paper for the -- to 17 let you know what we've done and who did it. That gives you 18 a little idea. 19 The paper that was proposed, that was prepared, 20 noted a number of arguments -- oh, okay, thanks, Ray -- a 21 number of arguments on both sides. Certainly, the committee 22 people were not agreed on this. Now, when I say the 23 committee people, we had four days of meetings involving 24 approximately 200 engineers in the course of the week, and i 25 about a third to a half of them are from the utilities. The ANN RILEY & ASSOCIATES, LTD. ~- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034

l I 52 1-others are other people involved in the industry, like us A. 2 manufacturers; the NRC people and the consultants. 3 They had a number of areas that weren't summarized i t 4 into these points, and I'm not going to go through those, 5 because that would take too much of your time this morning. 6 One thing that I noticed from the comments that 7 _have been given so far that hasn't been touched on is that l 8 _Section 11 is more than just an inspection program and 9 inspection methods. A big part of Section 11 is repairs and 10 replacements, repair methods, and that hasn't been 11 mentioned, hasn't been considered particularly in this 12 update, and that's an important part; a lot of changes are 13 being made in that area. We're making a lot of progress 14 there. 15 One of the things that was really brought home to 16 me yesterday after lunch, a couple of people from our 17 company came around to see me and said they had a question 18 about welder qualifications. Well, we're moving ahead in 19 -the area, and we're doing laser beam welding. Electronic j 20 beam welding is being used in another application, and if 21 we're stuck at the 1989 code, those methods are not 22 recognized for qualification of welders, welding personnel, 23 welding machine operators. 24 They show up in Section 9, which is the welding 25 . book, after the 1989 edition, and we've got the inspector g ANN RILEY & ASSOCIATES, LTD. g Court Reporters 1025 Connecticut Avenue, IM, Suite 1014 Washington, D.C. 20036 (202) 842-0034

[ 53 L 1 saying no, you can't use those methods because we don't have t. 2 a' process in the code for qualification of the welders. 3 That's the sort of situation you get into when you try to 4 freeze yourself into the past. I think there is a lot of 5' hidden benefits in keeping the process moving forward; I 6 endorsing the latest editions of the code in a prompt 7 manner, and I'll stop with that. 8 Thanks. 9 MR. SCARBOROUGH: Thank you. 10 Any other initial remarks or prepared remarks 11 someone would like to make? 12 [No response.) 13 MR. SCARBOROUGH: Okay; good. Dick Wessman has 14 one or two comments he'd like to make, and then, we'll take 1 O-15 our break. 16 MR. WESSMAN: I want to offer just a couple of j 17 comments and a little. bit of reaction to a couple'of the i 18 things that I heard,.and I also want to clarify a couple of 19 things, and then, we'll do with our break. i 20 You may have heard early on, when Alex Marion 21 spoke on behalf of NEI, he kind of smiled at me and said I'm 22 sure you all in the NRC and Dick Wessman will do the right 23 thing. I need to respond to that in yes, we will do the 24 right thing. I don't know what the right thing is yet. ~ 25 That's why we're here today, but I do not want to send a . 7- -. ANN RILEY & ASSOCIATES, LTD. l q Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F l ) 54 1 signal or offer an implication that because one individual (~) 2-or any individual says Dick's going'to do the right thing i'~/ 3 that I and that individual have decided what that right j 4 thing is. We haven't. That's why we're here. 5 Secondly, we've had some reference to code cases 6 on various presenters, and one of the administrative issues 7 dealing with the code cases has been the untimely 8 endorsement by the staff of various code cases and the 9 issuance of the regulatory guides that endorses those code 10 cases. There is a story, and it's a long one, and it's 11 taken us a'long time, but I did talk with the people 12 involved with that this morning, and believe it or not, the 13 code case regulatory guides went to the printer today, and 14 they should be on the Web site and should be available for \\ 15 (d people to use within 30 days or so, and this will endorse 16 the collection of code cases through 1995, I believe, so 17 this eliminates a nuisance that has been out there for many I 18 of you for a long time and means that witn that list of code 19 cases, licensees and utilities can make use of them without 20 having to come to the staff with a specific relief request. 21 Thirdly, I would offer a comment regarding what I 22 might refer to as being stuck with the 1989 baseline. I 23 think if you look carefully at the rule as it is proposed, 24 _the concept of 1989 baseline is there, but nobody is stuck 25 with the 1989 baseline, and the intent of the staff with 7g ANN RILEY & ASSOCIATES, LTD. 1,') Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

c. 55 1 this approach is to endorse and continue to endorse in the 2 future later versions of the ASME code for voluntary 3 implementation by licensees if they so choose, with whatever 4 limitations may be in that particular rulemaking. 5 But I don't want to leave people with the 6 impression that we are setting a situation where licensees 7 are stuck or required to use the 1989 version and could not 8 make use of later provisions and later benefits or later 9 technology. That's just not the case. We are expecting 10 that if this proposed rulemaking is implemented and that licensees wanted to use later versions of the code that they 11 4 12 would adopt that version in its entirety. That eliminates 13 this concept of cherry-picking that Tom referred to earlier. 14 On the other hand, if a licensee says I really am () 15 only interested in one particular verse of the 1998 code or 16 one particular section, there is nothing in the regulations 17 that precludes a licensee from coming to the staff and 18 providing a basis of why they want to select that version 19 but not all the rest of the 1998 code. 20 So, in fact, the proposal that in part is on the 21 table does not baseline people; does not force people into a 22 particular situation and does allow a certain amount of 23 flexibility. 24 Okay; what I would propose at this point in time 25 is that we take our break, and I think we're thinking in (~x ANN RILEY & ASSOCIATES, LTD. (,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l 56 1 terms of 15 minutes, Tom, and then, we'll constitute the .r) 2 panel. We're not sure whether, because of the number of i V 3 people, whether we'll move ourselves into a U-shaped table, 4 or we'll.ask our panel to be up in front. It's a little 5 more of a nuisance, but we'll do the best we can to 6-accommodate everybody, and we'll work on the 10 subject 7 areas for discussion, 8 Thanks. 9 [ Recess.] 10 MR. SCARBOROUGH: I think this will work out fine, q 11. The thing we have to remember is to speak into the 12 microphone but not too close so that it can be transcribed, 13 'if you would, and I know that's going to take a little bit 14 of coordination, but I think if you just put the microphone N 15 over to whoever wants to speak, I think that will work out [d 16 -- work out fine. 17 Okay; we,did send around a handout from NEI on 18 individual discussion topics, so hopefully, you'll see that 19 come around, and if you don't see it, if we run out of 20 copies, let us know; we can make more. 21 All right; so, if you'll turn in your handouts -- 22 you can look in my handout if you like and go back to the 23-discussion topics, slides, or you can use your copy of the 24 Federal Register notice, whatever's easier for you. We'd 25 like to walk our way through, and just to make sure that we .r'] ANN RILEY & ASSOCIATES, LTD. ( f. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

p 57 1 have NEI and ASME, give them a chance to speak before we 2 q move on, we're going to try to have about 15 minutes per \\# 3 topic, but I think we'can go a.little bit long on that for l 4 these first five or so, because I think they cover a lot of 5 the real. meat of what we're trying to talk about today. The 6 latter five, some of them are repetitive, so we'll make sure 7 we spend adequate time on these first five. 8 What I will do for -- I'll let ASME and NEI have 9 the floor first, and we'll try to alternate back and forth 10 on that, and then, we'll kind of open it up for more broad 11 discussion from other individuals, and if you would, just 12 identify yourself when you speak so that the reporter can 13 make sure that's recorded. 14 Okay; let me wait just a minute for people to come 15 in. The people in the back, you'll have to remember that 16 you don't have a microphone, so you have to come up and 17 borrow somebody's if you want to t'alk on a subject. 18 Okay; the first topic that we are going to talk 19 about this morning is potential effect on safety, including 20 ' potential reductions in effectiveness of ASME boiler and 21 pressure vessel and O&M codes, and since NEI was so kind to 22 have a package for us, let's let them have the first word. 23 MR. COZENS: Let me just explain what we have 24 here. We have a task force on this 50.55(a) issue. 25 MR. SCARBOROUGH: Can you give your name, please, I I pg ANN RILEY & ASSOCIATES, LTD. i \\~/ Court Reporters S 1025 "nnecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034

r_ _ 58 1

when'you start?

f-~3 2 MR. COZENS: Excuse me; I am Kurt Cozens with NEI. s 1 \\I 3 I should know that by now. 4 [ Laughter.] 5 MR. COZENS: And we had looked at each one of 1 6 these issues and had an opportunity to put together our 7 thoughts based upon input from utilities, and that's what 8 you'll.see in this package. We have five different individuals from eight utilities who will indeed be speaking 9 10 on different items in this list. I think we have 11 information provided on nine out of the 10. 12 So let me just introduce each one who will be 13 speaking. We have Bill-Brice from Entergy here; excuse me 14 -- Jim Conner.from Florida Power and Light, Jim; Gene Miller 15 from Virginia Power -- Duke, excuse me; Alex McNeill from 16 Virginia Power; and Ben Montgomery from Calloway Company who 17 will be speaking on these topics. 18 So, having said that, are you ready to go into 19 item number one? Okay; Bill is going to speak for us on 20 that one. 21 MR. BRICE: I'm Bill Brice, and I'm on the NEI 22' task force, and I work for Entergy at Grand Gulf. I'm going 23 to talk about the safety aspects of this change. 24 I think it's fair to say that currently, we're .25 working under the assumption that newer is safer, and safer ANN RILEY & ASSOCIATES, LTD. (~). { Court Reporters g'- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034 i

1 59 1 is necessary. And I think that's a valid assumption from g-~) 2 the beginning until now, but I do think that we have to ~' ~ 3 consider the fact that incremental changes are accompanied 4 by additional burden. That's true for anything we do, 5 whether it's building a house or developing code process. 6 I think the question we have to ask ourselves is 7 .is the incremental change necessary, first, and is the 8 increased cost or burden commensurate with that burden or-9 with that change? A 10-year interval, I think the original 10. use of it was to define a time frame for controlling the 11 disbursement of examinations. What you had was a sampling 12 process that involved periodic examinations, and what we l 13 were trying to do was define a time frame for doing those 14 examinations and also to provide a limiting time frame for fT 15 completing all of the examinations. Updating to newer b 16 versions of the code'was later required by NRC. The 17 original purpose of Section 11 was to establish examination { 18 inspection requirements for pressure containing components 19 of light-water cooled and moderated nuclear power facilities 20 and also to provide for the general overall condition of the 21 safety-related pressure boundary. I think that's the key 22 point, and we need to remember that that's what the -- that 23. the general overall condition is what the intent of the code 24 process is. ~ 25 It's also -- all of these provide for the I ANN RILEY & ASSOCIATES, LTD. (ni '/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l L

60 1 protection and the public health and safety. p 2-The examination of various selection philosophies V' 3 that they used at the time or one of two: high service 4 factor. areas induced by operating conditions; for example, 5 vessel materials that were subject to high neutron flux 6_ might be an example of that, and representative sampling, 7 which was used to assess the overall general condition. 8 Originally, the construction code was used to evaluate 9 results or to effect repair and replacement, because those 10 had not been incorporated yet. 11-The original construction code, it turned out, was 12 not necessarily appropriate to address service-induced 13 degradation. So it became obvious that changes were needed 14-to adjust to the -- to expand the scope to the appropriate I 15 level; to evaluate examination results and to perform repair 16 and replacement. The evolution of Section 11 requirements 17 for mandatory updates were appropriate to implement-those 18 needed changes. 19 As the code matured, updates became less and less 20 necessary. Most of the significant changes occurred in the 21 1970s; for example, the addition of class two and three 22 components; pressure testing and pump and valve testing. 23 Today, current changes are not necessarily safety 24 influenced, and I think that's another key point. The 25 Section 11 code has become relatively mature, and if you l I ANN RILEY & ASSOCIATES, LTD. I V Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1

t 61 1 look at what changes are being made now, I think those ( 2 changes are focused on the elimination of unnecessary \\_, l 3 requirements and the introduction of new technologies. 4 These -- this is also a key point in that these will tell us 5 why the code process will continue to function as it does ) 6 now. 1 7 Examples of that would be if the repair and 8 replacement -- excuse me -- replacement and modification 9 subgroup recently prioritized their agenda items based on 10 industry importance. They based these on significance, 11 safety significance, economics or maintenance. Of the 174 12 agenda items, none were prioritized as important to safety; 13 rather, they were based on economics or maintenance. 14 And another example is that Grand Gulf evaluated () 15 some changes to go from the 1989 to the 1992 edition of the 16 code. We did this at the request of the NRC to help them 17 evaluate what the differences in the code was at the time. 18 We identified 184 changes. Seventy-seven turned'out to be 19 editorial; eight were errata; 22 reduced requirements; 25 20 increased requirements; and 52 were no change in 21' requirements. None of these were identified as safety 22 significant, and none addressed specific safety issues. 23 Safety issue resolution is achieved through other 24 means. The ASME consensus process is an engineering 25 evaluation; it's not designed for rapid resolution of (] ANN RILEY & ASSOCIATES, LTD. j Court Reporters ( 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L

F1 ' 1 62 1 emerging regulatory safety issues. This is due to the fact r'T 2 that you have multiple layers of review; it's dependent on '() 3 voluntary industry participation and requires separate 4 regulatory endorsement, and the code process is designed to 5 establish that base program we talked about earlier and to { 6 maintain the plant's. general overall condition. i 7. Safety issue resolution is done through the NRC 8 and industry. T' hey take these emerging issues, and they 9 handle them typically outside of the normal code process. i 10 We looked, and we looked at 25 generic letters as examples 11 of how these issues were addressed, and we found that none 12 of them initially addressed -- were initially addressed 13 through changes in code requirements. Examples of that 14 might be generic letter 8908, float edge corrosion; IGSCC or

[]-

15 BWSCC. !D 16 I think it's fairly clear that industry initiative 17 and regulatory actions are better vehicles for emerging 18 regulatory safety issues that require prompt action. This 19 way, you can handle the issue in a time frame that's 20 appropriate for its safety significance. 21 In conclusion, I'd like to say that there will not .22 be a negative impact on safety as a result of this change. 23 Safety issues will continue to be addressed through 24 aggressive industry and regulatory response as it's 25 currently done, and the role of the ASME must continue to l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L

w 63 -1 change to accommodate the industry. Section 11 will continue to refine and adjust processes based on industry 2 73 3 importance, which is what's occurring today, and the 4 regulators will continue to mandate safety significant 5 requirements through regulation as needed. 6 Thank you. 7 MR. SCARBOROUGH: Okay; thank you. 8-Would ASME=like to make some remarks on this? 9 MR. FERGUSON: When I'm done, Ray is going to make j l 10 a couple of comments, and in the spirit of. cooperation, Alex 11 is going to hold the mike so that -- 12 [ Laughter.) 13 MR. FERGUSON: A couple of comments that were just i 14 made, I happen to totally agree with, and maybe just the / 15 'last one, I would. pick up as-one of the more important is v 16 that as the industry matures, the ASME clearly has to learn 17 how to mature with the industry. When we initially wrote 18 many of these codes and standards, we used a shotgun 19-approach. We used the best information available for us at '20 the time, and we tried to cover the waterfront with our 21 codes and standards. And I'll give you an example: in the 22 IST area, where I used to work pretty extensively, we wrote 23 standards for issues that had already been uncovered. I 24 Generic Letter 9801 requires heat exchanger testing 25 methodologies. That's a very important issue that still 4 ANN RILEY e ASSOCIATES, LTD. Court Reporters \\ 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 (202) 842-0034 4 h__._.

i 64 1 follows on today. The issue was not solved with the initial ,-~g 2' blast of!the generic letter, and we're working now to come { 3 up with standards that give.you better ways to come up with 4 the important factors in heat' exchanger testings. That is 5 clearly a safety issue where we're going to make a safety 6 improvement. 7 It's similar with OM 8 on valves. So it's not as t 8 static as it seems, and I would have to say that what'we 9 don't know is what we don't know in this arena as well, 10 There will be new issues that will come up that will get 11 kicked off by quick generic actions and will be followed on 12 with the code committee activities, where everybody can 13 actually take benefit of the code committee activities. OM i 14 8 is a good example again; the risk based inspection is r~' 15 actually aimed in two directions: cost and safety. Do the N,)1 16 right inspections and test in the right place and do them on 17 the right equipment, saving exposure, saving time, saving 18 money and doing more focused inspections with the money you j 19 have left, with the resources you need. 20 So I'd have to say that there is a potential 21 impact on safety, because this 120-month update forces you 22 to go through your programs and look for items that you may 23 have potentially missed by the approach that maybe less 24 uniform, less organized as we go forward. I can't pick one l 25 item that won't be addressed, because I'm not sure we know ANN RILEY & ASSOCIATES, LTD. g Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014 x-Washington, D.C. 20036 (202) 842-0034 L

65 l 1 that item yet. l /~N 2 And that concludes my comments. I would mention N,. 3 just -- you know, I went through the code cases as well, and 4 we have a large number of code cases that have really looked 5 at how we do better evaluations of flaws. Fortunately, 6 maybe our original scatter approach is very good, but I 7 think there's still more work to be done. 8 Ray? 9 MR. WEST: I've got an ASME hat on now. 10 Augmented programs have their place, and they i 11 address the issues that come up in the industry today. The 12 code takes a look at those with regards to what gets done 13 under those programs and feeds it back into the process for 14 a level of minimum requirements that are needed for safety, ( }' 15 and a lot of times, changes aren't made, but I know that 16 there are changes underway now to consider thermal fatigue, 17 because I'm working on it. 18 And the minimum' requirements will be set for 19 public health and safety. Augmented programs usually have a 20 life to talk to BWR internal projects that the inspections 21 were done under BWRs were focused back into the code. A lot 22 of the issues that were identified there were corrected by 23 the industry, so there was no code change needed. There are 24 a lot of activities in the code right now that are reducing 25 requirements because of experience. All of the code rules l (~- ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 lL:

m j 66 f 1 were initially written based on fossil experience and i. ' (T. 2 petrochemical. They weren't written for nuclear. q,1 3 We've got 25 years of it now; we're working on it, 4 and we're trying to make those changes, but there are safety 5 things that come into the code, and there will be more 6 requirements, and I'm not sure how that's going to be 7' handled as those chango. 8 MR. SCARBOROUGH: Okay; thank you. 9 Go ahead. 10 MR. DEBONIS: My name is John DeBonis. I'm with 11 TU Electric at Comanche Peak, also representing Diablo 12 Canyon and STP as a resource-sharing type plan today. i 13 For item number one, the question is does the 14 elimination of the 120-month mandatory update tend to have a () 15 potential effect on safety? The mandatory 120-month update v 16 does not increase safety. Potentially, as discussed here, 17 reviews of a program uncover things within a program that 18 may be safety significant, but reviews of a program can 19 certainly be accomplished without a mandatory 120-month 20 update. Politics involved, I don't need a government 21 telling me that I need to review my program in order to get 22 my program reviewed. 23 As far as the effect -- the potential for reducing 24 the effectiveness of the ASME code, I think the ASME code is 25 an important process. The ASME code could be effective. t ) ANN RILEY & ASSOCIATES, LTD. q,) Court Reporters 1 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 t t

[ 67 The problem with the effectiveness of the ASME code right 1 .(~ 2 now is the approval process through the NRC. This was 3 discussed'previously; the NRC, I know, is addressing this. 4 There was a workshop in Chicago last October addressing some 5-of the areas to improve the approval process. If that 6 approval process was improved, then, the effectiveness of 7 the code would also be approved. Nothing in the elimination 8 of a mandatory 120-month update would prevent utilities from 9, being involved in the code process and adopting code 10 improvements. 11 That's my comment on_that one. 12 MR. SCARBOROUGH: Anyone else like to make 13 comments on this topic? 14 MR. HERMANN: Yes; I'm Bob Hermann, and again, I'm ~ ('T 15 also on the committee on repairs and replacements, and maybe \\_) 16 it's worth talking about some of the things that are in 17 later' code editions, and maybe the quality -- the ASME has 18 gone through and identified as changes as low economic, high i 19 economic, et cetera, et cetera. 20 Maybe it's worth talking about that a little bit, 21 though. Those changes maybe are low economic, high 22 economic, as they are in later editions, but some of the 23 things that get done in that area, like in the 24 repair / replacements area are temper bead, for instance, 25 repair rules for fixing, say, if you find a flaw in a j ANN RILEY & ASSOCIATES, LTD. (m') Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i

r I 68 1 reactor vessel, and you can't easily do a heat treatment. [] 2 These later temper bead rules could be looked at as an 'N J .3 economic benefit; they could be looked at as a relaxation. They also could be looked at as a realistic way to safely 4 5 fix a reactor vessel so you wouldn't fail it. 6 And those things have evolv2d, like vat overlays; 7 rules for mechanical tube plugging. Those are listed as low 8 economic or listed as economic changes, but clearly, they're 9 not without some safety implications. 10 MR. WHITMAN: I'm Keith Whitman. I participate 11 both in Section 3 and Section 11. 12 ' And I just want to point out that Section 11 of 13 the code goes well beyond ISI, okay? The focus here 14 primarily has been ISI, but in terms of flaw evaluation, 15 reactor vessel embrittlement, appendix G and appendix K, 16 other things that' relate to service or age-related 17 degradation, okay, are evolving. Very important, okay? One i 18 of the highest priority issues before this agency right now 19 is license renewel, and all of these things come into the 1 20 - picture in evaluating age-related degradation, so I just 21 want to point that out. 22 MR. SWANN: Tom, my only comment was this a 23 question. Is this workshop or is this forum an appropriate 24 place for just a straw man ballot? I mean, could you 25 actually just -- could you get a straw man ballot here of n ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 2 84 b34

69 1 the people involved and get-a count for those who think that 3 C]/ - 2. the 120-month mandatory update provides any safety f' ) 3 improvement? 4 MR. SCARBOROUGH: I have no problem with a show of 1 k 5 hands if that's what you want to'do. I don't think it's ) 6 very scientific but -- '7 MR. 3WANN: And I agree with you; it's-not. But I 8 think that,.you know, we're going around, and we're hearing 9 everybody give all these opinions and so forth, and we're ) 10 kind of getting back to everybody's still defending, you 11 know, certain positions and so forth, but you've got a good j 12 sampling of people here, and I'm just saying it's basic ~ 13 questions. So would it be appropriate just to get a straw 14 man -- /~N - '15 MR. SCARBOROUGH: I've heard some objections to d 16 that, so we won't be able to do it. Okay;.thank you~, 17 though. 18 I wonder if ASME would talk a little bit about the 19 second half of that sort of question in terms of the 20 potential reductions in effectiveness. You know, what's { l 21 your reaction in terms of effectiveness? Can you say a few 22. words about what's your reaction to that? 23 MR. FERGUSON: My name is John Ferguson; I'm 24-- sp'eaking for the ASME. 25 I mentioned earlier I think there could be some ,m-ANN RILEY & ASSOCIATES, LTD. -,) -Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

c f' V[ 70 'l impacts on the code, and I think they could be worth noting. r-) 2 One is by baselining the code, there would be little 3 incentive for utilities to provide resources, to provide -- l 4 to support the code revisions'. Now, I know some people have 5 given different opinions on that, but I have to say from 6 where I sit, within the ASME code and what the membership 7 talks to me about and what we hear, for those of us who are 8 managing code committees, we do hear that as a real concern. 9 And how that comes through is if we don't have the ability 10 to support the process, then, the ASME code will be a less 11 effective body to be able to do the types of things, and I mentioned this multiplier effect earlier. 12 13 I think that is a real and a valid concern. Can I 14 make accurate predictions on how that might happen? (} 15 Obviously not, because I do not know all the forces, and I .Li 16 couldn't project what all the utilities; and other people, 17 frankly, who support it. 18 So I think that there is an impact. I do believe 19 that, you know, we have an established infrastructure over 20 the years that's been written in a conservative manner, and 21 as we go forward, we need to be very good about changing. 22 'As I mentioned earlier, we need to make sure we make the 23 right changes in our code as we go for a more focused 24 approach. I 25 Alex, you have to get it closer to me. I ANN RILEY & ASSOCIATES, LTD. C-}s. Court Reporters 1025 Connecticut Avenue, NW. Suite 1014 Washington, D.C. 20036 (202) 842-0034 L 1

p 71 1 ! I think that frankly, there is a potential on the 2 ASME code clearly, and I think that probably how it will be i) s-3 manifested is through how the support for the code 4 ' committees is given, and I think this 120-month rule will 5-impact that. We've already seen that from the discussions l 6 that we've had at the code committees; this has already come 7 up. So there are different opinions by different utilities, 8 but I have to tell you what I see coming to me. 9 Thank you. 10 'MR. MONTGOMERY: My name is Ben Montgomery. I'm 11 the ISI engineer at Calloway Nuclear Plant. I want to speak 12 about the effectiveness of the ASME boiler pressure vessel 13 code. I attend the ASME meetings, and I think that they're 14 very important. I think they're critically important to the p-' 15 success of nuclear power, and I think my company feels that 16 way also. 17 But in these days of deregulation in the electric 18 power industry, more efficient practices by all the l 19 stakeholders are going to be essentially for the success of 20 nuclear power, and I think that's the one common denominator 21 we have in this room is that everybody here, I believe, is a i 22 believer in nuclear power. I've been in nuclear power my 23 entire adult life, starting with an enlistment in the Navy. 24 I think what we need to do now instead of talking

25. '

about'-- when they use the word baselining the code and ANN RILEY & ASSOCIATES, LTD. /^ k-Nl Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D C. 20036 (202) 842-0034

y 72 1 freezing.the code, I think that bothers people, but what I -('T 2 think we need to look for here is a way to revitalize the G/. ' l -3 ASME code, to breathe new life into it. If ASME is coming up with changes that don't significantly improve safety or 4 5 cut cost, you really have to-ask yourself why are we doing 6 it? 'If the changes do improve safety, then, we need to l 7 adopt those things because they're the right thing to do. 8~ If they do reduce cost or give cost benefit, then, you just 9 need to get out of the way, because the industry is going to i 10 adopt them. You don't need to mandate it. It's not 11 necessary to mandate, in today's environment, updating code i 12' to save costs, because trust me, the push is on to save 13 costs at the utility. 14 So in either case, the mandating of a 10-year (~')i 15 -update is really a deterministic and dogmatic approach, and 16 we need to look at that again. I personally would like to 17 .see the NRC come up with a way to adopt a code or accept a 18 code in a more timely manner so that you can use this ASME 19 code as a living document, and when changes are made to the 20. ASME code, they will be incremental, and incrementally, you 21 can improve your process. You can say we're coming out with 22 a 1999 code this year or the 2000 code this year; we can 23 look at the changes; we can make incremental changes in our 24 process, and we can stay into and up-to-date instead of 25 looking at something that's 10 or 12 or 15 years old or 1 p) ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 L

[L l-73 1 looking at a list of code cases, oh, we're finally going to 2 get to the 1995 code cases. 3 Well, there's 1998 code cases out there, and there 4. are 1999 code cases in process. You know, that length of 5 time to the table is unacceptable where I work, and I think 6 it's probably unacceptable where everybody else works, and i 7 that's my comment. 8 MR. BRICE: I'd just like to -- this is Bill Brice 9 again -- I would just like to add to what Ben had to say and i 10 maybe give an example. I talked about it a little bit 11-earlier that our plant upgraded, I guess, from the 1989 to 12 the 1992 and portions of 1993 addenda. I guess the reason 13 we did that was because the code was a better code, and I 14. think that demonstrates how ASME can continue to address and 15 how they.can~ meet utilities' needs and why utility 16 participation will continue, assuming that ASME can continue 17 to provide for the needs of utilities. 18 MR. MILLMAN: Gilbert Millman, NRC staff. 19 The 120-month update has a profound effect on the i 20 whole process. It affects NRC's implementation and ) 21 regulation of the licensees; it affects licensee 22 implementation of the code, and it affects ASME code's 23 development of the code, and I just want to address one of 24 those points, the effect it has on the ASME code in terms of 25 safety. There is one very good example of how important the g~g ANN RILEY & ASSOCIATES, LTD. f y' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

~ 74 1 120-month update is'in the context of the code addressing jg-2 issues that affect safety,' and that example is appendix 8, 1 '~' 3 which deals with performance demonstration associated with 4 ultrasonic examination. 5 Appendix 8 was incorporated into the code and the 6 1989. addenda after many years of development. It was 7 clearly at the' outset of the development going to be a very 8 expensive process, and it turned out to be over a $70 9 'million process. Every utility participated, contributed 10 money to performance demonstration initiative, PDI, to l 11 implement that process. Why did they do this? Why did the 12 code ever get started on this, and why did so many people 13 get involved in the development of appendix 8, because they 14 knew there was going to be mandated by the NRC. It was (} 15 suppcsed to have been mandated back in 1995, according to v 16 our normal regulatory turnover of that particular rule, but i 17 here we are in 1999, and it hasn't been mandated yet. 18 But at that time, in the 1991 time frame, it was 19 very clear that the code -- that this portion of the code ) 20 would be implemented, and that's the very reason that so 21 many people from utilities, NRC, participated in the 22 development of that mandatory appendix. If it had been 23 determined at that point, back in the 1987 time frame, that 24 this was going to be a non-mandatory appendix, it would 25 never have had the participation by national, international (S ANN RILEY & ASSOCIATES, LTD. l ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

P-1 75 1 .research and development participation, and we would not 2 have the product of appendix 8 that we have now, and that ,( 3' '.goes to other parts of the code as well, but:that is a prime 4 example of the impact _that a mandated code has on this 5 process. 6 MR. SCARBOROUGH: Okay; anyone else on this one? ) 7 We may move on. 8 Sorry; go ahead. 9 MR. SHAW: My name is Sherm Shaw from Southern 10 California Edison. I just have a question for Gil. There's i 11 a difference between being mandated by the NRC and the ) 12 120-day normal 10-year update. The 120-year update that 13 we're talking about today had nothing to do with my decision 14 as a utility to participate in PDI. Southern California I .. 15 Edison was probably the last utility in the bunch to sign up 16 for PDI, but we did it based upon it was the right thing to ] 17 do; it was going to be implemented; at least, back in the 18 ~ early nineties, we thought it was going to be implemented. 19 The.t may be in question today, but it didn't have anything 20 to do with the 10-year update. 21 Are you trying to make the -- I don't understand 22 the -- 23 MR. MILLMAN: Gilbert.Millman, NRC. 24 I suspect it did. If you were the last plant to 25 -sign up, if you didn't sign up, you were going to be on your l ANN RILEY &. ASSOCIATES, LTD. + U Court Reporters 4 1025 Connecticut Avenue, NW, Suite 1014 j Washington, D.C. 20036 (202) 842-0034 )

76-1 own'to implement it. I don't know how you would have done 2 that.. It was going to be mandated; Southern California ~' 3 would have been required to implement it, and how would you I 4; have done that without being part of PDI? 5 MR. SHAW: I agree with that question. I mean, 6 that was my question to my management when we' finally ended 7 up signing up for it or participating in it. We didn't know 8 how to do it independently. But that doesn't have any 9 relationship to the 120-day -- 120-month update to my 10 program, ISI program on the plant. 11 MR. MILLMAN: It nas everything to-do with why the 12 other utilities signed up, why anyone signed up to that 13 program. They knew it was going to be mandated, and they 14 couldn't do it themselves, and that's_why PDI was formed, to [ 15 create a cost-effective way of implementing this rule that 16 was determined by the code and everyone participating to be 17 a necessary new provision, because the in-service inspection .18 that was being performed could not see well enough to detect 19 indications that were important. 20 MR. WESSMAN: Dick Wessman from the staff. 21-At the risk of being in the midst of a 22 disagreement on both sides of me here, I think I would like 23 to point out that the original proposed rulemaking that went 24 out in 1997 did have, along with an extensive cost-benefit 25 analysis and a backfin analysis, the requirement to i l je's ANN RILEY & ASSOCIATES, LTD. (') Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

r 77 1 implement the appendix 8 initiative. So with or without 1 ~ 2 consideration of the elimination of the 120-month update, 3 that particular initiative was going to be required of the 4 industry as part of the NRC's rulemaking activity, and I 5 think that still stands in the way we are looking at that at 6 this time. 7 MR. MILLMAN: I have to respond to that. 8 At the time the appendix 8 was developed, we 9 ' weren' t talking expedited; we were talking the routine 10 < update. That became later on in,the -- turned out to be a 11 part of the later process, but in terms of it being -- in 12 terms of the development of appendix 8, it was strictly a 13 10-year update implementation. The expedited aspect was a 14 later regulatory issue. () 15 MR. SCARBOROUGH: Okay; one more. Go ahead. 16 MR. DEBONIS: John DeBonis. 17 Elimination of the mandatory 120-month update does - 18 not prohibit the NRC from mandating issues to utilities that 19 ~ are important to safety. 20 MR MILLMAN: We're talking about the effect of 21 the 120-month update on the ASME code development. If you 22 tell ASME that NRC might implement something that you're 23 endorsing, that's a totally different issue from knowing 24 that the NRC will implement what you're endorsing. It has a 25 profound effect on the development of the code. l l ANN RILEY & ASSOCIATES, LTD. s y) Court Reportera 1 1 1025 Connecticut Avenue, NW, Suite-1014 Washington, D.C. 20036 (202) 842-0034 )

I 78 l 1 MR. DEBONIS: I agree, and the NRC should ! -r) 2 certainly determine which areas they are going to mandate NJ 3 and let the code process those areas and not have them go off on things that'may or may not be mandated. 4 5 MR. MARION: Alex Marion, NEI. l l 6 Interesting discussion, but I find it kind of 7 troubling in that what you're saying, Gil, is that the NRC 8 drove the process through ASME, and I would suspect that the 9 professionals that we've heard from today who are 10 individually involved in the ASME code development process 11 might have some concerns and take issue with your 12 understanding of how appendix 8 was developed, with the 13 objective of NRC mandating it as a requirement and that if 14 NRC proceeds with a voluntary. approach to the 120-month O, ) 15 update requirement, then, that will affect negatively l 16' similar activities in the future. 17 Well, if that's indeed the case, then so be it, 18 because I'm firmly against organizations unduly influencing i 19 any standard development entity. 20 MR. MILLMAN: Alex, I'm afraid you inferred 21 totally incorrectly what I've said. NRC provided research l 22 information to the code that provided a basis for the 23 development of appendix 8; appendix 8 was developed strictly l 24 by the code, and it's a code product. 25 MR. FERGUSON: I would just like to make one l l (~3 ANN RILEY & ASSOCIATES, LTD. 1 (_,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

r I 79 1 comment. Again, one comment that I'm concerned about; I (~N 2 mean, we've agreed on a number of things here. One of the Q, 3 things, we talked about the update process about ASME. I 4 have not heard one difference at the table about that, that 5 that needs to be improved and made better, and that's-6 clearly a benefit. 7 One of the things that we have not agreed upon, 8 though, is if it's a voluntary update, it will be taken 9 versus if it's a mandatory update, what will happen, and I 10 would suggest that in the future environment, not the past, 11 the future, we're seeing a huge change in utilities. We 12 don't know who's going to own each other next month. We 13 don't know which management structure is going to be at 14 which utility with which idea next year, because plants are -[^) 15 fundamentally all going up for sale. \\J 16 But one constant that we do know in terms of ) 17 safety is that the ASME writes codes and standards that help 18 set the level of safety, and the NRC, with the 120-month j 19 update, gets these codes and standards implemented no matter 20 which management is there. And I think that's an important 21 feature as we go forward, because we're about safety. 22 As we go forward, if each code and case has to be 23 evaluated in terms of its cost-effectiveness by each 24 individual utility, I mean, that alone costs money, and I'm 25 not sure, as the utilities go through the significant f-'s ANN RILEY & ASSOCIATES, LTD. '(_ ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 L t

l 80 l 1-( pressure to reduce costs that that will be something that )<~s 2 they will'take on easily, because these are not easy issues ~ 3 l-to come out with the cost-benefit on in every case. I think ~4 that the 120-month update gives you a more uniform code 5 that's easier to update and allows -- prevents creating a 6 patchwork or a jungle of code cases that you're running your j 7 programs by. 8 So I suggest as we go to the future -- and again, L 9 I can't predict the future -- that the 120-month update 10 allow, along with standard processes of updating and l 11 creating codes that protect the level of safety, gives us a l i 12 good process as we go forward to this change that's 13 occurring. 14 MR. SCARBOROUGH: With that, I'm going to say just ! /'N-15 one thing that occurred to me. b - 16 I'll let you-have your word, but let's move on to i 17 the next item, and then, when it comes to be your turn, you .18 can add your point, okay? When it comes to be your turn on 19 that one. But I do want to make sure that we have time to i 20L cover what I consider to be the second most important of l 21-these, and that's why we spent more time on the first one, f 22 because obviously, it is the most important, because it has 23 an effect on safety. 24 The second one has to do with the selection of the 25 proper baseline edition and addenda of the ASME code in 7-sg ANN RILEY & ASSOCIATES, LTD. ( ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ( Washington, D.C. 20036 (202) 842-0034 I

p 81 1 terms of safety, resources and efficiency, and since we gave -f N 2 NEI'the first word on the last item, we'll let ASME have the 3 first word on this one. 4-MR. FERGUSON: Based on what we see right now, 5 we'd recommend that the proper baseline edition of the code ~ 6 in terms of safety, resources and efficiency be the one 4 7 proposed in the rule published on December 3, 1997. 8 Basically, we think it reflects.the latest edition to the 9 codes endorsed by NRC. It endorses up the current 10 -improvements in technology, including improvements on health 11 and safety. It picks up the lessons learned; as I mentioned 12 before, it's a more current, consistent, uniform standard. 13 It's updating the more recent codes to provide, as I said 14 earlier, cost-effective -- it also was the best code, we O 15 think, if it had to go forward. d,) 16 Thank you. 17 MR. COZENS: Just one quick bounce-back to item 18 number one, and that is we should never forget what the 19 title of this item one was, which was to deal with the l '20 impact on' safety, and I might note that in the presentation, 21 we mentioned a review and changes that concluded that the 22' impact on safety just didn't -- there were no items that i 23 were impacting on public health and safety and also that the 24 aspects of whether the NRC -- excuse me, the ASME codes and 25 some of the codes are characterizing the activities they're i ANN RILEY & ASSOCIATES, LTD. (n' ).- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 g

g-f l 82 1 changing that they have not -- are not directly impacting on l I je"g 2 safety.but more driven towards economics. i ~' 3 But that, now, I think we're probably ready to go 4 on to item two, which -- Jim? 5 MR. CONNER: I'm Jim Conner; I'm with Florida 6 Power and Light. 7 In essence, we would like to express some support 8 for the baseline code editions that were expressed in'the 9 supplement. Using the 1989 as the edition for most of the 10 ISI, we feel that the vast majority of the plants in the 11 country are already on 1989. There are only a few that 12 would need to change programs to do that. Using a separate 13 edition from that would incur additional expense, requiring 14 essentially another update for all those who are currently ' (~) 15 using 1989. L) 16 I-feel that staying with 1989 right now, most 17 people have their program pretty well settled. Even if 18 there are relief requests required to go with it, they have 19 a program in place. They understand what's required of 20 them, and it drives in a bit of consistency. 21 In terms of editions for IWE and IWL, 1992 is 22 currently endorsed, and we do have some folks who already 23 have their programs submitted using the 1992 edition. We 24 support,the use of the 1992 edition as a baseline, although l 25' we also recognize that there are a great many people who i i ANN RILEY & ASSOCIATES, LTD. g( 'f Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 L

r 83 1 would like to benefit from the 1998 edition and those () 2 improvements that are in the 1998 edition that make it much %J -3 easier to implement a set of rules. 4 Using the 1992 should be the baseline, but as we 5 discussed here, as part of the rulemaking, the later 6 editions of the code that are coming down the pike should 7 also be approved for use, allowing a utility to choose which 8-edition mtst suits their needs. 9 In terms of the appendix 8, the only caveat that 10 "we would add to that particular edition of the code is use 11 of the code case N622. That was discussed earlier; that 12 particular code case is the result of a great deal of effort 13 between the code committees and all those involved in order 14 to come up with a set of rules that are implementable and I [d \\ 15 think still meet the needs of those who are trying to ensure 16 that we have adequate ability to detect flaws. 17 So, as, _say, an amendment or a change to what's in 18 the proposed rule, we would recommend that consideration be 19 given to approving code case N622, 20 Thank you. 21 MR. SCARBOROUGH: Any other comments on this 22 particular item? 23 MR. DEBONIS: John DeBonis, TU Electric. 24 As it's been mentioned, many utilities are 25 currently at the 1989 edition. However, establishing the p ANN RILEY & ASSOCIATES, LTD. t,'~'/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

84 1 1989 edition as a baseline seems semi-arbitrary. It is the (~'N 2 last approved NRC version. However, other utilities are 3-working to NRC-approved programs that are written to code 4 editions earlier than the 1989. The same arguments for not 5 requiring update beycnd the 1989 baseline also apply to not 6 requiring update beyond the currently-approved ISI program 7 code of record. 8 The people who have an earlier code edition, it is i 9 recognized that the supplement will allow them 5 years to 10 get to the baseline. However, I expect most people are 11 going to be eventually going to a risk-informed type 12 program. This would require those utilities to update a 1 13 program twice, potentially, where other utilities would not 14 need to do that. () 15 Again, there are no safety significant issues, 16 say, in the 1986 edition that have been corrected by the 17 1989 edition or that have not been corrected by some sort of 18 NRC'rulemaking. 19 In regard to IWE and IWL, again, the -- as stated, 20 .the 1998 edition incorporates many improvements over the { 21 1992 edition and allows for a more cohesive program 22 development, implementation and enforcement by the NRC. 23 With regard to appendix 8, as stated for the rest of the ISI i 24 program, there is no technical basis to go beyond what is 25 currently approved in the licensee's ISI program code of rx ANN RILEY & ASSOCIATES, LTD. (,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F: 85 1 record. b,/~N 2 Appendix 8, although it does -- it increases the 3 ability to detect indications, whac has been demonstrated so 4 far is it actually increases the ability to detect 5 acceptable indications that require evaluation on critical 6 pr.th time and are very costly to work with during the outage 7 situation. 8 Again, requiring updates beyond the j 9 currently-approved ISI program does not seem to be based on I i 10 any safety significant issues. 11 MR. SCARBOROUGH: Just a point of clarification, 12 if you would. Are you proposing that it be frozen where the 13 licensees are now and don't go up to the 1989 and just 14 freeze them where they are now? () 15 MR. DEBONIS: Yes; allow the current ISI code of 16 record to be the baseline for that utility ~with voluntary 17' updates as discussed -- there is'no reason to go to the 18-1989, per se, versus the 1986 versus whatever other 19 currently ISI . 20 MR. SCARBOROUGH: Okay; thank you. 21 Yes, sir; could you come down to the mike? 22 - MR. HEDDEN: This is Owen Hedden. 23 I think I really have to respond to that, because i 24 there are a lot of subtle benefits in the later revisions to -25 the code since 1989, and one of the things that I'm ANN RILEY & ASSOCIATES, LTD. .) Court Reporters y 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

IE 86 surprised nobody has mentioned here is the effect on ALARA, 1 i (N 2 L that we have a lot of changes which affect the amount of G 3 time people are working inside the units, and it's not just in the examination methods where we have been eliminating 4 5 some examinations. Each time we do that, you have fewer man 6 hours in containment, and with the savings that -- and I 7 think that's a safety consideration. 8 In addition to that, in the repair-replacement 9 methods since 1989, we have a lot of methods that you 10 couldn't use before that let you get in and out of the hot 11 areas faster. We've got a lot of advanced methods that have 12 been brought in. Those contribute to reducing personnel 13 exposures, contribute to safety. 14 You forget about evaluation methods. We've added (' /r 15 a lot of evaluation methods for flaw evaluation since 1989. x_ 16 These mean that you can analyze a situation and not send 17 somebody in to do some repairs. You start adding these up. 18 I say these are subtle changes; you can't put a dollar sign 19 on each of these, but we have a whole series of things that 20 have evolved in the code that are going to increase safety, 21 reduce personnel exposure, and I guess they're pretty subtle 22 sometimes. 23 We're talking about appendix G changes: really 24 subtle little changes in appendix G which opens up your 25 operating window on heat-ups and cool-downs just a little I p< ANN RILEY & ASSOCIATES, LTD. ) ( Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F 87 1-bit, but it makes a difference. And the people who are r (^ 2 working on this say it doesn't look like much on the curves, (_-

3' but when you're operating the plant, it makes a significant 4

' difference, and_that's a safety consideration. 5 LThank you. _6 MR. SCARBOROUGH: Tom? 7 MR. HERMANN: Thank you. 8 .Yes, just a response to the earlier statement on ( 9 . code case N622. There were public comments on the rule 10 originally with regard to implementation of appendix 8, and 11' the revised rulemaking,.the rulemaking that was revised from 12 the original package recognized that there were problems in 13 the early implementation with appendix 8, and what's in the 14 current rulemaking package, there were industry meetings on () 15-this subject, and the current rulemaking package for 16 appendix 8 includes -- as a matter of fact,. it was probably 17 the driving force for code case N622. The things that are 18 in the rulemaking package, without calling it.N622, are ) 19 essentially code case N622. 20 MR. WESSMAN: I only want to make one observation, 21 which.is I don't want to go back to the 1997 rulemaking 22 package, because it isn't the subject at hand, and the staff 23 has not finished its decision process on that. Although 24 obviously, the interest in appendix 8 is intense, let's try 25 and bring ourselves back to the 120-month update issue that I r-ANN RILEY & ASSOCIATES, LTD. (S 1 Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

88 1 we're trying to work on today. I r~' 2 The only other addition I would make is we've had 'i ) ~ '" # 3 a lot of discussion on various safety and technical issues 4 or improvements that have come in the code, and some have 5 been subtle, and some have been, I think, very, very 6 important or very, very obvious, and Keith has talked about 7 flaw evaluation and some of these other things. 8 These technical improvements are still there and 9 are still available for use and could be voluntarily used by 10 licensees with or without a baseline. Go back to some of 11 the early remarks that I made and that Tom made of what this 12 120-month update elimination concept did do and didn't do. 13 It did offer a baseline, and we are just discussing what 14 might be the best baseline, but it also, regardless of the ~( '} 15 baseline, has always kept the concept of licensees can V 16 select later portions of the code if they come to the staff 17 or later code editions voluntarily in their entirety if they 18 so desire. 19 I don't want to lose sight in our concern over 20 many of the wonderful technical improvements that we are -- 21 somebody is thinking, oh, I can't use them anymore. Not the 22 case. They are there to use with certain rules on how you 23 go about using them. 24 MR. MAKINDRAKAR: Getting into this proposition 25 will not stop us to get any benefit from the recent 7. x ANN RILEY & ASSOCIATES, LTD. ( 4 Court Reporters k' 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

89 1 developments. Believe me, if there are any safety concerns 2 or anything, we will implement that. 3 It is not freezing, but getting into the baseline 4 edition has not stopped us from not doing that. That is not 5 the concept. We do evaluate the code and code cases 6 constantly. If it is a benefit to the plant or company or 7 anything, we will evaluate -- we do implement that, even if 8 it costs or anything, and just to make a comment that it 9 will not stop us. This particular proposed rule will not 10 stop us doing that. 11 This is definitely a benefit to us. 12 MR. SWANN: Dennis Swann, Southern Nuclear 13 Operating Company. 14 I'm also a member of the ASME OM code committee; 15 also a member of the boiling water reactor owners' group and 16 the boiling water reactor vessels internal project. Just 17 I'd like to tag along with what Mr. Wessman said. Dick very 18 well put I think that a lot of people here are losing 19 sight of the fact that we're just looking for a baseline 20 edition to bring everybody up to. We're not saying you 21 can't use things after that, and the rule package endorses 22 versions of the code way on past the 1989 version. 23 In response to what Mr. Hedden had to say, all of 24 your examples, Mr. Hedden, were basically economic. I think 25-we all agree that there have been subtle changes in not only i .p ANN RILEY & ASSOCIATES, LTD. Q ' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I 90 1 .the Section 11 code but the OM code. All have been i.[O 3 t 2 beneficial in ways of examining ALARA concerns and so forth, 3 but those are issues that the utilities should be able to 4 make based on economics. I don't think that there are all ,5 that many -- I think that we're all in agreement that there 6-have been no real safety significant changes in the code for 7 a number of years. 8 The majority of the safety issues within the 9 indusery have been handled independently from the code, and 10 the BWRVIP is a prime example of that. I think that it's 11 time that we all realized that adoption of a code and 12-elimination of-this 120-month mandatory update is not really 13 a safety benefit for safe operation of the plant, but we l 14 ought to let the licensees and utilities make the economic A(,) 15 decisions that are best for them. 16 MR. WHITMAN: Keith Whitman, NRC staff. l 17 I would take issue with your statement about lack 18 of safety issues being addressed in later editions of the 19 code. Appendices G and K, having to do with reactor vessel i 20 integrity, are very safety significant, okay? So is flaw 21 evaluation as far as I'm concerned. i 22 MR. SCARBOROUGH: Would ASME like to respond to 23 Mr. Swann's comment about the no significant safety 24 improvements? 25 MR. WEST: If you look at the rules for l [~N ANN RILEY & ASSOCIATES, LTD. ( Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

r 91 1 -containment, when I first started coming to ASME, I attended 2 the containment meetings. There was no interest by L3 utilities in those rules, and those rules were put into the '4 code.and were there since 1980. And until they were 5 mandated, utilities did not take action to make any changes 6 to'those rules, and without this mandate, when something new 7 comes up'that's going to require you to do more, you're not 8 going to -- it's not going to happen. 9 Now, we want to use the 1998 edition, because the 10 1998 edition has had all that input, but that would never be 11 there if it wasn't for a mandated requirement to use that 12 code. ( 13-MR. SCARBOROUGH: Earlier today, there was a 14 discussion between where they were showing some changes [ 15 between the 1989 and 1992. Has any work been done to take a ( I 16 look at, like, between 1989 and 1995? I know there is a j 17 comprehensive testing and that sort of thing that's in there 18-now, in the 1995 code. Has there ever been any work from 19 anyone to take a look at the change between those two 20 editions? 21 MR. FERGUSON: You're asking me if there's been 22 some work done to show the comparisons of what we've done in 23 each case. I do believe we have some information. I do not 24 have it with me. 25 MR. STENGER: Dan Stenger with Winston and Strawn; g ANN RILEY & ASSOCIATES, LTD. '"") Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l 92 just at the risk of making an obvious point, picking up on 1 1 I l (] 2 Mr. Swann's comment, if, in fact, there are safety V 3 significant changes to the code that produce a substantial increase in safety, your current proposal allows that to be 4 5 implemented. There's nothing in the supplemental proposed 6 rule that would prohibit that, in fact. You contemplate -- 7 you will evaluate such changes in accordance with the 8 back-fitting rule and adopt them if they pass the 9 substantial increase in safety and cost benefit tests. 10 So if there is something that is truly a 11 significant safety benefit that comes down the pike, that ) 12 can be implemented. Again, as Mr. Wessman pointed out, 13 we're sort of losing sight of the fact that there is plenty 3 of flexibility in this proposal that would allow such things 14 O 15 to come through. It's not going to freeze -- the O 16 supplemental proposed rule is not going to freeze those 17. things out. 18 MR. SCARBOROUGH: Tom? 19 MR. MILLMAN: In response to that point -- this is 20 Gilbert Milliman, NRC staff -- the back-fit test is a very 21 high hurdle to pass. The code deals with issues that can 22 pass the back-fit test, but they're infrequent. The 23 majority of the types of revisions that are incorporated 24 into the code are small revisions that cumulatively, over 25 one or two additions, have a significant effect. Those will ANN RILEY & ASSOCIATES, LTD. O j Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

g 93 1 be entirely lost in this process. l r"N 2 MR. COLACCINO: There is one, and we haven't N^-l 3 really been talking about in-service testing; that's fine. l 4 I think there are harder issues in ISI, but the pump testing 5 that's' incorporated in the 1995 code, it's euphemistically 6 called in the ASME as the comprehensive pump test, is, in 7 fact, a substantial improvement over what's required now. 8 The 1995 code will require, where practical, full or 9 substantial flow testing once every refueling outage, which 10 right now, all the requirements are is for testing at 11-whatever point the licensee chooses to test. 12 Those familiar with pump testing -- I know we have 13. Dennis here, who's a member of the working group know that 14 and should probably admit that little information, little if .f'} 15 any information can be gained about testing at 5 percent of v 16 design basis flow, which is in fact what we're finding at 17 some of the utilities in the country. 18 Thanks. 19 MR. SCARBOROUGH: Any more comments? 20 MR. STENGER: Dan Stenger again with Winston and 21 Strawn. I'm just not sure I agree with Mr. Millman's 22 comment. Those things would be lost. I don't think that 23 necessarily follows. I think there is flexibility in the 24 back-fitting rule to look at a number of changes 25 cumulatively together and decide whether they pass the l l l ANN RILEY & ASSOCIATES, LTD. f'(') Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F 94 1 cost-benefit test. The gentleman to your left, I'm sure, 2 f-) could give you some sound legal advice on that point. ' k_ / 3 [ Laughter.] 4 MR. MIZUNO: This is Geary Mizuno, NRC Office of 5 General Counsel. Although Mr. Stenger is correct, I believe 6 that industry in the past has' opposed the NRC combining 7 items to consider them cumulatively for their -- to meet the 8 substantial safety benefit test. :If the industry is going 9 to change'that position, that'would be welcome. 10 (Laughter.) 11 MR. HADDEN: I'd just like to respond again to the 12 comments on my comments on subtle changes and the cumulative 13 changes. There are 100 utilities that are each with their 14 own budget process, and if it's like the place I work, if /% 15 you go in with a small change, and you can't put a hard U 16 dollar item on it, you're not going to get it approved. I 17 think there's, you know, 100 little changes that we feel.are 18 going to benefit both safety and economically, but you're 19 not going to be able to get approved because you can't 20 quantify them. 21 .At this point, if we have to go in piecemeal, code 22 case by code case, appendix by appendix, the utility 23 management is not going to approve those changes if they're 24 not mandated. 25 MR. DUDLEY: Noel Dudley, ACRS staff. These i i 1 ANN RILEY & ASSOCIATES, LTD. f. ( Court Reporters N 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L

r-t 95 -1 comments are mine alone. ) l r~3 2 I'm somewhat surprised that the back fit issue is l b 3 coming up, because the change you're making to the rule is eliminating the requirement.of the 120-month update. That 4 i 5 was placed in the initial rules to assure adequate public 6 safety, with the understanding that the code would evolve, 7 would provide additional improvements to the processes and 8 that it would be required to be updated every 10 years for l 9 adequate safety to the general public. 10 What the staff is talking about right now is 11 removing that requirement, and it's a burden on the staff to 12 show how removal of that 120-month update is going to 13 provide additional safety. So the first thing the staff has 14 to prove is it's going to be safer for plan operations, and i [^1 15 I haven't heard from the discussion a clear case for that. \\v t i 16-Once you get past that screen, then, you talk 17 about cost-benefits. So -- and Geary, I think I may need 18 some help on this. 19 MR..SCARBOROUGH: Tom? 1 20 MR. STENGER: Dan Stenger with Winston and Strawn. 21 I don't think that's the proper interpretation of the back 22 fitting rule, with all due respect. If you're reducing a 23 requirement, that is not a back fit. You don't have to meet ~ 24 the standards for the back fitting rule. In addition, I 25 don't think when the automatic updating provision was put l I r"T ANN RILEY & ASSOCIATES, LTD. (,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 l^

) { 96 l l' into the rule that that was meant to be a blank check for ) \\. /^T '2 all time, that anything new that came out of the ASME code NY 3 could be adopted as a regulation. The commission doesn't 4 -issue blank checks, and those things need to be looked at. 5 MR. MIZUNO: I was hoping this was going to remain 6 on a technical basis as opposed'to a legal basis. 7 [ Laughter.] 8 MR. MIZUNO: I guess I would generally agree with 9 Dan Stenger with respect to the voluntary aspect of 10 relaxation of requirements with just the caveat that if that 11 only applies in a situation where a licensee can continue to 12 -meet the requirements of the relaxed -- the so-called 13 relaxed requirements of the rule without changing its 14 existing program, as opposed to a situation where there is a 15 relaxation, i.e., a reduction in cost or burden to the 16 licensee, but he ultimately ends up, to get there, having to 17 change his program or change his design in some fashion. In 18 that case, you would still have to evaluate it as a back 19 fi't. 20 I don't think that this particular rule proposal, i i 21 the supplementary rule proposal, actually falls into that i 22 category. So I don't think that a back fit analysis would 23 be necessary for this particular relaxation. 24 MR. SCARBOROUGH: Any more comments on this item? 25 MR. JANCLOVITZ: John Janclovitz from Three Mile ) Q ANN RILEY & ASSOCIATES, LTD. ' C/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l

I l 97 1 1 Island. ('"N 2 D. I just want to discuss the theme of not taking 3 advantage of future codes and future requirements. I think l J4 one of the examples we have where utilities are taking j 5-advantage lof future improvements in the code and technology, 6 even though we're not required, is appendix 8. Even though l 7 it's not required, there are a number of utilities, 8 including ours, that are right now using PDI qualified 9 people, even though it's more painful and more expensive. 10. We are using those people right now, and I think that's 11 generally true for a lot of the utilities. 12 So we are taking advantage of the improvements . 13 that are coming from the code, and I believe we will 14 continue to do that without being mandated to do it. () 15 MR. SCARBOROUGH: Any final comments on baseline? 16 [No response.) 17 MR. SCARBOROUGH: It's almost 12:00. Do you want ~18 to break for lunch now and be promptly back at 1:30, and 19 we'll start right at 1:30, so please be back, and then, 20 we'll move through the others more rapidly. 21 (Whereupon, at 11:58 a.m., the workshop was '22 recessed, to reconvene at 1:30 p.m., this same day.] 23 24 25 .[) ANN RILEY & ASSOCIATES, LTD. i,/ Court Reporters s 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

f. 98 1 AFTERNOON SESSION (} [1:33 p.m.] 2 3 MR. SCARBOROUGH: Good afternoon. 4 I think everybody's back, so why don't we go ahead 5-- and start? The next item, the next topic we want to discuss 6-this afternoon is the regulatory benefits or hardships to 7 licensees, industry suppliers, including vendors; nuclear 8 insurers; states; standards organizations and others, and I 9 think it's NEI's turn to start first. 10 MR. WESSMAN: Tom, before people start, let me 11 remind you all: a few of us may have changed positions, and ~ 12 we've got to take care of the court reporter. At least as 13 yna get started, introduce yourself and your organization 14 again as you make your first remarks. 15 Thanks. 16 MR. MILLER: I'm Gene Miller with' Duke Power 17 Company, and I'm here as a member of the NEI task force 1 18 responsible for developing positions on 50.55 (a) rulemaking. 19 I'm not going to speak to all of the organizations that are 20. listed there. We purposely decided not to address nuclear 21 insurers, states, or standards organizations, because we 22 felt like we would be speaking for others in that case, but i 23 in your handout, as licensee benefits, we see increased 24 regulatory stability, a reduced volume of changes that 25 licensees have to deal with, including reduced procedure l l /~ ANN RILEY & ASSOCIATES, LTD. k,h) Court Reporters s 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

r 99 revisions and less associated training for folks who carry 1 () 2 out ISI activities. It's a more stable environment. 3 More efficient and higher quality inspections; the 4 thought behind that is if things don't keep changing so 5 often, you can get better at what you do. Elimination of 6 ISI and IST relief request resubmittals; what we're talking 7 about there is each time you go in for a 10-year update, 8 you've got to ask the NRC for each and every one of those 9 relief requests to reevaluate, so they have to be 10 resubmitted. That volume would go away, and typically, 11 we're talking.20 to 30 of these relief requests per unit, 12 per plant. j 13 So that's from a licensee standpoint. From a 14 vendor standpoint, and the vendors we're addressing here are ,-(j 15 ' maintenance and. repair vendors, again, benefits; benefits in ) 16 reduced effort necessary on the part of the vendor to keep 17 up with the various code editions, and it's easier for them 18 to serve plant needs, because ASME code criteria is more 19 consistent. Another advantage, more consistency across the 20 industry, and with and by specific customers. So benefits 21 for vendors. 22 We see benefits for the NRC. Licensees, as we ~ 23 said earlier, will average 20 to 30 relief requests per 24 interval. That number would be eliminated. So across 100 25-plants, we're talking 2,000 to 3,000 relief request () ANN RILEY & ASSOCIATTS, LTD. i \\m / Court Reporters { 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

e 100 1 resubmittals associated with the 10-year updates. That's a .[ 2 significant reduction in NRC efforts, and we didn't fool 3 ourselves. We realized that, you know, we're not talking '4 about an end to all relief requests. Relief requests will 5 still be.the vehicle by.which licensees will ask for NRC 6 approval specific to some improvement 11n the code, and those 7. things will go on, but there will be significantly less 1 8 volume, both for the licensee and for the NRC in terms of 9 ~ relief requests. 10 And that's it. 11 MR. SCARBOROUGH: Thank you. 12 ASME? 13 MR. WEST: This is Ray West, ASME. 14 I guess my first question centers around your A) i 15 statement about vendors, and this will be easier for s 16 vendors. What I found is working in ISI and NDE is that 17 outside of the nuclear industry, vendors use the latest 18. codes, additions and addenda that are available. 19 Ninety-nine percent of their procedures are written for 20 that, and if there's any problem, it's trying to get them to 21 go back and rewrite it so they can meet an earlier edition l 22 of-the code than we have to work to. 23 So I think that, you know, the 10-year update at 24 least tries to close in that disparity. 25 As far as the numbers of relief requests, I think ( ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F 101 1 they're going to dramatically increase, because they're l-(m) 2 going to want to take advantage of the code cases and the i 3 things that ASME puts out that are beyond your baseline 4 additions that give you reduction, a burden reduction. When 5 you update to do a 120-month update, a lot of those code 6 cases have been incorporated into that later edition and t 7-addenda of the code that you don't need to write again. So 8 I disagree that you're going to have, you know, less with j 9 this action. 10 MR. FERGUSON: We did look at it a little bit in 11 another way.as well. Again, we're trying to project what 12 the future is-going to bring here, and again, that's not 13 always clear to everybody, but we looked at it in terms of 14 two ways. And the next two questions are almost the same in 4 ) 15 terms of the licensee, and we said, you know, we looked at 16 it in terms of the burden on the license if eliminated. You 17 know, there is clearly an administrative cost reduction 18 immediately if you did eliminate it. Clearly, the costing 19 of burdens, we feel, might probably increase due to the 20 updated, due to the relief requests, and again, backdating 21 to an older code and trying to make up for it by adding i 22 different requests. 23 We thought that the IST and ISI utility programs 24 might become'more of a patchwork of regulations than a nice, 25 consistent code that you would have. We looked at it the i r l [ l ANN RILEY & ASSOCIATES, LTD. \\- / j Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Wanhington, D.C. 20036 (202) 842-0034 l

r l-L 102 i 1 other way, too, and said what if we didn't eliminate it? > () 2 Well, the $200,000 or $300,000, whatever number you keep 1 3 remains. Every year, your self-assessment, some utilities 4 may do it; some may not. We've heard some excellent 5 comments here that take very proactive actions. 6 The latest ISI and IST operating experience and 7 technology will be implemented in the code if you determine 8-that you want to do it and your management agrees with you 9 to make that change. I think the process will be simplified 10 by going to a more standardized approach, and you'll get 11 more help on the generic issues, I believe, and you'll have 12 a higher confidence level in your ISI and IST program. But f 13 again, we're all projecting into the future here, and we're 14 all trying to guess what might -- based on our experience O t ! (,,) 15 what might happen. 16 So I think that's the best you can do with that 17 type'of question. 18 MR. SCARBOROUGH: Brent, would you like to add 19 anything from Illinois? -20' MR. METROW: Brent Metrow from the State of 21 Illinois, speaking for myself, however. 22 I mentioned before and others mentioned as well, 23 there are some states that automatically adopt new editions 24 and addenda as they come out, and in those cases, there l -25 could be a legal problem in state enforcement of a more f') ANN RILEY & ASSOCIATES, LTD. Court Reporters ss 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 L

( i l 103 1 recent code at thel time when a 10-year program would be / \\ 2 -V updated if there was no need_to address that from the NRC 3 view on behalf of the licensee. 4 That's all I wanted to say. 5 MR. MILLER: I. wanted to address -- this is Gene 6 Miller with Duke Power Company -- I wanted to address some 7 of the ASM,E comments, in particular the code editions that 8 'we. characterize as a benefit to vendors. We're addressing ~ 9 our comments specific to the rule making, and the rule 10 making isn't talking about any and all vendors; they're 11 talking about vendors associated with nuclear work; in 12 part'icular, ISI and IST and so forth, and, you know, 13 granted, there is' going to be a disparity as long as the 14 codes that are approved for nuclear work are significantly t 15-out of kilter with codes that are the absolute latest and b 16 greatest that are implemented in those areas that are not 17 nuclear. 18 And that disparity is going to continue to exist, 19 'whether the rule passes or not, because of the disparity in 20 getting approval to use those later editions of the code. ] 21-So I don't see that as a point affecting the rule at all, 22 and we're commenting on the rule. From the standpoint of 23 requests for relief, as I said earlier, we didn't fool 24 ourselves. We recognized up front that that is the vehicle I-25 by which utilities get NRC approval to use bits and pieces, 8 ' /N ANN RILEY & ASSOCIATES, LTD. N,) Court Reporters s l 1025 Connecticut Avenue, NW, Suite 1014 4 Washington, D.C. 20036 (202). 842-0034 L l t

n I' 104 1 and that's going to continue, but we don't see the level [) 2 changing. So we're still characterizing all of these as \\~/ 3 benefits for adopting the rule. 4 MR. SCARBOROUGH: Does anyone else have a comment 5 on this? 6 I have one question. Maybe someone can shed some 7 light on it, regarding the effect on nuclear insurers. Does 8 anyone have.any sort'of viewpoint on that,'how it might 9 affect them? 10 MR. FERGUSON: I can offer one opinion, and that 11 is I have heard a concern expressed that if we have various 12 different levels of codes out there, it will require the 13 nuclear insurers to be dealing with different sets of rules 14 at different times, and it seems like that may be an O ( ) 15 appropriate comment -- more rules to deal with, I should 16 say. 17 MR. COZENS: This is Kurt Cozens from NEI. j 18 I'm a bit puzzled by the discussion of this 19 overall concern for varying editions of the code being out 20 there on the street, because right now, there are multiple 21 editions of the code for different licensees; has been for 22 some time Over a 10-year interval, you will indeed find 23 different editions of the code out there. Matter of fact, l 24 it would probably.be a much more extreme case of having a 25 variety of codes out'there right now if the latest and ['i ANN RILEY & ASSOCIATES, LTD. (m,/ Court Reporters i l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l

C 105 1 greatest to the latest edition of the ASME code was ( )i 2 available for licensees to update to. 3 . So, say realizing that in a 10-year period, the 4 ASME code updates 10 times. Therefore, there would be a 1 5' . possibility of 10 percent of the industry adopting a 6 particular edition of the ASME code, and then, you would 7 have. effectively a variety of 10 different types of base 8 editions that various' licensees had used. That's one h 9 comment that we ought to be putting in perspective. This is 10 not a new phenomenon to have a variety of code requirements 11 out there at any given time. It's a fact. It happens now; 12 it will happen in the future. 13 MR. SCARBOROUGH: In terms of the nuclear 14 insurers, in terms of your contact,'your interactions () 15 speaking to everyone here with the nuclear insurers, do you 16 know if the nuclear insurers are aware of this proposed rule 17 change from your interactions? Do you have any feedback on 18 that? 19 MR. COZENS: Just answering a question, our 20 nuclear insurer is. Hartford Mann; Howard Potter is our ANI, j 21 and he is aware of this rulemaking and is conversant on it, 22 so -- because I have_ talked to him about it at length. I 23 MR. SCARBOROUGH: Actually, we would like to have 24 information on that as far as public comments, if they would 25 choose so to send in a public comment letter; that would be 'O ANN RILEY & ASSOCIATES, LTD. (m / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I l; 106 1 very helpful. Could you pass that along to him? ,( )' 2 Okay; no other comments? .Oh, down here. Go 3 ahead. 4 MR. HERMANN: Yes; this is Bob Hermann of staff. 5 I don't think that the authorized nuclear i 6 inspection agencies are what he was talking about. I think 7 he'was talking about like American Nuclear Insurers. 8 MR. SCARBOROUGH: Any other comments on this 9 question, on this topic? 10 (No response.] 11 MR. SCARBOROUGH: Okay; all right. { 12 Then, let's go on to the next one. This is topic 13 number four, the reduction in burden on licensees to not 14 update their ISI and IST programs and related procedures. (Q,; 15 And I think -- does ASME have the first go at this one? 16 MR. FERGUSON: Yes; I think -- let me grab this so 17 I can get it closer; thank you. 18 I think we pretty much tried to address these two 19 together when I made my discussion on the last one, where I 20 showed -- tried to show a balanced view of if eliminated and 21 if not eliminated, how the difference would look. My 22 comments included this question when I made those comments. 23 MR. SCARBOROUGH: Okay; thanks. l-24 NEI? 25-MR. BRICE: Yes; I'd like to give you -- this is l /~'h ANN RILEY & ASSOCIATES, LTD. \\ms/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034

\\ l 107 Bill Brice with the NEI task force; I work for Entergy at 1 .-m. I )i 2 Grand Gulf. L 3 I'd like to explain -- I've tried to give you an 4-estimate of what it cost us to do our update. I'd like to 5 explain a little bit on the front end. I did it -- I had 6 -some numbers that we had previously come up with as an 7 estimate, but I had no basis for those numbers, so I decided 8 to call'the appropriate people in my organization and try to 9 get real numbers from them or at least hours and convert 10 them, and so, we had -- because of our CBLA item and certain -11 things associated with that, we had to do our update in a' 12 pretty fast manner, and therefore, our cost may have been a 13 lit'tle inflated because of that. 14 But anyway, given that, I'll try to get through () 15 this pretty quickly. The IST program cost for the program 16 development ended up being~in the neighborhood of $248,800, 17 and this is just to develop the program. This was done by a 18 contractor in our case because of the expedited need to { 19 complete our programs. After we did this, because it's IST, 20: you have to go to the system engineering review, which 21 basically verifies that your design basis and your tech 22 specs and everything else that goes along into 23 characterizing the safety function of each item is, in fact, i 24 correct was done at a cost of $268,720. 25 After that, it goes to the plant engineering i l' $ - ANN RILEY & ASSOCIATES, LTD. \\%/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i l

108 1 group, who ha's to revise the test procedures and provides [V3 =2 the base IST document. Their cost turned out to be 3 $164,800. 4-I called our operations people. They,'because it 5 was expedited, had to put two people on it for a specific 6 period of t'ime, and their estimate or actually their total 7 hours turned out to be, at $80 an hour, S229,120. 8 The total cost, when you include the NRC review of 9 relief requests, which was in the neighborhood of $50,000, 1.0 turned out to be $961,440. That may be inflated a little 11 bit, given that I used contractor dollars in all cases, and .12 for in-house work, that would be reduced somewhat. On the ' 13 ~ other hand,~I didn't include things such as quality, 14 licensings and things like that. 15 The other programs, _ISI, for example, would 16 probably be much less in cost, because they don't have to go 17 out and characterize the hardware. Basically, you're 18 dealing with pipes and weld seams. So the estimate for that 19 was from a range of $200,000 to $500,000 a unit. These 20 numbers are from the NEI group and trying to find estimates 21 from various utilities. 22 The IWE and IWL. updates, I don't think anybody has 23 done one, but we do think, because it's less prescriptive, 24 and there's-less chance of things like boundary changes, the 25 cost for that would run maybe from $50,000 to $100,000 per

(N

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l 109 11 unit. When you add'all'this up, you end up with IST program 2 -costs anywhere from $300,000 to $950,000; ISI program 3 anywhere from $200,000 to $500,000, and IWE/IWL anywhere 4 from $50,000 to $100,000, which totals.to $550,000 to 5 $1,550,000 per unit, with a total industry cost of somewhere 6 between_$55 million to $155 million. 7 MR. SCARBOROUGH: That's all? Okay. 8 MR. FLANAGAN: Bob Flanagan, with Northeast 9 Utilities. 10 I just have a question for the previous speaker. 11 Were those costs segregated such that those items that were 12 in the best interests, the ones we keep hearing everybody's 13; going to do anyways, were taken out, and those were only.the 14 costs that you would have incurred solely for updating, not n 15 including what you would have done anyway? (} 16 MR. BRICE: These costs were what it cost us to do 17 the update. 18 MR. FLANAGAN: Including what you would have done 19 anyway. 20 MR. BRICE: That is correct. 21 MR. ROBERTS: Hi, my name is Tom Roberts. I'm 22 with the Public' Service Electric and Gas, but I'm really 23 speaking for myself. 24 I've listened most of the morning, and I actually '25 had personally not_taken a position either way, but what I ("~'N ANN RILEY & ASSOCIATES, LTD. () Court Reporters 1025 Connecticut Avenue, NW, : Suite 1014 Washington, D.C. 20036 (202) 842-0034

h 110 l l-1- find interesting, particularly with this last presentation, ('^) ' 2 is that we are going from a state of known to a state of v '3-unknown, but we're.not drawing any comparison to what the 4 cost might be, and I think it's probably meaningless to l .5 present figures in a steady state condition right now l 6 without duly taking into account what the costs may turn out 7 to be due to the process change. 8 I'm not advocating.that the proposed rulemaking is 9 good or bad, but rather, there are some inherent costs which 10 don't seem to be well-characterized at the moment. For 11 example, we've spoken about utilities having a baseline 12 program to the 1989 edition. I would dare to venture that 13 there's probably_no utility in the United States that has a 14 1989 edition program. They've all virtually taken advantage \\-)i l 15 of code cases and will continue to do so; will take 1 16 advantage of relief requests and will continue to do so, and 17 those costs have to be essentially backed out. So I don't 18-question that these are probably industry average numbers, 19 but'I think it goes along with the individual who just made I 20 the question: what is the cost in terms of future if the 21 rulemaking were to go through as proposed? And all those 22 have to be taken out of the equation, because if one is to 23 believe'that utilities will do the right thing, because it l 24 makes sense; it's in the best interests of dose saving, 25 labor reduction, et cetera, then these costs, I'm not sure, I 1/y ANN RILEY & ASSOCIATES, LTD. (s,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l

g 111 1 are truly characteristic, because I know that we do things - (~'I 2 continually over the course of a 10-year period, and the '\\-) 3 cost of the update is really almost an administrative burden, because by the time you get to the 10-year, you've s 5 gotten virtually a dozen different code cases, a dozen 6 different relief requests, which we've all heard this 7 morning, and it's basically just a matter of collecting it 8 all together and starting a new benchmark. 9 Thank you. 10 MR. SCARBOROUGH: Can the NEI provide any response 11 to that, in terms of how you would want to characterize 12 that? Do you have a way to kind of characterize that? 13 MR. MARION: Yes, Alex Marion, NEI. 14 We always get into these kinds of discussions when /~'T-15 D we have a meeting with the NRC and discuss the burden or the 16 financial impact of a regulatory activity, and what we've 17 tried to do in the past, and we can say we're reasonably 18 consistent, as in this particular case, is call the 19 utilities involved in our effort and have them give us their 20 best estimate of the cost associated with implementing the 21 rule change, and mere importantly, the cost material that 22 was provided deals with the particular question at hand, 23 which is question number four. 24 MR. SCARBOROUGH: Okay; any other comments on -- 25 yes, go ahead, (p) Court Reporters ANN RILEY & ASSOCIATES, LTD. 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i

112 1 MR. WEST: Ray West, ASME. f~'N 2 The cost.that you have there for your IST program 3 update, what was that update to? Was that strictly what's 4 referenced in the 1989 edition, or did you go beyond that? 5 MR. BRICE: In the ISI program, we went beyond 6 that. In the IST program, we went to the 1989 edition. So 7 I think -- and like I say, a lot of these costs, for 8 example, the relief request costs are, in some cases, asking 9 for relief for something that we already had relief to in 10 the earlier programs. 11 But to answer your question, the 1989. 12 MR WEST: So the IST was strictly 1989. 13 MR. BRICE: That is correct. 14 MR. WEST: You didn't go O&M. f 15 MR. BRICE: That is correct. L 16 MR. WEST: Thank you. 17 MR. SCARBOROUGH: Yes; I guess my comment is these 18 numbers are just quite a bit higher than the numbers we 19 referenced and stated in our Federal Register notice, and 20 I'm just trying to rationalize in my own mind how we so 21 underestimated the cost if these are more realistic costs. 22 MR. BRICE: Well, I was a little surprised at the 23 number myself. I didn't go out looking for a number. I 24 simply didn't have any faith in the number that I had from 25 my earlier estimate. So I decided I wanted a little basis ANN RILEY & ASSOCIATES, LTD. Court Reporters s_ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F 113 1 so that when I came up here to talk about it, I'd have ' (~'T 2 something that I thought was realistic. 'w) 3. When I called these guys, I questioned -- I called 4 most of them back-when I got my final answer because it was 5 so much higher than what I had anticipated, but I do think 6 it's in the proper frame of reference, and like I say, I was 7 a little surprised at it myself, but I went back and talked 8 to some people again; got the hours. It's not an exact 9, thing. It's just my best guess at this -- I mean, it's 10 based on actual hours for the most part. 11 MR. MARION: I'd like to answer your question, 12 Callaway-specific. 13 When they asked us to estimate how much we spent 14 on the ISI program, it was worded that way to me. And so, I 4 /3 i%s) 15 cent in the answer to Kurt here, and the answer I gave him 16 was how much it cost the last time we updated the ISI 17 program alone. I didn't include the IST program; I didn't 18 include the'others, and I sent him a figure.-- it was right i . 19 out of our budget of I think $270,000 for just the ISI 20 program updating to the 1989 edition. I didn't even 21 consider until I came here yesterday the IST program, IWE 22 and IWL. Our IST program was updated in -- pretty much in 23 house, and so was our IWE and IWL programs. 24 So that might explain some of the disparity. I i 25 think that you've got very' tight numbers. These numbers, as [~% . ANN RILEY & ASSOCIATES, LTD. i s,1 Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014 ) Washington, D.C. 20036 l (202) 842-0034 1

p 1 114 1 he stated, they shocked me. I'm not sure that they're not N]J /~ 2. inflated somewhat. But on the other hand, as was stated, 3 there were other things they-could have pulled in to make. 4 these numbers even more unbelievable; for example, QA hours ) 5 to perform QA audits; the amount of time that was spent by l 6 the licensing department to submit all these things; A&I 7 oversight of the process. 8 So, I don't think these numbers are all from an 9 order of magnitude is the point I'm trying to make. 10 MR. SCARBOROUGH: Thank you. 11 Any other -- 12 MR. MAKINDRAKAR: I found the same thing. These 13 are not out of the line. They do cost quite a bit to 14 update. They do cost quite a bit. There are several O 15 engineering organizations involved, NIs and the QAs and all +V 16 that. It has to go through all that procedure, the process, 17 and that is quite a time-consuming and very costly -- there 18 are a lot of costs in it. l 19 MR. SCARBOROUGH Thank you. 20 Go ahead. 21 MR. WESSMAN: Dick Wessman from the staff again. l 22 I guess I sort of want to ask maybe a little favor 23 of NEI and some of the utilities present as we look at this 24 cost aspect here. You may recall that at the very start of 25 the SECY paper that forwarded to the commission and some of O) ANN RILEY & ASSOCIATES, LTD. I ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 washington, D.C. 20036 (202) 842-0034 i z--

L 115 our opening-remarks dealt with the issue of-eliminating an 1-(g 2'

unnecessary. regulatory burden, and we're doing some l

3 struggling with information that we are very dependent on l .4 you all to help provide, and some material has been 5 presented today that deals with costs of updating an ISI/IST 6 program, and we've discussed those numbers a little, and 1 7 yet, I ask can we look into what I'll almost call the 8 hypothetical, because let's take the hypothetical of if the 9 120-month update requirement is eliminated, but utilities 10 still have certain activities that go on relating to code 11 activities, they are, as people have expressed earlier, 12 likely to incorporate and add into their programs ~ 13 voluntarily many of_the provisions and things and technical 14 advances and train people and this sort of thing. f~'t 15' So, as they go forward, some of the things that U 16 are part of the 120-month update, they are going to be 17 incurring as they go forward. I've heard speculation from 18 members on the staff that we'll be faced with a lot of 19 relief requests as we go forward. It's hard to know. I l 20 don't have the crystal ball, but if there are a lot of 21 relief requests as we go forward, those are costs if we go 22 down the path of eliminating the 120-month update. 23 What I'm really searching for is more pro and con, 24 more situational analysis on the burden that may still 25 exist, depending on the path taken; the burden that may be 1 s ANN RILEY & ASSOCIATES, LTD. I () Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L

L l-116 1 saved,' depending'on the path taken. But we need this help, ,/} 2 and I think we don't have it all'yet just from the handout \\,,r' 3-and the brief discussion.we've'had. 4-So when it comes time for written comments, any 5 work.in this area that you can do to help us I think would 6 be very. valuable. 7' MR. MARION: This'is Alex Marion. 8 Dick, we'll do the best that we can with the time i 9 frame'that we have to make comments. 1 10 MR. SWANN: This is Dennis Swann with Southern 11

Nuclear, i

12 Dick, I think you just hit the nail on the head. 13 I think what we're all realizing is that a lot of the j 14 development of an ISI and IST program update, if you go look . I~ ) - 15 at the regulations, the only thing that the NRC is required ' LJ. 16 to review and approve are the relief requests. But if you ~ 17 go follow the guidance provided by the NRC for what they 1 18 would like to see in a program submittal, it's a fairly long 19 list. 20 You know, they want the licensee to prepare copies 21 of drawings and design bases; they recommend the development 22 of a basis document for IST now. So you get into some costs 23 for later updates and so forth that perhaps plants have not 24 experienced before. 25 Another thing I'd like to mention is that a lot of r"'s ANN RILEY & ASSOCIATES, LTD. (_') Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

117 1 the - 'the relief requests that you're going to have for the () 2 IST component that you just cannot test in accordance with \\J 3 the code is going to exist no matter what, and the ISI 4 relief. request for the component that you can't examine to 5 meet the coverage requirements and so forth is going to 6 remain no matter what. And all the other relief requests 7 where people are developing to take advantage of later 8 editions of the code or improvements in the code, it appears 9 that the best' way to spend the money would be to allow the 10 NRC personnel to review the later editions of the code as 11 ' opposed to reviewing licensees' updates to where there would 12 be a much quicker vehicle for application of these later 13 codes without having to write relief requests to use a code 14 case, because it hasn't been incorporated into the 15 regulations. 16 It's -- you know, I hate to say it, but, you know, 17 we're talking an awful lot about economic considerations and 18 so forth, and I think we all came here to talk about whether j 19 or not this is the proper thing to do as far as maintaining 20 safety of the plants. 21 MR. COZENS: This is Kurt Cozens. Just as a 22 clarification, the costs that are in this presentation do 23 not reflect the costs of relief requests to code cases that 24 occur as interim edition in between 10-year updates. That's 25 mainly in place because that's the only way that the code j ('~)T ANN RILEY & ASSOCIATES, LTD. t,, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l 118 1 case could be used. i () 2 So those are the type of things that the licensees 3 are typically wanting to impose on themselves and take a 4 commitment to, because there is a benefit to it, but those 5 are not incorporated in this particular set of costs. 6 MR, SCARBOROUGH: Why don't we move on? 7 Okay; the next topic is essential effect on the 8 reduction in the number of licensee submittals; for example, 9 relief requests associated with ISI and IST programs, and I 10 believe NEI has the first shot this time. 11 MR. MILLER: I'm Gene Miller from Duke Power 12 Company, and to some degree, you're going to hear some of i 13 the.same things we talked about in item three, and the 14 reason for that is that potential effect on reduction in () 15 number of licensee submittals, that is, relief requests, 16 were one of the primary benefits that we saw in item three. 17 In the handout, we had said earlier that our view is that 18 there will be a net reduction of 2,000 to 3,000 relief 19 request resubmittals I guess you'd say every 10 years, 20 because those are associated with the 10-year update. 21 Program efforts on the part of licensees will be 22 aimed at selective improvements, and those efforts will not 23 include these repetitive relief requests. So that's a very 24 tangible and quantifiable number that we see as a reduction 25 in~these submittals. N ANN RILEY & ASSOCIATES, LTD. s-) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I!- 119 l 1 We also anticipate that licensees, as I said I '\\ [b 2 earlier, will continue to submit relief requests to 3 selectively adopt new ASME code criteria. We also 4 anticipate that the lag time for the NRC to adopt new ASME 5 code editions, addenda and code cases to be the same as it 6 was before the rulemaking. Clearly, an expedited NRC-7 process to adopt these new editions, addenda and code cases 8 is needed. 9 There is a cost-benefit, again, to licensees of 10 selectively adopting portions of the code rather than the 11-entire code edition or addendum. So we've got, in our list 12 of items here, a proposal. We propose that the NRC should 13 consider letting licencees selectively adopt portions of 14 later editions of the code without a relief request.

And,

() 15 of course, we're talking about approved code editions. The 16 precedent has been set in 10 CFR 50.55 (a) (f) (4) (4) and new 17 reg 1482, and we've got a paraphrase out of that here. It 18 allows that portions of editions or addenda may be used if 19 all related requirements for that portion of the respective 20 edition or addenda are met. 21 MR. SCARBOROUGH: Okay; thank you. 22 ASME? 23 MR. FERGUSON: I think we've covered this topic, 24 again, pretty thoroughly in the past, so again, as I 25 mentioned before, we're projecting into the future. It's /'N ANN RILEY & ASSOCIATES, LTD. (s,) Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

p 120 1-our judgment at this point that we would see an increase in 8) 2 submittals and actions with the NRC. We do agree -- at ,-\\J 3 least I do agree -- that it would be good if we could get li more timely approval of the work that we did. I think that 5 has been a common theme throughout, and I have to totally 6 agree with that, without reservation, and that would help in 7 a lot of arenas here. 8 I think, based on what I said before, I think that 9 we just say that we think it will become more of a patchwork 10 of regulations as you go forward. 11 Thank you. 12 MR. SCARBOROUGH: Okay; any other comments on this 1 .13 ' one? 14 Yes, go ahead. [J) 15 MR. HOLSTON: I'm Bill Holston from Baltimore Gas N, 16 and Electric, and carrying on for part of the discussion 17 there about selectively adopting, one thing I did not see 18 addressed in the proposed rulemaking, and we've touched on 19 it before, is the repair and replacements modifications 20 arena of Section 11, and in fact, I happen to be the { 21 chairman of that subgroup, that committee. 22 And I believe very strongly that if we go to a 23 baseline of the 1989 code, first place, you take one of the 24 largest financial hits we've probably done in a long time in l 25 .the code, and that's the elimination of the one-inch and I i /~N ANN RILEY & ASSOCIATES, LTD. ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i L

Fj; 121 1 under exemption, which principally affects pressurized water [^)h ' 1 - 2 reactors, not so much boiling water reactors, but we l t l l 3 narrowly reduced the scope of the one-inch and under 4 exemption because we adopted principally the 50.55(a) rules, 5 which say you cannot use the one-inch and under exemption ] 6 unless the leak rate out of your break would be less than 7 your charging capacity. 8 And again, so BWRs, it probably doesn't hit a lot, k 9 but PWRs, it has. Since 1989, we've done a lot of 10 improvements in the area 4,000 that would significantly 11 reduce costs with no corresponding reduction in safety for j 12 the utilities. Areas, for instance, we adopted a code case 13 for cure in place piping; to repair underwater salt water 14 ' lines. We've done a code case for engineered clamps that's () 15 been introduced in the code, and I'm sure all the utility ) 16 reps around this table have had cases where they've had to 17-do leak repairs of that nature. Now, it's a code process. 18 We've developed reconciliation rules that not only 19 allow you to use later editions and addenda of the code; 20 they allow you to use earlier editions and addenda to the 21 code. They've greatly reduced the scope of the engineering 22 -process required in reconciliations, and so, there's been a 23 lot of really good enhancements. I would predict possibly 24' within the next year or two that we're going to be issuing 25 new rules on procurement that would make for Section 3 l. (~] - ANN RILEY & ASSOCIATES, LTD. A,) Court Reporters ~ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i-y

e, 122 plants a significant reduction in the cost of them obtaining 1 f3 2 -material. V 3 And none of these changes are related to the ISI 4 rules and the IST rules of Section'11. So I would really 5 like to see added to this effort rather than forcing 6 utilities to adopt all of the provisions of a later edition 7 and addenda that if the NRC can review IWA 4,000, which is 8 where all the replacement and the repair rules are now, as a 9 . complete set of rules and allow that adoption to go forward 10 as the NRC reviews those editions and addenda 4,000. 11 MR. SCARBOROUGH: Thank you. 12 MR. HERMANN: Bob Hermann of the staff. 13 I agree with Bill that there have been a lot of 14 changes in RR&M. Maybe'one of the things, though, that i (m) 15 isn't reflected in the cost data are the kind of things that s_ 16 Bill is talking about. If you're going to do a cost-benefit j 17 analysis, and you're going to adopt costs for adopting later 18 editions of the code, you probably need to address those ,19 things that are pluses as well as minuses. 20 And if there is relaxations in the later code 21 editions, then, they ought to be reflected in the cost data, \\ 22 and I think it would be incumbent upon the industry if they 23 want to take that kind of approach to provide relative cost 24 data. 25 MR. MARION: I appreciate this discussion on the j l p(_) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 L.

c - l 123 1 costs associated with these' updates, the voluntary ones, the f; 2 involuntary ones, the nice to have ones and the ones you 1 'w/ 3 just think about. l 4 But fundamentally, let's not. lose sight of the 5 regulatory process in terms of safety significance of these 6 updates. Thank you. 7 MR. FERGUSON: Thanks for the comment, Alex. 8 You know, I didn't entertain being a part of this 9 conversation, because frankly, we don't have that cost data F '0 in the ASME. It's not the type of thing that we frankly 1 11 deal with. We're trying to think of what's the right thing 12 to do, how to do the right program, how to come up with the 13 right inspection or testing criteria. So in some respects, 1 14 we're blind to this. I have to be straightforward, because { () 15 our focus is clearly what's the right thing to do for 16 safety. 17 Obviously, we don't put in requirements where you 18 get a minimal benefit for $1 million. I mean, you do think 19 about that. i 20 But I did mention earlier, and I'll just mention 21 now, and I think many people around here mentioned it; the ) 22 ASME clearly is interested in doing things in a 23 cost-effective measure, and to that end, it does not relate 24 to this issue. I only mention it because I don't want to 25 give the impression ASME just does not-think about that. (] ANN RILEY & ASSOCIATES, LTD. A,/ Court Reporters s 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F L 124 1 Many of the code cases I heard here mentioned today deal f~)' 2 with. cost and radiation exposure setting, and I think I have lN/ 3 a list of about five or six here, and1I will not go through 4-them all, because it would take too long. 5 But I just want to make the point that we are 6 conscious of that; we know we need to do the right thing, 7 and clearly, we do not have significant cost numbers like 8 have been expressed here. 9 MR. SCARBOROUGH: Okay; thanks a lot. l 1 10 Why don't we move on to the next one? i 11 Item six is consistency in the range of ASME code I i 12 editions and addenda that will be applied by licensees, and ) 13 I believe ASME has first word on this one. 14 MR. FERGUSON: Again, the questions here are /~ (h 15 becoming repetitive. I think we've already stated the if we ] j 16 think the future codes become voluntary as opposed to I 17 becoming more enforced through the 120-month update, we 18 think that the range of code editions and addenda applied by 19 licensees will significantly increase. I think it just 20 follows, because every 120 months, you go through a process 21 to update. 22 So we frankly, the way we see it right now is this 23 adds a consistency to the process. And I also mentioned 24 earlier that I think this is one of the ways, one of the 25 costs that are incurred by this is the self-assessment that 7'T ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ) Washington, D.C. 20036 (202)'842-0034

125 'l you go through your programs when you do this. It forces f-x .( } 2 you, apparently,' judging by the numbers that I've seen this 3 morning, to spend a significant number of engineering man 4 hours to make sure that you've gone through the details of 5 your ISI and IST programs, and of course, why we think 6 that's important is the ISI and IST programs are very 7 significant programs, large programs, and the devil probably 8 is clearly in the details. 9 Thank you. 10 MR SCARBOROUGH: Thank you. 11 NEI? 12 MR. CONNER: I'm Jim Conner with Florida Power and 13 Light. 14 My comments here were I tried to focus pretty ) 15 narrowly on where we are right now, what I do right now with 16 the program and then what the elimination of the update 17 would maybe have me doing as a program administrator, and 18 currently,.right now, I've got several options in terms of 19 what I have in my program. You know, whatever editions of 20 the code are approved, obviously, we.can use those. We can 21 go to later editions with the current rules, portions of 22 later editions or addenda if you use all of the related .23 requirements. 24 We can obtain relief from impractical 25 requirements; we can obtain permission to use alternatives (O ANN RILEY & ASSOCIATES, LTD. m,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

126 'l proposed to the code, and we can use approved code cases. [ ') 2. So, when I put together a program, I've got these resources LJ 3 to pull'from in order to build that particular program. I 4 think where we are right now is we've got a lot of people 5 using'1989; when'we do repair and replacement activities, d 6 although we've had some discussion on a lot of the good 7 things that are indeed coming out of repair and replacement, 8 in a lot of cases, where practical, you end up going back to 9 your construction code for guidance, at least in my j 10 experience. 11 We use those things under repair and replacement 12 guidelines, obviously, when it's impractical, when they were 13 indeed valuable. But for the most part, we end up going 14 back to the construction code. Most plants right now, at 15 least in my experience, we're running about 20 relief 16 requests per ISI program,.and they vary between whether it's 17 code coverage, use of code case or alternatives. It varies j 18 across the board. It's kind of an even mix for us. 19 If we implement the rule change where you don't 20 have to update, but you only are going to baseline to the 21 1989 edition, I see very little change in that you'll have 22 your utilities largely to the 1989 edition; those who choose 23 to use other editions, later editions or whatever will do 24 that through the code process with a weekend update without 25 relief'or whether we need to get relief to do that. We're j I ANN RILEY & ASSOCIATES, LTD. Court Reporters l l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 j

l 127 still going to see that spread in code usage. -1 2 )- So,_in summary, I don't know that we're going to 3 see a drastic change in the spread of codes and requirements l 4 that -- from where we really are now, because I think we do 5' have a fairly wide range of various requirements 6 incorporated in the individual ISI programs. 7 MR. SCARBOROUGH: Any additional comments on this 1 8 item? 9 (No response.) 10 MR. SCARBOROUGH: Okay; all right; item seven is i 11' the potential effect on risk informed ISI and IST 12 initiatives, and NEI has first up on this one. 13 MR. MCNEILL: Alex McNeill, Virginia Power. I'm l representing the position supporting the general rulemaking. 11 4 [J) 15 Specifically, with the effect on the new j l 16 risk-informed regulations, I think this is a prime example' 17 where a totally voluntary program has worked. We've worked 18 in concert with ASME, NRC and industry to bring this about. 19 There are some current code cases that cover these 20 particular items. As far as I know, they have not been 21 endorsed by the NRC. Any approvals to date have been i 22 through alternatives to the code, through 50.55 (a) (a) (3) 23 rulemaking. 24 The voluntary basis for this new initiative has 25 worked very well. It's working well because all parties r ANN RILEY & ASSOCIATES, LTD. f s (, ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

128 1 involved see it as beneficial. As far as'I know, it will f]. 2 remain on a voluntary basis. The code cases, by their very i l. q] 3 nature, are voluntary; the code is eventually working 4 towards a non-mandatory appendix which will again make it 5 voluntary. The voluntary nature of this is needed, because 6 not every utility can do these things. They have to look at 7 several considerations: length of license; the cost to do 8 the evaluation as well as how much the exposure reduction 9 will be. l 10 In conclusion, I think again, the risk-informed 1 initiatives will be unaffected by the potential rulemaking. 11 l l 12 It will remain a voluntary type program. 13 MR. SCARBOROUGH: Okay; ASME? 4 i 14 MR. FERGUSON: I almost feel like this is point, ): 15 counterpoint. We agree, s 16 [ Laughter.) 17 MR. SCARBROUGH: Is there anyone here -- If 18 MR. HERMANN: Just to comment on maybe code cases. 19 Code cases alternative to the regulations are voluntary, in 20 the fact that you have the choice if you want to adopt them 21 as an alternative to the regulation. But, once you adopt 22 them, once you've got them, you've got them. They are part l 23 of the regulations, then. That's what your program is. 24 MR. MONTGOMRRY: I think the statements that he 25 made, though, were directly to the question of relationship )T ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 t.

E l 129 1 i 1 of risk. informed to this change -- you know, what's going to ,lO 2 happen there. 'And what you say about code cases is true, %.J t 3 but it doesn't, I don't think, speaks to the question. 4 MR. COZENS: Kurt, cause it's just a very minor 5 technical clarification. I would interpret that when a licensee adopts code cases accepted through the NRC process, 6 7 that's a licensee commitment versus a requirement. 8 MR. MIZUNO: OGC does not agree with that. ~We t 9 consider that the. approval of the alternative, if properly 10 carried out by the NRC staff when they approved the { 11' alternative, should result in some change to the FSAR and 12 then that would be controlled appropriately, sent to the .13 50.159 process. The rational for this is because the rule 14 50.55a requires the use of the ASME code by rule. The rule () 15 also provides for an alternative to compliance with the 16 rule. And the rule also sets forth the requirement for the 17 documentation of the other requirement. And so, therefore, l 18 it follows that the alternative that is approved pursuant to 19-50-55a (a) (3) should remain at the higher level, to be. 20. controlled by 50-59, as opposed to a simple commitment on l 21 management process, which is, I think -- I think we've 22 agreed with NEI that commitments,are outside the regulatory 23 purview of our -- of the Commission, until they take further 24 action. I 25 MR. MONTGOMERY: Gary, thank you. I stand -{"N ANN RILEY & ASSOCIATES, LTD. t Court Reporters s-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l u

c 130 1 corrected. J ![ )- 2 -MR. MIZUNO: I did see -- I guess I should add, I V 3 did_see a letter from NEI, I believe, asking us to address 4 that point. And I had the impression that they were 5 proposing that we -- if we took this position -- position -- 6 if they thought that this was the position that the NRC was 7 taking.that I understood it as saying they wanted some -- 8 they wanted it to be a commitment tracking process, as 9 opposed to the process that I was -- discussing it, so I I 10 think that we would have to address it as a comment, and 11 either accept it or reject it and provide a reason for that. 12 MR. MARION: Alex Marion, NEI. What you're i 13 referring to deals with a completely separate topic and we 14 can discuss it during the break, if you want. / t 15 MR. SCARBROUGH: Okay. I did want to just raise a 16 question, since this is a risk-informed IST initiatives that i 17 .we're talking about here in this question. Any of the 18 utilities' representatives here, who are from a risk-informed 19 IST pilot plant or plant that's going down that pathway? 20 Either one -- what's your perspective on this question? Do 21 you see any effect at all, either way, how this -- the 22 update, whether it goes or stays, how it would affect your 23 plants in this area? i i 24 MR. MCNEILL: Alex McNeill, Virginia Power, and 25 the comments that I read previously were my comments. O ANN RILEY~& ASSOCIATES, LTD. l (,-) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l

131 1 MR. CONNOR: Jim Connor with Florida Power & () '2 . Light. We're doing a pilot project with the Turkey Point 3 site and, once again, I agree with the comments previously 4 before, that I' don't see any real effect on our effort. 5 MR.-METROW: Brent Metrow from State of Illinois. 6 Breadwood Unit Two and Byron Unit Two are power plants in 7 Illinois, and both of those are, I think, considered follow 8 on plants for risk-informed ISI. And I was -- I was at 9 Breadwood Unit Two evaluating, among other things, the -- 10 those examinations, which were conducted -- those 10 or 12 11 exams, which were conducted in the risk-informed ISI realm, 12 as well as the ISI program -- risk-informed ISI program. 13 They have a. partial implementation for just class one piping 14 at those two plants. And I wouldn't see that that would () 15 have an effect on -- this rule change would have an effect 16 on risk. 17 MR. DEBONIS: John DeBonis, for TU Electric. We .18 were a pilot _ plant for the risk-informed IST. We are 19 implementing that now. We are going to pursue the 20 risk-informed ISI. We do not anticipate this supplement to 21 the rulemaking affecting that one way or the other. 22 MR. MAHINDRAKAR: And this is Arun Mahindrakar, 23 California Edison, We are a pilot plan for IST. It will 24 not affect any of the effect on that, and we still see that 25 120 month upgrade as a burden. i /'N. ANN RILEY & ASSOCIATES, LTD. (s,[ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l 1 l L

[L T i - 132 1 MR. SCARBROUGH: Thanks for the input. All right. / 2 Next move on to the next topic. Number eight was the C) 3 potential effect on states and other organizations that rely 4 on the ASME code, in their interactions with nuclear power 5 plant owners. I want to break -- I'm going to let Brent 6 Metrow, Illinois Department of Nuclear Safety, have the 7 first comments, since this is strictly related to his 8 organization, 9 MR. METROW: Thank you. There's several areas 10 that we interact with Comed Illinois Power, in the realm of 11 ASME code Section XI. Starting off at the top, we're 12 charged by law to issue or withhold operating certificates, 13 traditional role of boiler safety within the states. And 14 for your air tank out in the switch yard, that's pretty () 15 straightforward, one certificate for one piece of equipment. 16 We've devised a different scenario for the nuclear 17 power system. Instead of issuing a separate certificate for 18 each steam generator in a PWR, for example, we issue one 19 certificate for the nuclear power system. That is -- that r 20 covers all the vessels and boilers that are part of the ISI 21 plant, and the period -- the term we issue the certificate 22 for is equal to the period of the in-service inspection for 23 40 months. At the end of that time, after -- after we do a l 24 numbers check, we reissue the operating certificate for the 25 next ISI period. The numbers check I'm talking about, of /N k) ANN RILEY & ASSOCIATES, LTD. Court Reporters s-1025 Connecticut Avenue, NW, Suite 1014 1 Washington, D.C. 20036 t (202) 842-0034 1

~ ff h 133 l .1 course, is meeting the percentage requirements for various ( ') 2 exams'that you have to do. l \\~J l 3 So, this particular rulemaking, as long as the l 4 periodicity of -- is maintained and after the 10 years, 5 'albeit no program update, you start another ISI interval in 6 an ISI period. I don't see any impact of our process -- I 7 don't see our process being impacted, one way or the other, 8 by the. rule change. 9 Another area is -- myself and my supervisor, Larry 10 Sage, both do inspections on behalf of the NRC Region III at 11 power plants. We inspect to NRC modules -- inspection 12 manual modules. And using their procedures, we're an added 13 resources for the region. And I don't see this having any 14 affect on that activity. Whac we inspect to is the code of ) 15 record and if that doesn't change, then that wouldn't be -- 16 that wouldn't be an affect on that activity, whether it 17 changed or not. 18 I can see -- I can see a-difficulty in the repair 19 area, especially the role of the ANII. And what I see there 20 is, again, going to -- it's going to have to result in 1 21 cherry picking of selected requirements. If you want to use l 22 temper B technique, if you want to use repair techniques ) 23 that are brought in to later approved codes, you're going to 24 have to first get approval to use them from the NRC, or else i 25 the inspectors are going to catch that type of -- that type ') ANN RILEY & ASSOCIATES, LTD. ss' Court Reporters s 1025 Connecticut Avenue,.NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

[.- 134 ( 1 of differences. I~' N.,)\\ ' '2 Lastly, although my state doesn't do it, there -- 3 I mentioned before about there are some that. automatically 4 update -- or automatic propose -- or approve updates to the 5 code, and that could be a difficult legal -- that could run 6 into a legal problem. And that's all I have. 7 MR. FERGUSON: Could you expand? 8 -MR. METROW: Yeah. With -- at the time of the 10 l 9 year interval ending and a new 10 year interval starting, 10 the code requires you to -- right now, the NRC requires you l 11 to update to the newer code of record. When there's a state 1. 12 requirement to update - when there's a state requirement l. 13 calling into -- I'm sorry, I thought I had something, but I 14 didn't. /~N f 1 15 MR. SCARBROUGH: Okay. How about ASMEGL, anything %J. 16 to add in this area? l 17 MR. FERGUSON: No, we have nothing to add in this 18 arena. l 19 MR. SCARBROUGH: Okay. NEI? l 20 MR. MARION: No, no comment. l 4 4 21 MR. SCARBROUGH: Okay. Thank you. All right, 22 number nine, application of portions of the ASME codes 23 incorporated by reference in the regulations subsequent to j 24 the baseline addition. This is the cherry picking issue l \\ l 25 that we talked about, l ) ANN RILEY & ASSOCIATES, LTD. s/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

3 135 1 MR. MONTGOMERY: This is Ben Montgomery, Hammer & 2 Huey Calloway plant. The first slide shown here is just an 3 overview. It changes to the ASME code, frequently a 4 refinement of the existing requirements, resulting in a more 5 realistic criteria, as a result of new techniques or 6 improved method or operating experience. In this regard, 7 time is on our side, because as we go through time, we learn 8 things. We have lessons learned, and that's how the code 9 evolves. 10 Time is a problem, though, because the NRC process 11 to adopt new or revised codes edition, addenda, and code 12 cases is inefficient. Typically, a licensee will adopt new 13 ASME criteria via a relief request prior to the NRC formally J 14 adopting a code. This is because the licensee's needs are ) 15 frequently measured in months, rather than years, and 16 edition and addenda updates can take far more time than 17 selective implementation. Code cases are frequently 18 available prior to the formal publication of a new edition 19 or addenda. 20 Timely -- what we're proposing in this area is a 21 timely approval of ASME code and code cases. We're 22 proposing, basically, three items: an automatic six-month 23 approval., unless the NRC identifies direct conflict with NRC 24 regulations of ASME code; generic approval by the NRC, if 25 relief requested could be used by the industry, so that you /^' k ANN RILEY & ASSOCIATES, LTD. Court Reporters %s 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1

136 1 don't have people repeating the same work and reinventing i\\~-]\\ 2 the same wheel over and over again; also, allowance to use 3 portions of the NRC approved code, without relief request. 4 This has been mentioned several times. The NRC uses the 5 phrase " cherry picking." We don't.really see it, as, I 6 guess, historically, we haven't seen it as that. 7 What we're' talking about here is, if I want to use 8 a repair and replacement out of the 1998 code and that's an 9 approved code, we take that repair and replacement. If I 10 want to use IWA 4000 and I meet all of the requirements of 11 the IWA 4000 and all these surrounding requirements, it just 12 makes sense to -- it's a better piece of code, and we don't 13 argue that it is, then we don't see any harm in us being 14 allowed to take that better piece of code, even though we r 15 don't take the whole thing. 16 And that's all our comments, in this area, 17 MR. SCARBROUGH: ASME? 18 MR. FERGUSON: First, I agree. I think many of 19 the comments you made about getting the code reference and 20 the updates are right on the mark, absolutely. And the 21 timeliness, we feel that's -- I think you could have written 22 this for us, as well. You know, we're right on the same 23 mark. 24 One comment I would make about the codes. I do -- 25 and I've mentioned this three or four times, there is some IT ANN RILEY & ASSOCIATES, LTD. Cl Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

E ) I 137 .1 thought that there would be a cherry -- if you're allowed to [ .2. cherry. pick codes, you're going to get a patchwork of codes. 3 I believe that eventually, that may increase the burden on 4 the regulator, which you mentioned earlier, because he will 5 .be required to evaluate the pieces you give him in the 6 larger context, to determine that you're still meeting the 7 appropriate level of safety. I do have a concern that the 8 utilities will not'be able to evaluate each of these pieces 9 adequately, up to their management chains, and make sure 10 that these things get the light of day. I mean, they're 11 done at different levels within the utilities, and some of i 12 these have pretty significant costs. 13 But, fundamentally, I have to say, I agree. I 14 agree with the code update process. I think that makes a 15 lot of sense. We, in the committee, have the same issues. 16 MR. MONTGOMER7: This is Ben Montgomery, again. 17 I'd like to point out one other thing that not on here. The l 18 NRC needs to acknowledge their participation in the code 19 process, as somewhat of a review of that code. I know they 20 do informally, but the frustration that people involved in 21 the code process have is that the code goes through many 1 22 levels of review, before it goes out, and then it disappears 23 again for some number of years before it's once being 24 reviewed again. The code process is a good process and it 25 does put out a good product, and I think that needs to be l /~'\\ ANN RILEY & ASSOCIATES, LTD. Q Court Reporters 1025 Connecticut' Avenue, IN, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I I 138 1 recognized. f [[ 2 MR. SCARBROUGH: Okay. Gary? J l Q' 3 .MR.~MIZUNO: I don't think our office has taken a 4 position yet, so I should say that this is my own personal i 5 view. With respect to the -- this automatic six-month { s 6 approval process, I think that there are litigational risks 7 were the NRC to adopt the. rule in that fashion, primarily, 8 because'if that process were not allowed for incorporation i 9 by reference of the -- a new rule by the Office of the 10 Federal Register, and that process of obtaining official incorporation by reference by the Office of Federal Register 11 12 is a requirement, in order for that ASME code or any other 13 document which is to be considered a binding legal 14 requirement, you must go through that process. I\\ -15 So, I would be interested -- the Office of General V 16 Counsel would be interested in comments that -- comments 17 from the industry that address thi'a issue of whether the -- 18 an automatic approval process -- a rule that allows for 19 automatic approval, absent an NRC action -- rulemaking 20 action, that disallows a certain portion of the rule, 21 whether that meets the requirements of the Administrative 22 Procedures Act, and, in particular, the requirement for j 23 incorporation by reference, j 24 MR. STENGER: Dan Stenger, with Winston & Strom. 25 The was 50.55a is structured now and worded, I think you're l /'S. ANN RILEY & ASSOCIATES, LTD. l (, Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i 1

E 139 1 probably right, with respect to new editions of the code .f 2 that have not formally been incorporated by reference. 3 Somewhere down the road, and it's probably the subject to 4 this workshop, if we had a more performance-based 50.55a or 5 one that was'not tied to the incorporation by reference 6 process, I think you could say that the code is the 7-acceptable means and then endorse in a reg guide different 8 versions of the code, as an acceptable means.to meet the 9 regulation. 10 MR. MIZUNO: I agree that that is a possible 11 regulatory route. And although there are some significant 12 downside to that route, both for the licensees and the NRC, 13 I'm sure you're probably aware of what those might be from 14 the standpoint of, I guess, regulatory certainty and, also, O k_/ at the issues that are available for litigation in any 15 16 hearing proceeding associated with a license amendment. 17 MR. STENGER: How about for -- Dan Stenger, 18 Winston & Strom. How~about for code cases that reflect an 19 interpretation of the existing code, why couldn't those be 20 allowed for automatic implementation? 21 MR. MIZUNO: I don't think that there's any reason 22 why -- there's no legal reason -- I want to be' clear that-23 there is no legal reason why we couldn't go through a system '24 that allows for NRC endorsement in a regulatory guide, as 25 opposed to incorporation by reference and approval in a A ANN RILEY & ASSOCIATES, LTD. C Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i

l 140 1 rulemaking. 'But, there are downside to -- I mean, there are l ['] 2 positives and negatives to that. And in the past, as been ' b 3 determined by both industry, as well as the NRC, that the -- 4 I guess the interest converge and say that it would be best 5 to have the rule -- I'm sorry, have the ASME code endorsed l 6 in a rulemaking, because of the certainty that is accorded 7 by rulemaking. But, we could move to a different system. 8 Now, assuming that we stay within the same 9 existing system, I, also, don't believe that there is any 10 legal problem to endorsement in a regulatory guide of a code 11 case, which simply interprets the rule, but still provides 12 for compliance with it, okay. My understanding, and the way 13 that I've counseled the staff in the past, is that the code 14 cases oftentimes go beyond interpreting the rule. In fact, (m) 15 they provide alternatives to compliance with the provisions 16 of the rule. 17 As soon as you start talking about an alternative 18 to compliance with the provision of the code, you are also 19 talking about non-compliance with the rule, because the rule 20 -- the rule being 50.55a, 50.55a mandates by rule that you { l 21 must comply with the code. It does not refer to anything { 22 involving code case. And that's why we have counseled the 23 staff that, ideally, code cases -- NRC endorsement of code 24 cases that offer alternatives to the existing code, if they 25 intend to be -- if they intend for that endorsement to be / ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 x

L 141 l 1 legally binding, the same way that a 50.55a, as a rule, is L L (T 2 binding, that it needs to be done in the context of -V 3 rulemaking. 4 You don't have to go through that way. You could l 5 have the endorsement in.a reg guide and then.have a licensee 6 come in with a license amendment and a -- what is 7 essentially either a relief request or a -- actually, a l l 8 50.12 exemption request. And you can accomplish it that l 9 way. But, then, of course, that results in a l 10 licensee-specific proceeding or determination, as to whether 11-that code case is applicable. If you deal with it in a 12 -rulemaking, then it's a generic approval and the licensee l '13 just goes forward, takes advantage of that code case. 14 MR. HERMANN: Bob Hermann, the staff. A comment () 15 on intent. Intent are never included in code cases. Code 16 cases are alternatives. They're not intent. Intent type of 17 things go through the inquiry sessions or through another 1 18 process, but.not code cases. 19 The other comment I just would make on the 20 timeliness issue: I think certainly the industry has a valid 21 point, in terms of code case updates, in terms of timeliness 22-of those issues. I would comment with regard to updating l 23; the rule, itself; that some of the timeliness issues, in 24 terms of getting later editions of the code endorsed outside 25 of the' context of whether or not updating ought to be the ,e N ANN RILEY & ASSOCIATES, LTD. (,)- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l i. L_

f5 i 142 1 way to do it. This whole issue on updating and CBLA, [) 2 certainly in part, has delayed implementation of the \\J

3 adoption of later use -- later code editions.

So, I think 4' that piece -- the industry has a piece of that one, as well 5 as the staff does. 6 MR. SCARBROUGH: Anything else? All right. The 7 last discussion topic here is the clarity of the supplements 8 of the first' rule. And ASME, do you have some comments on 9 this area?- 10 MR. FERGUSON: Yes, I do. Just two comments from 11 my reading of the rulemaking. One of them is in the code -- 12 in the rule that talks very clearly that this is mature 13 code. It wasn't clear where that basis came from, that this { 14 is a mature code. It said the staff has done that. And it 15 seemed to me that that requires some clarification, because 16 that's clearly one of the foundations, that the 1989 code is 17 a mature code. So, that's one of the things we can go into 18 great detail today, as well. So, maybe you got some i 19 information that can help you with that. 20 And the second area, which I think you did a good j 21 job today, the basis of the cost estimate. I think it looks 22 to me'like you'll get some additional information on that. 23 That's the end of my comments. 24 MR. SCARBROUGH: Okay. Anything in that area that 25 .you all can provide or anyone else could provide in their D . ANN RILEY & ASSOCIATES, LTD. L b Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington,.D.C. 20036 (202) 842-0034

r 143 1-written comments on the proposed rule, that will be very () 2 helpful, in both these areas and others. J 3 MR. COZENS: This is Kurt Cozens from NEI. We've 4 had quite a few comments on the actual wording of the rule 5 in our previous presentations. So, I -- but, I will not 6 repeat those, because they're already in the record. So, 7 that should be noted as such and they'll also be provided in i 8 the written response that we will be providing. i 9 However, I might note there was a couple of 1 10 comments that came to mind that did fit into the scope of 11 the things that we've talked about, and I'd like to make 12 note of those. And there's three of them that we have in 13 our presentation here. 14 First of all, let me note that in the rule on page () 15 22584, there's a statement that says, "However the NRC could ~ 16 apply a time limit on the acceptable of an ISI leave 17 request." And we don't think that's an appropriate action 18-to take. We don't understand the technical basis that one 19 might automatically set some' set limit on a request. And we 20 believe it would indeed negate the intent of the proposed 21 rule, because a lot of the expenses that we incur are, 22 indeed, having to resubmit relief requests. So, it seems a 23 contractor action. 24 The next column we have is that the initial rule 25 that was issued in December of '97 talked about the '95 (')\\, ANN RILEY & ASSOCIATES, LTD. (, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

144 1 ' edition through '96 of the ASME code. And if this rule is (nx_-) 2 ' adopted, that we would propose that the rule adopt that for 3 voluntary implementation, the later edition of the ASME code 4 that was initially reviewed and found acceptable by the 5 staff. So, this was not talked about in this supplemental 6-proposed rulemaking that what, if any, additional later 7 editions of the code would be available for licensees to 8 use. So, there's one that's already been reviewed. We 9 think that the staff's efforts have already been complied. i 10 Lastly, assuming that this rule is promulgated and 11 there is a base code adopted, should the NRC staff choose to 12 adopt any other base coded, other than discussed, we would 13 propose that the rule be reissued for public comment, seeing 14 that we don't have the chance to review that. And that is a (A) 15 very critical element of whatever the base code might be. 16 MR. SCARBROUGH: Tom? 17 MR. HERMANN: Just to comment to Kurt's comments. ] 18 The question of terms for relief request, I think we 19 mentioned that earlier, there is certainly some relief 20 request we completed granted, because of inadequate 21 technology to do something. For instance, examining VWR 22 reactor vessels, 10 years ago, people could examine -- 23 couldn't -- didn't have the tooling to do VWR reactor 24 vessels, because shield walls run away. Today, they do. 25-So, there certainly is some things that are technology j'] ANN RILEY & ASSOCIATES, LTD. (- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

r 145 li ~related. ) i ( 2 I guess the other thing is you brought up a N. 1 13 subject about the rulemaking package and I think the l 4 rulemaking package that-was out for comment had the '95 code 5 .through '96 addenda, and I think'that's already been out on l 6 the street. 7 ~ )MR. MONTGOMERY: This is Ben Montgomery. 8 Concerning the time limit on relief request, the NRC already 9 has:a vehicle -- have many-vehicles available to them. If 10 the technology changes in the future, they can issue a 11-letter. They can require people to go back and look at the 12 relief requested, apply to that technology, and update it, 13 put it in a dogmatic -- spend 10 years on it, 12 years on 14 it, whatever number you might come up with and say, in every .{ ) 15 12 years, you're going to have to spent so-many thousands of 16 dollars, regardless of whether the technology changes cn 17' not, is not an efficient process. 18 And I think the thing that we're hearing over and i 19 over again, here, and I think that I truly believe, is 20 . efficiency is -- is a watch word here. We need to be 21 looking for efficient ways to improve our processes. 22-MR. SCARBROUGH: Any other comments on that last 23 item on clarity? 2.4-MR. WESSMAN: Tom, if I may respond to the NEI. 25 comments. I think our intent was that the second bullet p-ANN RILEY & ASSOCIATES, LTD. 3,j Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

e 146 1 that Kurk mentioned about voluntary adoption of the '95 ) 2 edition through '96 addenda, was certainly intended, if it's 3 not clear in the rule, we need to fix it. I think we made l 4 reference to that concept in the statement of consideration. I 5 So, we'll.take a look at that. 6 As far as the third bullet, about adopting a 7 baseline other than the listed one in '89, one of the l 8 specific questions that was in that-Federal Register notice 9 dealt -- and one of the questions we've discussed today is 10 the very issue of selection of the proper baseline edition. f 11 So, I think, in fact -- and OGC will have to help me out I 12 here -- but, I think we have, in fact, put this concept in 13 front of the public comment process, by virtue of the way we 14 invited comments and the things that we identified for r(g j 15 consideration. So, I'm not sure that there would be a 16 requirement to go back through a public comment, if, for 17 example, the staff selected the '95 '96 for the' baseline, as 18-opposed to_the '89. 19 ~ MR. MIZUNO: This is Gary Mizuno. Legally 20 speaking, we wouldn't if the NRC were to adopt a baseline 21 code edition other than '89, a more recent edition up to the 22 '96,. I think it was, edition -- or was it the '95 edition 23 that was -- '95 edition that was adopted -- that was 24. proposed in the '97 -- '97 rulemaking, we would not feel 25 that the publication would be necessary to meet the (9 ANN RILEY & ASSOCIATES, LTD. \\_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034

147 1 requirements.of the APA. Whether or not a further comment ( ). 2 period should be provided, I think, would be primarily a 3 matter of policy for the Commission and the staff to 4 consider, but it wouldn't be required as a matter of law. .5 MR. SCARBROUGH: Any comments? Any comments on 6 any of the 10? Anybody would like to mention something that 7 they' forgot or missed earlier -- in one of the earlier ten, 8 before we take our break, and then we'll come back? 9 MR. MARION: Alex Marion -- l 10 MR. SCARBROUGH:. Hang on one'second; hand on one 11 second. 1 12 MR. MARION: Oh, I'm sorry. 13 MR. SCARBROUGH: go ahead. 14 MR. NORRIS: Wally Norris, NRC staff. I'm on a A i ) 15 couple of co-committees and one thing I would just like to s 16 throw out for thought was last week at~a few of the. ~ 17 committee meetings, as items were discussed, at two 18 'different meetings, I heard that -- the question was put 19 forth of why should we work on this increase and 20 -requirement, because if the NRC baselines, we'll never have 21 to pick it up anyway, talking about effect on safety. Just ) l

22 something.I wanted to throw out for you to think about.

~ 23 MR. MARION: I was just reflecting -- I'm sorry, 24 Alex Marion, NEI. I thought some time in the morning 25 discussion, somebody' identified one or two issues that they i ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 l L

l 148 i 1-said they. wanted to discuss today that weren't captured by f- /' T 2 the 10, at your meeting announcement. And I don't remember i ! V' l 3 who that was. Does that ring a bell with anybody?

Okay, l

4 I'll withdraw my comment. 5 [ Laughter.) 6 MR.'SCARBROUGH: We'll think about it over the 7 break and we can wrap it'up at the end. Anything else? Go 8 ahead. 9 MR. MILLER: Gene Miller with Duke Power Company. 10 I know that the December '97 rulemaking is off limits for 11 discussion today. But, again, referring to the recent ASME 12' section 11 meeting in Greensboro, there were come confusing 13 signals put up there regarding when'that larger rule would 14 be published. Some of the NRC correspondence seemed to (m,i 5 15 indicate that both the larger rule, from December of '97, %/ 16' and the decisions on the supplemental rule would be hailed 17 and published together at a future date. But, some of your 18 people -- the NRC's people at the code meeting were 19 indicating that perhaps there's been a change and that the 20 larger piece would go ahead and be published in the near 21 term. Can we get a clarification on that? 22 MR. WESSMAN: I'm aware of a little bit of 23 confusion on comments of the two pieces and also some 24 diversity of views on the two pieces of the rule. And so, 25. let me try and clarify. I was not present in Greensboro and l /] ANN RILEY & ASSOCIATES, LTD. ! (,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D. C -. 20036 (202) 842-0034

l 149 l l 1 if something-was said that created confusion, of course, you / l-2 know, we're sorry that that happened. U j 3 I think our intent is to treat this as a l 4 supplement to the larger version that was published in '97. 5 And the intent is once we disposition this particular 6 activity, we merge this activity'with that '97 package; and 7~ along towards December, January, February, depending on how 8 swift we are with some of the administrative processes and l 9 the publishing process, what would be published as a final 10 rule represents a merging of the two activities.

Now, i

11 because of this supplemental activity, if the final decision 12 is that a 120 month baseline is eliminated -- 120 month 13 update is eliminated and we do have this 1989 baseline, obviously, the reference to the '95 version of the code in 14 () 15 the '96 addenda would be referred to in the category of for 16 voluntary implementation by licensees, subject'to thosa i i 17 limitations that would be contained in that final rule. I l 18 There has been diversity view on this, and I'm -- 19 there has been, I guess I would call rumors about, gee, is 20 there being direction given to the staff to go forward with i l 1 21 that package or not go forward with it; at their direction 22 to do something slightly different. We have no specific 23 directions to do something different, even if there had been 24 rumors to that fact. We do not have that. We are 25 proceeding according to the process we described in the SECY l l ("'/ \\ ANN RILEY & ASSOCIATES, LTD. \\-- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 -Washington, D.C. 20036 (202) 842-0034 i L

p i 150 1 99-17 that you all have and that we presented to the -f" 2 ' (_-} Commission and proceeding accordance with the Commission 3 requirements, memorandum that came back to the staff. 4 That's what we're,doing and that's why we are here 5 today. And that is still the process, unless we are given -6 some different policy direction. So, hopefully, that helps 7 clarify that bit of confusion that I know did surface in 8 Greensboro. 9 MR. SCARBROUGH: Anything -- 1 10 MR. SWANN: I'd like to make one comment about 11: Wally's comment. I guess I was a little bit upset by your 12 statement, Wally, but I don't doubt for a minute that it's 13 the truth. If there's any adversarial here today that are 14 members of the staff or ASME code committee or licensees () 15 that let this potential supplement to the rule affect our 16 work on the issues that are deemed as being safety related 17 for our plants, then we're all at fault. 18 I'd like to say that I can't speak for Section 11, 19-because I'm not a member. But, I know that I've sat in a 20 lot of meetings at the ASME code meeting, where NRC staff 21 - representatives have made presentations about issues that 22 they considered to be safety significance. And they brought j 23 it to the attention of the code committee that they would 24 much rather let the industry and the code handle that issue, 25 as opposed to having to handle it through the regulatory . () i ANN RILEY & ASSOCIATES, LTD. (_ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

b I i 151 l l 1 process. l. /i 2 So, I can't see that we let a statement about, O 3 well, we're not support th= code or we're not going to support this, because there's no l'onger a mandatory update 4 i 5 process, that should not come into play. 6-MR. WEST: Ray West, ASME.

1. attended the 7

meetings in Greensboro last week and I heard those 8 statements made..The code process is a very frustrating l 9 process. It takes a long time and a lot of effort to make 10 changes to it. And when you're going through that, it's l l 11 very easy to say, why should I put all this effort into 12 something that's not going to be used, and particularly, in l 13 those instances where it's an increase in the requirements, { 14 it's very difficult. () 15 So, it may have only been an isolated statement, 16 but I think it's there and I think it's part of the problem l 17 with this update and doing away with the mandatory update of 18 120 months. Thank you. 19 MR. SCARBROUGH: Okay. All right, why don't we 20 take a 15-minute break and then we'll have the wrap-up 21 comments. 22 [ Recess.] 23 MR. SCARBROUGH: Marge is passing out a copy of L 24 Mr. Hedden's handout, earlier today. We set them on the 25 table back there, but we didn't make sure that everyone had l (N ANN RILEY & ASSOCIATES, LTD. \\,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 l l t.

152 1 a copy. So, she's making sure that-you get your copy, (')N 2 before you leave. They'll show up in the meeting summary. \\_ 3 We'll attach all the handouts. I think we have a copy of l l 4 everybody's handouts and we'll make sure they get attached. 5 Okay. We've made it through the round table 6 discussion and we're getting ready to do our closing 7 remarks, once everyone gets_ settled. NEI, would you like to i 8 go ahead and do your. closing remarks? 9-MR. MARION: Alex Marion, NEI. I'd like to go 10 back to the comments I made this morning in my opening 11 statement. I think I said it three times. Well, here we 12 are. As a personal observation, I was really impressed and 13 enthused about the depth of discussion. I find it very 14 interesting that there were some rather emotional threats ] () 15 related to some of the topics and issues, and I'll leave it 16 at that. 17 One thing that did trouble me, and I feel 18 obligated to speak up on this, is during the conduct of the j 19 meeting, I had the impression, and maybe it was just me, l ~ 20 that we were in somewhat of a debate, if you will, NEI's 21 position, ASME's rebuttal, and then NRC staff's rebuttal, 22 etc. And that's not the case at all. For the record, I 23 want to-make it clear that NEI supports the standard l 24 development process. We feel it's very important. We think l 25 the process has served the industry well in the past; it's 1 ( ANN RILEY & ASSOCIATES, LTD. l (,j) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l t

1 153 1 serving the industry well now; and it has to serve the 2 industry in the future, because, quite frankly, we will not 3 have a future without a very solid, dependable, independent 4 objective standard development process. 5 I think a lot of the issues that we brought up 6 related to things beyond the question at hand. The question 7 at hand was the impact -- realistic practical impact of 8 eliminating the 120 month update. And we got into a lot of 9 issues, a lot of challenges thet involved the standard 10 development process within ASME, also the output of that 11 process, in terms of work products, in terms of code 12 editions, addenda, and code changes, as they are applied in 13 the regulatory process. And as we were going through that 14 discussion this morning and then to the afternoon, it (,-) 15 appeared to me that what we're tried to do here today is v 16 discuss and focus on the regulatory process, but what became 17 clear to me is we couldn't separate the two. And I don't 18 know why that is. 19 It may be history. But it seems to me, today, 20 maybe we'need to think about trying to figure out a way of 21 separating the two. And the only way we can do that is to 22 do it together, if we think that is the right approach, or 23 recognize the fact that they're inseparable, the one plays 24 into the other. And then that causes us to focus our 25 energies on how to establish the most efficient regulatory (~ 3 ANN RILEY & ASSOCIATES, LTD. (,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l L

154 1 process, such that all these emotional threads don't show up (} 2 as they did during our discussion today. x._/ 3 I was really pleased with the utility personnel in 4 attendance. The only utility personnel that we worked with 5 at NEI were those, who were involved in the task force that 6 gave the presentations. I was really impressed with the 7 other utility folks, who are here at the meeting today in 8 their own volition that spoke up and offered their 9 observations and perspectives, and I was really pleased to 10 see that. 11 During the positions identified and the comments 12 made by the utility personnel here, I think I can speak on 13 behalf of what I heard, and that's that the utilities will 14 continue to participate in the ASME code process. They will A( ) 15 continue to use the products that come out of the ASME code 16 process. But fundamentally, that decision on how they're 17 going to use it and how they're going to participate is 18 going to be based upon the value. And the value, as we all 19 recognize over time, changes. There's value based upon 20 safety significance. There's value based upon operational 21 improvement at the plants; that depending upon where you 22 apply that improvement can lead to -- can lead directly to 23 safety performance. And then there's also economic value. 24 We spent a lot of time today talking about economics.

Now, 25 we need to keep those three elements of value, and probably

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r i 155 1 a half dozen more, in mind, as we move forward. ~/' 2 b I think it became clear that there was a need for 3 an expedited efficient process for the NRC to think about, 4 in terms of endorsing future versions of the ASME code 5 editions, addenda, as well as code cases. And it should be 6 clear to the NRC that we've been working with for the last 7 five years or so, we're willing to work with the NRC into l ) 8 the future, and I believe ASME would be willing to help out, 9 to the extent that they can, as well. 10 We made the point during the discussion that 11 regardless of what happens with this rulemaking, you will 12 still have relief requests, okay. There's not a whole lot 13 we can do about it, because the process that's in place 14 right now allows for relief requests for those kinds of /^% i ) 15 situation, where somebody wants to apply the ASME code in i %/ l 16 the regulatory environment, which includes the regulatory 17 process we currently put in place. Now, if that's not the 18 right thing to do, then'we need to take a look at the 19 broader, process. 20 Those items I just reviewed were basically items, 21 I think, that represented somewhat of a consensus in the ) 22- ' discussions from what I heard. If somebody has another 23 observation contrary to those wishes to complement, then 24 that's fine. 25 In terms of conclusions, I made the point about f~% ANN RILEY & ASSOCIATES, LTD. i j Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l 156 1 the separation or the distinction between development of a ('~'} 2 code with ASME and its use. We heard that they're going to V 3 be used. I think we even heard that later versions of the 4 ASME' codes are being used by the.non-nuclear industry. And 5 here we are in the nuclear, confronting an :ssue or question 6 of the impact of baselining to the 1999 edition. I don't 7 know'what that tells us. Maybe it's a process -- excuse me 8 -- maybe it's a process issue; maybe it's something else. 9 But, I'think that's a piece of information that ought to 10 cause us to pause and reflect, once NRC deals with this 11-regulatory question before them. 12 We provided, based.upon the information collected 13 by the utilities involved in our task force, cost estimates 14 on the burden associated with the 120 month updates. During _[v) ~ 15 that discussion, there was a request for us to provide 16 further clarifying information. We will attempt to do so 17 and submit that in our comments. I believe the due date for 18 the comments is June 28th. 19 We spent a lot of time discussing cost impact. I, 20 quite frankly, would have expected us to spend a lot more 21 time discussing safety significance of this decision that's 22 before the NRC. Some of our utilities that we've had look 23 at this have concluded that there's no safety significance, 24 from the standpoint of these updates. And quite frankly, 25 the utilities, in terms of application of these things at (~S., ANN RILEY & ASSOCIATES, LTD. (,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I 157 1 the plants, are probably.in a. pretty good position to make ' [G] 2 that determination. And I would hope you would take those 3 determinations seriously, as you move forward in your 4 decision. i 5 In terms of the decision that's before the NRC, it 6 seems to me it's a policy question, and the policy becomes 7 one of what mechanism, what vehicle does NRC use, if they ( 8 decide they need to have one in the future to endorse 9 editions of the code. I think the step that the NRC han l 10 taken is a small step. This is the one on considering 11 elimination of the 120 month update. But, it's the 12 beginning.of a journey, and you will never know that you'll 13 be successful until you take all the other steps. And it's 14 not clear to me you'll ever get there, because once you get ,D 1 (O 15 there, you'll not going to be successful, because success is 16 a journey, in my point of view. But, this is a start. I 17 think there was a lot of good input provided today to help i 18 you in making that decision, and I hope you find it helpful. 19_ I just want to take a second and reflect on the 20-decision that was already made by the Commission, and that 21 was to review regulations and eliminate unnecessary burden. 22 And quite frankly, I think from the discussion'that was '23 presented today supports the fact that this action that's 24 being proposed'by the NRC is consistent with that decision 25 that'was made by the Commission, in eliminating unnecessary l l t p ANN RILEY & ASSOCIATES, LTD. Q Court Reporters 1025 Connecticut Avenue, NW,' Suite 1014 Washington, D.C. 20036 (202) 842-0034 i

158 l 1 burden. And, also, lastly,.I'd like to comment that we (~N 2 believe that if NRC proceeds with that process of i u,1 \\ 3 eliminating this update requirement, that you will probably 4 see a little bit of downside impact on the code process, as 5 people react to this. But when they start recognizing the i 6 fact that the NRC is working at improving their process for 7 endorsing code cases, etc., in the future, I think you'll 8 see more involvement in the standard development process. i 9 And that concludes my comments. I don't know if l 10 anyone -- anyone of the other utility people have anything 11 to add. j l 12 MR. MONTGOMERY: it was mentioned several times 13 that the ASME code is a living document. I'd like to point i 14 out that this regulatory code is also a living document. () 15 And in saying that, I want to say that sometimes there's a 16-certain amount of fear of the unknown, as you go forward in 17 revising the code. Some of it is founded and some of it is 18 not founded. In the event that you do-go ahead and go 19 forward with this, it'doesn't say that sometime later on, 20 when you find out that you're having negative impacts, that 21 you can't address those negative impacts. And I think it 22 would be appropriate to do so, at that time. 23 Thank you. 24 MR. SCARBROUGH: ASME? 25 MR. FERGUSON: Thank you. First is, I did mention i (~] ANN RILEY & ASSOCIATES, LTD. () Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

159 1 this. morning that I hoped we had a meeting like the code (')'5 ' committee meeting, where we sit down and sort of thrash it 2 ( 3 out. We did it. And I felt very good about that, because 4 when you sit down and express your views and disagree 5 honestly, you'll probably come to the right answer. And I 6 -felt that we did much of that today. And it felt very much 7 like a_ code committee meeting. 8 I would like to thank the people that showed up .9 today -- or showed up that I knew, and spoke. Frankly, I 10 felt very positive things about the ASME. It's reassuring 11-to hear that something that you work on, because you think 12 it's important, is being used and useful in the industry. 13 We're only really talking about how we implement parts of it 14 and the impact on the code. But the comments and the ) 15 feedback and the different comments from the audience and 16 the different people was very much appreciated. And some of 17 them will be useful to us. This is an unusual format for 18, us. Usually, we work within ourselves. We develop codes 19 and standards, and they go forward. And somebody implements I 20 the codes and standards, because we've done the right thing. 21 This format is a little bit -- the next step. We're 22 actually discussing the implementation process here to a 23 -larger. extent. So, it's not exactly a comfortable forum for 24~ uc or a form that we're used to dealing in, but it's one i 25 that we did some learning in. l l l {)T ANN RILEY & ASSOCIATES, LTD. Court Reporters s 1025 Connecticut Avenue, NW, Suite 1014 1 2 84 b3 k_

l 160 1 .Some of the things that.I learned about clearly } 2 was the status of some of the risk-based inspections that 3 are going forward. I'm glad to hear that. Some of the l_ 4 costs I was somewhat surprised at. I'm not sure that I was 5 glad to hear that,.but we do not do a cost benefit analysis 6 specific in our standards. We do have a process where we 7 'think about'it. There used to be a process in the ANSI 8 nuclear standards support, where they did an estimate; but, 1 9 I think based on some' actions of yesterday, maybe that would 10 be replaced. L 11 I do think, based on what I heard today, that the 12 10 year interval for update of the ISI code still has a 13 useful purpose. I believe it worked for the utility, in 14 tsem6 of consistency, in terms of training for its r^g (' j 15 individuals that are on the code committees and learning, j i 16-and I do believe that it helped the utility do a strong self { 17 assessment. I did not look at the cost side of it. 18 I think it was helpful for the NRC. I believe it i 19 gives you insurance and regulation and consitency that 20 you've done as much as possible to get to all the same 21 regulations. It is clear that there is still different 22 levels of code out there, absolutely. And I think it helps 23 the ASME meet its mission of promoting the art and science 24-of engineering and helping set safety standards. It looked 25-like it was something that helped in all those arenas. I I p) _ ANN RILEY & ASSOCIATES, LTD. (_ Court Reporters i ' 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l

161 1 looked'at the ACRS report and I noticed it was interesting that they wrote that the experience suggested the inspection 2 3 technology is not so static and mature that the 120 month 4 update is unnecessary. 1 5 I believe that the ASME is a living code. I i 6 believe there are safety advances that need to be made, will l l 7 be made. I believe as the plants get older, that, frankly, 8 we need to -- this is a good process. This is not the only 9 . process, but this is a very good process to update our codes 10 and standards. 11 Alex mentioned that he thought that there would 12 not be a long-term negative impact on the codes and 13 standards. I'm not sure that I agree with that. I'm not 14 sure that I agree with that. Being in the codes and 15 standards committee, I hear what the volunteers say and I 16 . agree that the volunteers will-want to continue. I'm not 17 sure their management will let them continue. I'm not sure 18' the decision will be theirs, when they see that the process 19. has been made less required, I guess I should say. 20 I would like to thank, again, Dick Wessman, Tom 21 Scarbrough, the NEI, the people who came today, and all the 22' interested parties. It's been a good forum. We will 23 prepare our comments in writing by 6/28, which I believe is 24 the due date for you, and get -- and provide them in writing 25 .after they've gone through our process internally.

Again,

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p -- 162 1 very good day. Thank you all very much. It was worthwhile, f (' } 2 MR. SCARBROUGH: Thank you. Brent's office have \\_/- 3 anything,_since you had a presentation this morning? Brent 4 -Metrow, did Brent leave? Yes, he did -- oh, Brent, did you 5 have any last words.that you want to say? 6 MR. METROW: We will provide comments by the due 7 date. 8 MR. SCARBROUGH: Okay, thank you. Also, I want to 1 ) 9 thank everyone fro coming and participating and your 10 patience and your professionalism. Dick Wessman has a few 11 closing remarks and topics _he wants to mention, as we wrap 12 up. l 13 MR. WESSMAN: Thanks, Tom. I want to at least 14 pick off a.few things from the notes that I made to help () 15 remind us of what at least some of us took away as some of { 16 the important issues. I'm not going to wallow through every 17 item, item by item, because I think we all have planes to 18 catch and those of us here in Washington have to go back to 19 work. 20 And we-had about 40 people or so from the public 21 and the industry,Jand 15 members of the staff or so here, so 22 we had a good group. And I think we, also, discovered there 23 are some very strong views out there. The word " emotional" 24 was mentioned a couple of times and there are strong views, ' 25 in the staff, in the industry. And it's a real tough issue >~% ANN RILEY & ASSOCIATES, LTD. (,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l l. L

1 163 1 that'we're working on._ But, without getting ourselves f'Ap 2 around the table like we did, even if it does look like a 3 . code meeting, it's -- we can't get these issues shared and 4 put on the table with each other. 5 A couple of things that I did take away, at least, 6 from the remarks, as I turn my notes here: I think quite 1 7 clearly -- and if I've misquoted someone or one of the 8 organizations, when I get to the end, straighten me out, if 9 you will'. I'think John helped start us off with the 10 suggestion'that from the ASME, we should not go forward with i 11 eliminating the 120 month update process, and he pointed out 12 the living document of the code and the importance and 13 benefit of the technical. groups in ASME, and that the 120 14 month update process assures a relative level of consistence 15 across the licensee community. 16 I think Alex, as he spoke from NEI's perspective 17 and the industry's perspective pointed out some of the j 18 burdens of the continuing update and the belief, I think, 19 that's held by many folks, that the plant safety is there. 20 There plants are safe enough and it's demonstrated safe 21 'enough with the code of 1989 that's established for them. 22 We had a number of other individuals, some of them 23 representing themselves and some representing their 24 ' organizations that spoke. And one member of the state, 25 Brent Metrow, even though he came from Illinois, he spoke as ,q ANN RILEY & ASSOCIATES, LTD. ' \\~,) Court Reporters t 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F ~ 164 1 himself. But, we need those state views. And if we can get (h 2 some more views from members of the state community or the V 3 insurance community, I hope we're successful at hearing a 4 little bit more on that. 5 As we' looked at our 10 bullets, I think we did 6 spend a fair amount of time on the first two. And a couple 7 of times we've expressed some concern, did we loOk hard j 8 enough at safety, because we did do a lot of talking about 9 burden and economics. I think we did. We set it aside and 10 then moved on, because of the other nine bullets. But, I 11 think we heard some strong assertions that safety is i 12 preserved, if this 120 month update is eliminated.

And, 13

-yet, there was clearly-concerns about whether the order and i 14 uniformity-of the process.would necessarily be retained, if () 15 we eliminate this 120 month update. 16 I think there was some strong acknowledgment by a l 17 number of individuals that -- both on the staff and from the 18 industry, about the value of many of the changes that have 19 been made over recent years in the code, substantial, 20 technical, and safety improvements that are there. The flaw 21 evaluation process was mentioned, Appendix G, and some of 22 these things. And I think we pointed out that these 23 valuable improvements remain there, regardless of which way 24 the staff finally steps, regarding the elimination of the 25 120. update. . ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

{ 1 l 165 -1 We had a healthy discussion of Appendix VIII and I tf f'} 2 won't go further with that. That is a very important wt 3 initiative that's out there and there's a lot of money and a 4 lot effort that's been involved in that one. 5 As we looked at the concept of selection of a ) 6 baseline, if you could pick one or another -- we heard some 7 recommendations regarding we ought to set it at the '95 code 8 with the '96 addenda, consistent with the '97 proposed rule, 9, I think expressed by ASME and some folks; whereas the -- at 10 least some folks in the industry and NEI representing their 11 members spoke in favor of the baseline should stay at '89, 12 because 80 percent of the licensee community is there 13 already, and reaffirming the belief of safe enough with the 14 '89 code and confirming that there are safety and technical (3 15 j methods and innovations that come after that. They are 16 there and they are available for use. 17 I think then after lunch, we moved to some of the 18 . discussion about benefits and hardships and the burden 19 reduction, and I think a general view is held by NEI that 20 eliminating this requirement leads to a substantial burden 21 reduction. We discussed some of the costs that were given 22 as examples, and I have sought additional help at looking at 23 that cost comparisons. 24 I.think we've got some conflicting views out there 25 on whether.there will be more relief requests or less relief O ANN RILEY & ASSOCIATES, LTD. k,) Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

F 1 l 166 \\ 1 requests or more submittals or less submittals. John, I (T 2 think you suggested that we would probably see more relief L./ L 3 requests, as we go forward. That's one of those hard 4 crystal ball issues. It's real how to know just how that 5 will play out, depending, you know, in which path we take 6-and then what happens when the path is finally taken. And 7 as we worked on some of this cost discussion, we were 8 reminded again,--let's keep track of safety. I think that's l 9 very important. That's where it's at. I 10 As we worked on down through the bullets, we dealt 11 with some of the~ issues on whether there will be more 12 submittals or less submittals and a general view that, at-13 least as far as relief requests, going along with 10 year 14 updates,-there will be a whole lot less, because there I) 15 wouldn't be 10 year updates. On the other hand, some felt v 16 that there might be -- having more submittals or a little 17 relief requests dealing with what was characterized as i 18 individual or patchwork type of activity. 19-One place I think we reached common agreement was 20-the issue of -- on the risk-informed initiatives. It does 21 not appear that -- whichever path is finally taken on the 22' final rulemaking, these particular initiatives, they're 23 .important; there's a lot of attention towards them; but, the 24 path regarding 120 month updates will not have substantive l 25 impact. /'N ANN RILEY & ASSOCIATES, LTD. '(,,) Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

167 1 We touched briefly on whether there will be real f' 2 effects on the states or not, and I think we acknowledged C] 3 that we had limited information in this area. And then, 4 finally, as we looked at the last couple of bullets, we 5 reaffirmed -- several of us, both staff and industry, have 6-reaffirmed a couple of times the need for timoliness. And I l think it hurts us guys and it hurts the industry. We've 8 struggled in this and there's a lot of reasons and stories, 9 as the years went on. I'm sure Gil would say, when he 10 started working on the last rulemaking about eight years 11 ago, would he be working and talking on the next one now 12 eight years later, he would have said, no, can't possibly 13 be. We are. We work'each day as it comes and we work the 14 issues as they come and I'd like to think eventually, we'll (~% ( ,) 15 get there. 16 I think as part of the DSI initiative and some of 17 the discussions with the standards organizations yesterday, 18 as well as some of the things we're touch on today, that i 19 there is some optimism out there. We finally got the code 20 case reg guide out and we are working on the next round of 21 code cases. So, I think the clock in the future will look a 22 little better than the clock in the past. 23 I think that's all I really want to cover. I want 24 to say thanks to all an thanks to the staff. John, thanks 25 for pushing us into the round table format. It worked a lot k'~' ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

1 168 1 better than using that stage. And we want to get those () 2 written comments, and that closing date is the 28th of June. 3 The last chance for anybody else to add anything. 4 Otherwise, we'll let Tom adjourn us. I see two hands, but 5 John's went first. 6 MR. FERGUFON: Mine is, first, it's Alex and my 7 idea. And I' wanted to mention that at some point -- 8 MR. MARION: I did most of the work with the 9 tables. 10 MR. FERGUSON: I know you did. 11 [ Laughter.] i 12 MR. FERGUSON.: I wanted to mention that the format 13 on -- versus NEI and ASME. We're not on different sides of 14 the fence. We're all trying to do the same thing. And I ) 15 just wanted to make that point again, because I think that 16 it's a key point. 17 The other thing is, I did make one thing I'd like-18 corrected on the record. I did quote one version of the 19 code that I thought would be the best to put in, but what I 20 meant to say after that is "or the latest that is approved 21 code." That just happened to be the latest one that you 22 have approved. So, what I really meant to say is the latest 23 approved version, and I quoted the one that you were ) 24 currently working on. 25 Thank you. ) ANN RILEY & ASSOCIATES, LTD. s/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I 169 1 MR. MILLMAN: Gilbert Millman, NRC staff. In your iO 2 ib summary, Dick, you -- at-least I inferred from the summary l -3 that certain conclusions had been achieved at this meeting. 4 I don't believe that that's true. We may have discussed 5 those items and laid the points out. For example, the issue 6' of whether the '89 edition represent adequate safety, the 7 summary indicated that it did. I don't believe we concluded 8 that here and I don't believe that is a conclusion that may 9 be drawn either. 10 In addition, even with something as obvious as the 11 risk issues -- the risk code cases, the indication from the 12 summary was that we concluded that the risk code case 13 implementation was unaffected by the particular edition or 14 addenda. That may turn out to be true, but that's not a h] 15 conclusion that is outside of this discussion. It's simply l 16 something that was discussed and that seems to be the way 17 it's going. But, it's not the conclusion of an overall 18 consideration of it. 19 MR. WESSMAN: Thanks, Gil, and he's exactly right. 20 This meeting was not to form conclusions, and if I left that 21 impression, of course, I don't want to do that. I, in a 22 couple of cases, indicated where at least several l 23 organizations or several groups kind of thought the same way l 24 about a certain thing. But, today is not conclusion time. 25 We do not have the written comments. And the staff will (N ANN RILEY & ASSOCIATES, LTD. '(#) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.-20036 (202) 842-0034 I

F; c. 170 f 1 work on reconciliation and' disposition of the' comments, when [; 2 we get them. And there is a very.early process for that. 'O 3 So,'yes, exactly right. 4 MR. HERMANN: Dick, I just had one other one. It 5 seemed that one thing that may have got left out of the 6 summary that I thought I heard today from a number of 7 participants, in terms of safety improvements, that there 8 were no large safety-improvements in the code, but there 9 were many smaller safety improvements. If you looked at .10 ' them individually, in terms of a benefit, they might not be 11 there. But, if you took it over 10 years worth of code 12 work, they might be significant. 13 MR. WESSMAN: Okay, good. Thank you. Let's go 14 for one last chance around the room and then the airplanes i 15 will start departing. I see one hand back there. 16 MR. SIMOWITZ: Hi. My name is Rich Simowitz from 17 PECO Energy. And I just wanted to make a personal comment, 18 based primarily on my observations of what has transpired 19. today, but also on my 30 some years experience in the 20 industry and 20 some years experience with these codes and 21 regulations. 22 We discussed primarily today whether we should 23 continue to mandate 10 year updates or whether we should 24 eliminate the mandatory 10 year updates. And predominantly, 25 the discussion involved the impact on two of the r"N ANN RILEY & ASSOCIATES, LTD. )- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

171 1 stakeholders, namely the utilities and the regulators. From ('*)\\ 2 what I observed, my belief is that whether we maintain those c 3 updates or eliminate those updates, licensees, ISI and IST, 4 and repair, replacement programs will look the same at the 5 end, regardless of which path we follow. Given that to be 6 true, I contend that the impact on the two stakeholders, the 7 regulators and the utilities, will be identical. Therefore, 8 the impact on safety will be the same. 9 What we haven't mentioned enough of, I believe, is 10 the third major stakeholder, and that is ASME. And the 11 trilogy of stakeholders, ASME, regulators, and utilities, I 12 think, have been successful to date in maintaining safe 13 plant operations. I, personally, believe that ASME's effort 14 will be affected by virtue of examples that have been given I 15 -earlier. Gil's example of an effort that emerged in ASME, L 16-that everyone jumped on, because they knew beyond a doubt it 17 would be mandated by the 10 year update. 18 I have another example kind of converse of that, 19 namely the IWE/IWL effort. That is the only portion of the 20 ASME code that has ever been specifically excluded from the 21 regulations in writing by the regulators time and time 22 again. Given that precedence, people in the ASME committee 23 thought it would never get endorsed and nobody cared about 24 it. Nobody gave it any attention and it finally got 25 endorsed in a format that is impractical to implement. ()T ANN RILEY & ASSOCIATES, LTD. (, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

172 1 Then, everybody jumped on it. I believe that's an example t ' [-) 2 of what will happen, if this mandatory update is done away 3 with. If that happens and one of those three stakeholders 4 suffer, then I think the most important stakeholder will 5 suffer, and that's the public. 6 That's my comment. 7 MR. SCARBROUGH: Okay. Thank you. With that, 8 we'll wrap up. If you didn't put'your mailing address on 9 this, you'll probably getting a phone call from us, just so 10 we can get your mailing address. We can mail you the 11 summary and we'll have that in a few weeks. 12 Thank you. 13 [Whereupon, at 3:48 p.m., the workshop was 14 concluded.] (~) "\\m,/ 15 16 17 18 ) 19 20 21 i 22 23 24 i 25 l l i [~'l \\ ANN RILEY & ASSOCIATES, LTD. i \\~- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l REPORTER'S CERTIFICATE This is to cercify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: NAME OF PROCEEDING: PUBLIC WORKSHOP ON SUPPLEMENT l TO PROPOSED AMENDMENT TO 10 CFR 50.55A ON ISI/IST PROGRAM UPDATE REQUIREMENT l CASE NUMBER: PLACE OF PROCEEDING: Rockville, MD 'were held as herein appears, and that this is the original transcript thereof.for'the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting'by me or~under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. Co/\\ \\ J Hundley Official Reporter Ann Riley & Associates, Ltd. O}}

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