ML20210Q535
| ML20210Q535 | |
| Person / Time | |
|---|---|
| Issue date: | 08/27/1997 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3007, NUDOCS 9709020020 | |
| Download: ML20210Q535 (70) | |
Text
-
Official Transcript cf Proceedings
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O NUCLEAR REGULATORY COMMISSION
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Title:
Materials and Metallurgy and Severe Accidents Subcommittees Joint Meeting TRO4 (ACRS)
RETURN ORIGINAL TO BJWHITE 4
Docket Number:
(not applicable)
M@.g2s2s THANKS!
l Location:
Rockville, Maryland
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Date:
Wednesday, August 27,1997 l
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UNITED STATES OF AMERICA e-2 NUCLEAR REGULATORY COMMISSION
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3
+++++
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
JOINT MEETING 6
SUDCOMMITTEES ON MATERIALS AND METALLURGY 7
AND 8
SEVERE ACCIDENTS 9
+++++
10 WEDNESDAY 11 AUGUST 27, 1997 13
+++++
13 ROCKVILLE, MARYLAND l
x /
14 15 The Subcommittees met at the Nuclear 16 Regulatory Commission, Two White Flint North, Room T2B3, 17 11545 Rockville Pike, at 8:30 a.m.,
Robert L.
- Seale, 18 Chairman, presiding.
19 20 COMMITTEE MEMBERS:
21 ROBERT L.
SEALE CHAIRMAN 22 MARIO H.
FONTANA MEMBER 23 THOMAS S.
KRESS MEMBER 24 DANA A.
POWERS MEMBER
-s
/
25 WILLIAM J.
SHACK MEMBER NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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ACRS STAFF PRESENT:
rs 2
AMARJIT SINGH
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3 ALSO PRESENT:
4 JACK STROSNIDER S
TIMOTHY REED 6
EMMETT MURPHY 7
STEVE LONG 8
JOE DONOGHUE 9
CLIVE CALLAWAY 10 JOE HOPENFELD 11 12 13 x~/
14 15 16 17 18 19 20 21 22 23 24 rN
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A-G-E-N-D-A i
ry 2
Acenda Item Pace
()
3 Opening Remarks 333 4
Staff Opening Statement 5
Jack Strosnider 324 6
Interim Safety Evaluation Report 7
on BWRVIP-05 8
Timothy Reed 324 9
Summary Remarks 10 Jack Strosnider 367 11 Open Discussion 374 12 13
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's 14 15 16 17 18 19 20 21 22 23 24 6
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25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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P-R-O-C-E-E-D-I-N-G-S 2
(8:36 a.m.)
)
(
3 CHAIRMAN SEALE:
Good morning.
The meeting 4
will now come to order.
5 This is the second day of a meeting of the 6
Joint Subcommittees on Materials and Metallurgy and Severe 7
Accidents.
8 Yesterday we heard from the staff about the 9
BWRVIP-05 activities and the report that was written by 10 that group and some parts of the staff's evaluation of 11 that report.
We will discuss the reporting of our hearing 12 on that ta the full cominittee later on this morning.
13 In the afternoon we heard about the staff's
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14 efforts in the steam generator integrity area.
We got 15 down to the point where Mr. Strosnider was ready to 16 provide a response to previous ACRS comments on steam 17 generator tube integrity.
We will, later this morning, 18 hear about a few other issues having to do with GSIs 163 19 and 190, and then as I said, go over the results of the 20 two days of discussion to decide what our responses to the 21 staff will be and what kind of report we wish to provide 22 to the full committee.
23 This is a continuation of yesterday's meeting 24 and all of the formal requirements of subcommittee
!sr w) 25 meetings are being met as outlined yesterday morning.
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I guess we'll proceed with the meeting and 2
I'll call on Mr. Jack Strosnider.
O 3
MR. STROSNIDEh, Good morning.
Thank you.
4 Jack Strosnider from the staff.
Actually, we're going to 5
have Tim Reed cover this next subject on some of the
/
6 outstanding issues that have come up in prior meetings.
7 CHAIRMAN SEALE:
Okay.
9 MR. STROSNIDER:
Following that -- well, thero 9
are a couple of other issues and I would like to make some 10 concluding remarks when we've gone through all of that, 11 but basically, where I think we need to go from here.
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12 MR. REED:
Let me just make a few introductory 13 comments here about what we're trying to accomplish with 14 this presentation.
First, I'd like to identity and 15 hopefully clarify the issues that have been open and still 16 remain open, with our efforts to revise the regulatory 17 approaches, 18 You're aware, we start with the rule; now 19 we're in the Generic Letters.
Some of these issues may 20 have been more applicable under the rule, now may not be 21 applicable.
We're hoping to clarify that.
22 I'd also like to hopefully, identify whether 23 what we've presented in the last day and also the 24 information we've provided to you, if that's helped to 25 resolve any of these issues, and if possible, finally, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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identify anything that remains open or anything new that 2
you identify as an issue.
,s
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)
3 At previous meetings and in at least two 4
different letters, ACRS has identified issues based on 5
your reviews -- this committee's review of information 6
that was presented to you over the last couple of years.
7 What I've tried to do is, the best I understand it, 8
identify these issues generally.
9 This comes from a document, a memo that was 10 provided based on 6/12.
I don't know if you have that 11 if you can hand that out to the committee or not.
This is 12 basically a synopsis of what I think are the areas or 13 where the open issues are.
If they're not, we can
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14 certainly change that or work with whatever additions you 15 want to add.
16 The first one is this as the relationship of 17 regulatory approach to risk.
There were quite a few 18 questions of the way we handled risk regionally.
As you 19 remember, we had a rule, we had just one structural 20 integrity reg. guide at the time and there were a lot of 21 concerns about how that reg. guide was written, use of 22 defense-in-depth, this relationship to risk objectives and 23 that kind of thing.
24 As you were aware, we've changed this approach
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look at that issue here.
2 Another concern ACRS had was allowing
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3 licensees to consider risk versus simply a calculation of 4
frequency.
Finally, there was several concerns or issues 5
with regards to the performance criteria.
6 I've listed here four that I'm aware of:
7 whether the standards for complying with performance 8
criteria are clear -- I think that refers to the guidance 9
in the DG-1074, the structural integrity reg. guide; 10 whether in fact, the structural performance criteria and 11 safety factor of three are appropriate -- and that was 12 with regard to industry's proposal of a factor of three; 13 whether in fact, when you exceed the operational O)
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14 performance criteria what kind of actions should this 15 Agency pursue as far as inspection and enforcement, or 16 what was appropriate for us to do in those circumstances.
17 And a basis of the allocation of this 18 conditional burst probability to a given defect mechanism.
19 Those are the issues I'm aware are open in performance 20 criteria.
21 Also you had a comment or recommendation that 4
22 we should look at whether -- you called it -- I don't know 23 exactly your terminology but I refer to it here as the 24 pre-approval approach versus the more traditional, send it
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25 in, we'll review it and approve it, approach for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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proceeding with -- or handling this thing on a regulatory 2
basis.
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What that means is that, you know, 4
traditionally when you do stuff you have a] ternate repair 5
criteria sent into the staff, we review and we approve it, 6
and there's a resource expenditure, both in terms of 7
industry and the staff in handling that.
8 What we've done is now is, we've developed a 9
reg, guide.
It's kind of, if you will, kind of a pre-10 approval if you will.
It's like an SER sitting out there.
11 If you following this thing, you know, from a structural 12 standpoint we'll say it's okay.
And it was to examine 13 that issue.
Oksl 14 Finally, I think it was in the November 20th s
15 letter attached to that, there were some issues with 16 regards to the DPO, We discussed those yesterday.
And 17 finally, I think it was Dr. Powers who didn't like the use 18 of the terminology " reasonable assurance" -- at least the 19 way it was originally, and DG --
20 MEMBER POWERS:
Reasonable assurance is fine 21 but you just have to tell me what it is.
22 MR. REED:
Okay, that -- excuse me.
23 CHAIRMAN SEALE:
Uncertainty in the term of 24 that.
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i 25 MR. REED:
Okay.
Yes, the way we've used it.
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CHAIRMAN SEALE:
You're aware of the 7
s.
2 discussions that another subcommittee are planning this
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3 afternoon on --
4 MR. REED:
Actually I became -- just this 5
morning I was aware of that.
6 CHAIRMAN SEALE:
On defense-in-depth?
7 MR. REED:
Yes.
8 CHAIRMAN SEALE:
And you're certainly invited 9
to be there.
Because we' re ver/ concerned about this for 10 a variety of reasons.
Tom, you may want to make another 11 committee comment on that.
12 MEMBER KRESS:
No.
13 CHAIRMAN SEALE:
Okay.
'w I 14 MEMBER POWERS:
He's reasonably confident that 15 16 CHAIRMAN SEALE:
You've resolved these issues?
17 MEMBER KRESS:
Yes, got thtm under control.
18 MR. REED:
Let me just start by saying that 19 most of the issues that have been identified in the past 20 either involve the issue of how we handle risk or they 21 involve development application of alternate repair 22
- criteria, 23 That being the case, as far as the current 24 generic letter goes, I view the current generic letter in O)
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25 its current form as more of a compliance-based, fix the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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tech spec type of approach.
And that means that a whole f3 2
lot of these issues don't apply to the generic letter as
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3 it stands today.
4 I'm not sure it makes you feel real good, but 5
as far as the issues that really directly pertain to what 6
we have in the generic letter right now, two directly 7
pertain -- and that means to the deterministic performance 8
criteria as a matter of fact, also, Dr. Shack -- but 9
anyway, two directly pertain.
10 One is the safety factor of three, which 11 Emmett discussed in his presentation yesterday; that the 12 staff and its contractor had taken a look at that and had 13 come to the conclusion that the appropriate safety factcr k-)
14 in accordance with the ASME code should be a factor of 15 three.
16 I believe Emmett also said, we're going to 17 make that contractor's report publicly available along 18 with the rest of the package.
So that issue was addressed 19 as far as Emmett's presentation.
I'm not sure if the 20 committee wants to -- if you want tc you can just break in 21 and tell me whether in fact, you think that remains open 22 or not.
I don't know how you want to handle this, 23 Chairman Seale, but nonetheless, that issue was addressed 24 yesterday in Emmett's presentation.
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25 The second issues I'm aware of that --
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MEMBER POWERS:
But understand it, it was 2
simply an assertion.
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3 MR. REED:
Yes.
4 MEMBER POWERS:
I mean, it was -- we just i
5 said, ah, we thought about it, we were right, it was a l
6 factor of three.
The problem is that the industry thought 7
about it and was a factor of 2.4.
I mean, I can't judge 8
the quality of thinking, okay.
It seemed that the 9
industry had a pretty persuasive point.
10 MR. STRCSNIDER:
Jack Strosnider; let me make 11 a comment on this.
I understand what is said.
The staff 12 thought about it and we concluded that the factor three 13 represented what was in the -- the industry reached a
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14 different conclusion.
When we talked about the contractor 15 assessment we really looked at that as an independent 16 assessment.
17 We provided that contractor who had a great 18 deal of experience on the code and working with the code, 19 both the staff's thought and the industry's thought, and 20 we said, you go off and independently analyze it.
Got 21 some interesting feedback on that.
It's documented on a 22 report which you haven't had the opportunity to see yet, 23 but that -- or I don't know.
Was the draft report 24 included in this package?
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25 MR. REED:
No.
No, we didn't have a good NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHCDE ISLAND AVE., N W.
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enough report --
73 2
MR. STROSNIDER:
We can provide that but
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yes, we understand people need to look through that report 4
and it's a very comprehensive discussion of the history of el 5
the code, how the factors of safety were developed, what 6
their intentions were.
7 So what we're suggesting that we did to 8
address this issue is, we went out and got some 9
independent assessment of it.
That independent assessment 10 concluded that the factor of three is correct.
In fact, 11 there is even a suggestion that the factor on accident 12 loadings was lower than what was implicit in the code, yet 13 we don't think that we need to raise that.
/^N 14 But what we're putting out and what will go 15 out with the public comment package is that assessment so 16 that people can look at that and reach their judgment, 17 And it does provide much more detail on the thought 18 process.
We haven't gone through that in this meeting but 19 that's probably an hour or more presentation on its own.
20 MEMBER SHACK:
But this is the Talmudic as to 21 what the code really intended, right?
How much safety 22 factor you really needed.
23 MR. STROSNIDER:
Right.
24 MR. REED:
Okay, the second item here, the (3
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25 operational leakage performance criteria, I believe the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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committee's concern here was that just simply seeing
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operational leakage performance criteria in and of itself 2
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shouldn't be a reason for the staff to jump in and do 4
inspections and the like.
In fact, the real criteria 5
ought to be whether in fact, if you shut down because of 6
leakage, that result is that you go and identify a problem 7
with a structural -- or accident leakage criteria, not 8
operational.
9 Our response to that is that, as I think you 10 were aware yesterday, we still have an operational 11 performance criteria that corresponds to the LCO in the 12 tech specs as it is today.
The staff believes that's a 13 reasonable limit, first of all, reasonable forms criteria.
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14 Any time you set up performance-based kind of regulatory 15 framework, what you need to do is set tripwires, I'll call 16 them.
17 In other words, we're going to stand back and 18 we'll put the tripwire there and when licensees cross the 19 tripwires we become more involved.
It's the nature of 20 performance-based regulation that you need to have this 21 xind of & criteria set up.
We believe it's reasonable for 22 us to become more involved with the licensees activities 23 at this threshold -- this operational performance criteria 24 is a reasonable threshold.
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(,j 25 And I might say that anything the staff does NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE N W.
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as far as its activities at that point will be a futiction 2
of what we find.
Its other words, our inspector will be (p) 3 going to look at licensee's activities and our activities 4
to determine what the problems were, why the occurrence 5
happent.d, why they exceeded the performance criteria, 6
their corrective actions.
7 That's basically what we'd be doing --
a watching what they do to find the root cause of the 9
problem.
Any enforcement of that we would take would be a 10 function of whether they could reasonably have avoided it.
11 It wouldn't be our expectations to simply, because you j
12 exceed a performance criteria, to take enforcement action.
I 13 It would be a function of why you exceeded the performance (V
14 criteria.
Could you rcasonably have avoided it or not.
15 MEMBER KRESS:
When you set tripwires like 16 that, they' re based strictly on engineering jt igment and 17 experience, right?
18 MR. REED:
I think that's a safe assessment, 15 yes.
I mean, operational leakage is a very good indicator 20 21 MEMBER KRESS:
Yes, I'm not questioning that.
22 I just wanted to make it clear to everybody that that's 23 what to do.
It's probably the only way to set tripwire.
24 MR. REED:
It's considered to be reasonable,
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25 it's tolerable --
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MEMBER KRESS:
Short of having a real risk 2
analysis and risk tripwire, why that's probably the oest (7\\
3 way to do it.
It's based on judgment and consensus of 4
4 opinion.
5 CHAIRMAN SEALE:
Well, the real concern hern 6
is having performance criteria, hopefully that has some 7
graded nature to them.
That is, more --
8 MEMBER KRESS:
Oh, yes.
You want 9
CHAIRMAN SEALE:
-- than one.
10 CHAIRMAN SEALE:
-- to have the tripwire be 11 something that's still tolerable.
l 12 CHAIRMAN SEALE:
Well yes, graded so that 13 there's a threshold and then perhaps, higher levels of (D
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14 severity.
But in any case, they need to be, as you 15 indicated earlier, they need to be datectable and they 16 need to be tolerable.
And I think there's a great deal of 17 visceral uneasiness with reliable measures of that sort.
18 And I mean, when I say measures, the plural, that's part is of the difficulty we're having here with this.
20 MR. REED:
I mean, once you're at operation 21 ithis is it; this is what you've got to look at.
You've 22 got operational leakage across your tubes; that's your 23 indic1 tor.
And so --
24 CHAIRMAN SEALE:
Well, it's an indicator.
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25 MR. REED:
Yes, I mean --
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CHAIRMAN SEALE:
And maybe different levels 2
constitute gradations, but maybe there are other
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indicators, too.
4 MR. REED:
So I mean, so it's the one we're 5
going to use.
You know, we think it's reasonable, it's 6
the one %
would use to determine whether in fact, we 7
should get involved more with these activities on the 8
project.
9 MR. STROSNIDER:
Jack Strosnider.
I think one 10 of the key issues here was the concern expressed by the 11 industry that every time you crossed one of these l
l 12 performance criteria --
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13 MEMBER KRESS:
Yes, you include it with AIT (O)
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14 15 MR. STROSNIDER:
-- that you have enforcement 16 space, and that is not the intention.
The point here is 17 that if you exceed the performance criteria we want to 18 know about it and we want to understand why.
My thought 19 is that when we get a report that someone has exceeded the 20 performance criteria the first thing is probably a 21 telephone call that says well, what happened; how do you 22 think it happened?
If it's going to take you some time to 23 assess it, fine.
24 Yes, if it turns out that there was some gross
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25 breakdown in their program -- they were using an v
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unqualified inspection program and that resulted in some n
2 leakage -- there may be grounds for enforcement.
3 We recognize though, in the steam generator 4
business, that things can come up during the cycle that 5
weren't anticipated, could not have been reasonably 6
anticipated -- new forms of degradation, that sort of 7
thing -- you know, if it's comething that you had a good 8
program in place but the unexpected comes along, that's 9
not a basis for enforcement.
So there has to be this 10 degradation, this consideration of the actual 11 circumstances.
12 But the thing that we are pointing out is that 13 these performance criteria are -- when they're -- if V
14 they're crossed, are things that will get our attention 15 and we will take a look at it and try to understand it, 9
16 and basical]y make sure that the licensee understands it 17 and has taken appropriate actions, 18 MR. REED:
Okay.
Another issue -- the 19 remaining issues I guess, as I referred to them -- the 20 ones I think refer generally to risk and also to alternate 21 repair criteria.
I broke them this way becauae you don't 22 have the 1073 yet -- the risk guidance -- and alternate 21 repair criteria as it's currently built into the generic 24 letter require a risk assessment.
So that kind of option OV 25 of the generic letter is sitting out there; it's not NEAL R. GROSS COURT REPORTERS AND TRANSCillBERS 1323 RHODE ISLAND AVE., N.W.
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really in place yet.
2 But the issues that have been raised to date 7
't
/
3 ao far as that goes is, the relationship of what we were 4
doing in the steam generator rule, this was raised and a 5
draft at that time of our tube integrity reg. guide, how 6
that works as far as risk.
7 We've developed a reg guide that was pretty 8
much -- shows you how to develop and implement alternate 9
repair criteria, tells you how you to go and assess the 10-condition of the tube.
It was basically a reg. guide that 11 'was largely focused on ensuring tube integrity.
It fit 12 with pretty much the way we're doing the compliance l
13 generic letter today.
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14 What we've done now as you're well aware, is l
I 15 we've broken this thing into two pieces.
We have a i
16 structional integrity reg. guide and a risk reg. guide.
17 And the risk reg. guide now is following the 1061 18 guidance, and changes to the licensing basis, i.e.,
19 changes to the repair criteria now require a risk 20 assessment and that risk assessment will follow along the 21 guidance of 1061 and 1073 when you receive that.
22 So that we have a revised approach.
I think 23 that -- I believe that will address most of the issues 24 that you had with the way we had structured the reg.
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risk objectives and the like.
It's following what I think 2
is a reasonably approved approach 1061 as far as the
-~
3 committee's concerned.
So that should address it.
4 And that's why I've broken it apart as far as, 5
you know, the risk stuff is going to follow a 1061 6
approach and it's going to be in 1073, and the structural 7
integrity stuff, the compliance stuff, that follows the 8
structural integrity reg. guide.
So we've got them in two,
9 bins, if you will.
I think chat addresses a lot of those 10 concerns that you had.
11 Another issue that was raised was the iusue 12 that we were focusing largely on the calculation of large 13 ear!.y release frequency --
(_)
14 MEMBER KRESS:
Beforc you get to that, I'm 15 kind of interested in that second sub-bullet.
16 MR. REED:
Okay, probably this.
17 MEMBER KRESS:
Well, yes.
I find it 18 interesting that basically, the i.e.,
is in essence, 19 defining defense-in-depth as the sentence before it --
20 that you comply with the current regulations and meet all 21 the GDCs, Part 100, and other standards.
22 MR. REED:
Yes, that's Tim Reed's definition.
23 MEMBER KRESS:
Well, I think basically, it's a 24 good definition, frankly.
(3) 25 MR. REED:
When you guys. laid -- I didn't
/
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realize -- this afternoon --
2 MEMBER KRESS:
That's why I find it (3) 3 interesting.
4 MR. REED:
Yes, I put that on the slide; it 5
was my thought.
It-'s kind of what I hear us saying during 6
t.hi s - - in the entire effort, and I understand you guys 7
are going to put this real hard --
8 MEMBER KRESS:
See, we happen to have another 9
structure list --
10 MR. REED:
I mean, we've really, I think, 11 looked at it as, you know, what is tube integrity.
Tube 12 integrity is meeting the GDCs, you know, meeting Part 100.
13 It's basically the regulations as they stand today, and we
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14 implement using the ASME code basically built into the 15 tech spec, and that's -- if you want to call that defense-16 in-depth -- that maintains defense-in-depth.
17 MEMBER POWERS:
Well, I mean, the fact is --
18 MR. REED:
It's not perfect, but that's kind 19 of the definition.
20 MEMBER KRESS:
I agree with you.
21 MEMBER POWERS:
The fact is that the ASME code 22 enforces the prevention part of defense-in-depth.
The 23 compliance with Part 100 enforces the mitigation part.
I 24 mean, that's the structure that you've called out there, f}j 25 And it's a fine definition -- I mean, it's not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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inconsistent with current thinking.
2 The question that gets addressed this 7s t
)
'~
3 afternoon, is this the appropriate thinking now that we 4
have moved to a more risk-based regulatory profile?
5 Because there's an alternate view of -- there are the sage 6
thinkers in this wor]d that are called the structuralists 7
like yourself, and then there are these wild men that 8
happen not to be in the room right now, that are called 9
the rationalists.
10 And their view is a little bit different on 11 this.
They would go through and say, I only need that l
l 12 part of defense-in-depth that's necessary to keep me out l
13 of great uncertainties.
(~)
is/
14 MR. REED:
I mean, for what it's worth, my --
15 I guess where I come from on this is, you know, having 16 been -- worked at the vendor for seven or eight years, and 17 my experience was in accident analysis, and also in the 18 design basis.
But in accident analysis we basically -- we 19 looked at Chapter 15.
We looked at how the equipment es 20 it was designed, how it performed.
21 The designers over there, they looked at GDCs, 22 the ASME code, ANSI Standards, everything out there --
23 designed it to meet all that -- and then looked at, what 24 are the functional requirements this thing has to do to
('
(,T) 25 meet whatever it is -- Appendix K, 5046, whatever it is, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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okay, Part 100, oka'?
And they tried to build that all 2
into the design.
I
~#
3 We then assessed it.
We assumed that, even 4
though you designed it -- okay, you designed reactor 5
coolant pressure boundary not to fail, the containment, 6
everything else -- we're going to look at it and see, what 7
if it does fail, what if it does leak at the worst case?
8 So that's another level of defense-in-depth.
It's like, 9
okay, you designed it not to fail, we assume it to fail 10 and see if you still mitigate it anyway.
Let's build that 11 into it, too:
negation capabilities, what happens if the 12 worst does occur -- is it still okay?
13 So I look at all that toge+.ner as being
(^N, l
14 defense-in-depth, and that's why ic's a little more subtle 15 than simply just saying, Part 100s.
It's all the accident 16 analysis that goes into supporting when you meet Part 100 17 also.
18 MEMBER KRESS:
Not a bad view.
19 MR. STROSNIDER:
This is Jack Strosnider.
I'd 20 like to make a comment in this area because it's an 21 important issue and we've been thinking about it quite a 22 bit in terms of steam generators and other issues --
23 vessels as you heard yesterday.
24 He made the comment earlier about setting
,rx()
25 these tripwires or performance criteria -- I'm going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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paraphrase -- based on some experiential -- you know, some 7-2 experience and engineering judgment, if you will.
The i
)
3 ASME code to a large extent, reflects that.
4 I mean, it's very easy for the regulator to 5
say, well it's ASME code, therefore it's okay.
But 6
there's really more to the story than that.
There's a lot 7
of people there, it's a consensus document, there's a lot 8
of experience factored into it -- that give you some 9
confidence that in fact, you have some margin there, some 10 defense-in-depth.
j 11 Now, we've provided for the option to go to 12 something different, to do to something which is more 13 risk-informed and would allow, with the proper risk
(~'N
\\ >i 14 support, to go to something different than what's in the 15 ASME code.
16 The important thing there is that, before you 17 take that next step you have to make sure that you have, 18 as you pointed out, a risk assessment that you can perform 19 with enough confidence, all right, so that the 20 uncertainties in it are covered such that you still 21 maintain some -- or you have to maintain some margin for 22 the uncertainties -- I guess that's the important thing.
23 We talked yesterday on the vessel issue, about 24 flaw distributions and the uncertainties in the various p3(,)
25 input parameters and that sort of thing, and I think it's NEAL R. GROSS COURT REPORTERS ANC TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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343 4..
1 important to look at those and say well, do I feel 2
comfortable enough in what's going in there that I still 3
'-)
3 have that appropriate margin defense-in-depth, or --
4 MEMBER KRESS:
Well, I tell you what bothers 5
me a little about that, and that is, when you go that 6
route the inevitable consequence is that you're going to 7
erode defense-in-depth.
I think : hat's inevitable.
And 8
as part of that DG-1061 there are requirements in that 9
that you will maintain defense-in-depth.
I think those 10 are inconsistent statements.
Just going the risk route, i
11 if you're actually increasing risk a little then you are, 12 almost by definition, you're eroding defense-in-depth and 13 there's some inconsistency problems I have.
(D
' s. -
14 MR. REED:
Ths.t's a challenge:
how much can 15 you do that?
16 MEMBER KRESS:
Yes.
The question is, how much 17 can you erode defense-in-depth and stay acceptable?
18 CHAIRMAN SEALE:
How negotiable is it?
19 MR. STROSNIDER:
And one other comment with 20 regard to what Tim's presenting here.
To be frank about 21 it, I mean, we point out there are a lot of issues that 22 came up in our prior discussione about risk assessment and 23 how it would be dealt with in steam generators.
To some s
24 extent, what we're saying here is we're putting that off (9j 25 to the reg. guide you haven't seen -- not claiming that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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all those things are resolved.
,ey 2
But the context of this presentation is again, t
t
'~
3 that we want to put out deterministic portion of this for 4
public comment and we recognize there's still more work.
5 So it's not in every case that we've answered the 6
question, but we've kind of divided the problem up so 7
there's more to come later.
8 MEMBER SRACK:
Well, you told us yesterday he 9
has an honorary law degree now, i
10 MR. REED:
Okay, the next issue on this slide 11 here is the issue of whether we
_id allow licensees to 12 consider risk versus simply just a calculation of large 13 early release, and that pertains more to allowing more
\\
I K/
14 realistic treatment of fission product releases.
15 And I think that this was really g,ing to, you 16 know, the steam generator probably does act as a filter, 17 and in fact, what we calculate is, you know, a la conservative calculation.
The reality is, there's 19 probably a lot less released, and whether we should 20 develop the guidance and what have you and built that into 21 this regulatory approach.
22 My answer here -- I don't know if you like it 23 or not -- but the answer is pretty straightforward.
We're 24 doing 1073 very consistent with the way 1061 is, and that
(~h
(,)
25 tells you to go calculate large early release frequency.
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That's about all I'll say on that.
I'm not sure I
,x 2
understand fully why 1061 stops at LERF, but we're i
s L) 3 following that guidance right now.
4 MEMBER POWERS:
I think the comment was only 5
asking you to do that.
As it was portrayed in the past 6
you seemed to stop, and we wanted -- the comment was made, 7
it's basically satisfied by saying going a*d tying in with 8
1061.
When the comment was made, 1061 was in a fluid 9
state to say the least.
10 MR. REED:
Okay.
That's another one, okay.
11 MEMBER POWERS:
But it's somewhat solidified i
12 now.
13 MR. REED:
Upcoming events, okay, f3 14 CHAIRMAN SEALE:
Somewhere in here you get 15 into this argument though, between design basis space and 16 severe accident space.
And whether or not in the risk 27 assessment that division is porous or permeable or 18 whatever.
19 MR. REED:
Or a brick wall.
20 CHAIRMAN SEALE:
Or a brick wall, that's 21 right.
And that -- I think that's really in many ways, a
22 much more fundamental policy question that probably at 23.
some point the Commissioner is going to have to resolve 24 for us.
,O
(,)
25 MR. REED:
It's definitely a bigger issue than NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE (SLAND AVE., N W (202) 234 4433 WASHINGTON. D C. 20005-3701 (202) 234-4433
346 1
this --
,y 2
CHAIRMAN SEALE:
Yes, that's right
- Well,
(
)
3 except that this rather graphically presents the issue.
4 MR, REED:
I think in a lot of ways, the steam 5
generator effort is like -- it's way out in front of 6
people.
You know, we've got 1061 there and PWR steam 7
generator tubes are a very important component in terms of 8
risk, and we're right out there, you know, the lead, 9
driving the point home.
Here's how 1061 would work in one 10 application -- perhaps one of the most important 11 applications.
12 CHAIRMAN SEALE:
But all the risks are working 13 on the frontier.
(D
\\ s/
14 MR. REED:
Yes.
15 MEMBER KRESS:
I think this is a better 16 example of performance regulation than it is maintenance 17 rule.
It makes it more -- is more purely performance-18 based than Maintenance Rule.
19 MR. REED:
Okay, then the last item here, the 20 committee made a comment that they weren't sure that the 21 standards for complying with the performa:tce criteria were 22 sufficient to enable licensees to determine whether they 23 were actually, I believe meeting the performance criteria.
24 I think that's your issue, because I think that the ntaff
,/'N
(,)
25 and industry both understand pretty clearly what the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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criteria are.
7-2 They may not fully agree on all of them.
I (3)
3 think there's not a big difference but they understand the 4
criteria themselves as a matter of, what are the methods 5
you use to show you meet the criteria and whether those 6
methods are sufficient to truly, reliably, detect and then 7
reliably show that you are complying with the performance 8
criteria.
9 My answer here is very simple.
Of course, we 10 bel a that DG-1074 as it's written and it's provided to 11 you, provides sufficient guidance to do just that.
That l
12 was one of the central objectives in the entire reg.
l l
13 guide.
' /~T i
)
k/
14 That is why it's 60-some-odd pages long, 15 because we tried te put enough guidance in there so that 16 licensees can develop a methodology that reliably can 17 measure the variable, whatever it is, against the 18 performance criteria.
So 1 mean, it's our view that that 19 should be a sufficient document to accomplish that.
20!.
Okay, another comment or an issue was with 21 regard to one of the performance criteria -- and this was 22 an alternate repair criteria -- related performance 23 criteria -- specifically the amount or the basis for 24 allocation of percentage of conditional burst probability.
(_,!
25 This refers to, au postulate a steam line NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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break and then you look at, what's the conditional 2
probability if you're going to fail a steam generator tube 7-^)
E.)
3 on top of the steam line break? That's conditional burot 4
probability we're talking about here.
And --
5 MEMBER KRESS:
This one is
.05.
6 MR. REED:
Yes, there was -- I think it's 5 X 4
7 10 was the total allowable number.
8 MEMBER KRESS:
Yes, and we were talking about 9
how you allocated --
10 MR. REED:
Exactly.
11 MEMBER KRESS:
-- that total among the 12 MR. REED:
Different defect mechanisms within 13 the generator.
(--)
14 MEMBER KRESS:
Right.
15 MR REED:
What I'm doing here is I'm holding 16 this issue open.
We're still in the process of kicking it 17 around, if you will.
Part of what we're doing in 18 developing the risk guidance in 1073 is, you know, looking 19 at thermally-induced events, whether in fact, this may 20 come into play.
Should that criteria be risk-informed, if 21 you will?
I don't know.
And look at what effect it might 22 have on thermally-induced stuff also 23 At this point --
24 MEMBER KRESS:
Yesterday, when you were
()
25 talking about equal allocation among the various NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVE, N W.
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degradation mechanisms --
2 MEMBER SHACK:
You've changed it already in
,r~s s
\\
()
3 1074.
4 MR. REED:
That's correct.
5 MEMBER SHACK:
You assume it's still fluid.
6 MR. REED:
Yes, I mean, I think it was 20 7
percent for a defect mechanism.
I believe what we have 8
today is a 40 percent and then we've -- I'm not sure 9
exactly how you do this, Emmett.
You have the number but 10 the total -- the total quantitative result remain the 11 aame, I bel.teve.
12 You can allow 40 percent of a number that was 13 half, so it ended up being the same.
A little bit
[,.
\\
i l
L/
14 different way of going about it but yes, it's still fluid.
15 MR. STROSNIDER:
As Tim was suggesting though, 16 I think one of the main reasons we're still looking at 17 this is, one of the things we've not yet accomplished --
la we've talked about these performance criteria, we've 19 established performance criteria that we address basically 20 the design basis events.
And in fact, with regard to 21 design basis events we th3.nk we've gone with those 22 performance criteria we're able to go, basically, l
23 performanco-based.
Here's the criteria, go deal with it.
24 However, severe ace. dent space, we haven't (3
()
25 figured out exactly what that performance criteria should NEAL R. GROSS COURT REPORTERS AND TRANSCRIPsERS 1323 RHODE ISLAND AVE., N W.
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350 s
1 be, and some of the discussion -- Division of Engineering 2
it wac talked about, well how do we allocate this between
,-~
3 various degradation mechanisms?
4 But in developing 1073 some of the discussion 5
came up that, well you know, this performance criteria 6
could also affect severe accident issues and maybe we need 7
to take a harder look at that and understand if there's 8
something we can do in that regard or there's something we 9
can credit in this performance criteria toward the severe 10 accic;ent issue.
11 So we're trying to -- that's what we're 12 dealing with, really, and that's what we're trying to get l
l 13 into 1073.
t's i
i
'x
' m/
14 MEMBER KRESS:
It sounds to me like you're 15 trying to bridge this gap between design basis and risk --
36 MR. STROSNIDER:
Exactly.
17 MEMBER KRESS:
and that's really a tough 18 gape to --
19 MR. STROSNIDER:
Exactly, and that's why it's 20 a challenge to put that kind of a guidance together, but 21 those are the kind of things we're thinking about.
22 MR. REED:
The next issue is whether in fact, 23 recommendation that the methods for demonstrating 24 conformance with performance criteria should be approved
,cx()
25 versus the what we called the pre-approval approach.
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This refers to our generating the reg guide 2
and the reg guide from a structural standpoint --
g
('
3 structural integrity standpoint this is pretty 4
important to note.
It was put there such that if a 5
licensee followed the guidance they could develop and 6
implement, alternate repair criteria without the staff --
7 if you followed the reg. guide guidance -- without the a
staff becoming involved.
9 It was basically a recipe, if you will.
If 10 you follow this, we're going to approve it, okay, so if 11 you go do it we'll inspect it and we'll make sure in fact, 12 that you followed it.
And that was performance-based.
13 I kind of look at it, this is an issue with 3(b 14 kind of a long history, because for those of you that were 15 involved with this back in 1993 when we started this rule, 16 it was performance-based.
It wasn't until about, I think 17 about 1995 that the idea of.
- -informed started to be 18 connected to it.
And this was going with the PRA policy 19 and everything.
These two trains came together and they 20 kind of collided.
21 The 1061, the way that works is, you change 22 the licensing basis and you've got to send in the risk 23 assessment.
And when you send in a risk assessment that 24 takes us out of a purely performance-based mode now.
I 25 mean, now the staff's involved in looking at comething NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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that t'se licensee has done to support their alternate
^
2 repair criteria, so you can't really call that entirely O
3 performance-based any more.
4 Nonetheless, what we've tried to do is tried
(
5 to preserve those aspects that we could and keep them
\\"
6 performance-based.
And so the structural integrity reg.
guide, to the maximum extent, is performance-based, okay,
- ~
8 from a structural standpoint.
\\
9 If we, for example, said to a licensee, okay, 10 here's the reg. guide; if you follow it that's finn, but.
11 you still need to send it in and we need to review and 12 approve it.
Well, that basically becomes the status quv 13 at that point.
There's nothing different about that mode 14 of regulation and what we do today.
15 And all I'm point out here is then the 16 regulatory approach has virtually no performance-based 17 aspects, because we're going to, in fact, look at 18 everything.
What we'd like to do is continue to have as 19 much performance-based attributes in the approach as we 20 possibly can, and I doubt that --
21 MEMBER SHACK:
But reviewing the methodology 22 doesn't seem to me to get you out of the performance-based 23 approach.
24 MR. REED:
I would say it does.
I think that, 25 if you look at an example, I think that -- I'm not sure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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this is fair example, or maybe it's not pertaining -- if
-s 2
you look at Generic Letter 95-05 where in fact, the
'~)
3 voltage-based repair critoria is developed and the 4
guidance was provided that was something that took, I 5
think on the order of about four years.
I think it 6
probably started about 1991.
It wasn't until 1995 that we 7
actually had the Generic Letter.
8 And you can look at that as being a review of i
9 the methodology that continued over years and years.
That l
10 got us into a lot of issues, and I believe that that would 11 tie up both our resources and licensee's resources l
l 12 enormously.
And --
l 13 MEMBER SHACK:
Oh, well there's no question
(~)
14 that reviewing the methodology is going to take more 15 resources.
I mean, you know, if you use the 95-05 16 example, I mean, you know, wha t-you ended up is not what 17 Farley and what the industry originally proposed.
I mean, 18 I guess the argument that's under --
19 MR. REED:
Yes, that's right.
20 MEMBER SHACK:
-- 1074 you would have accepted 21 what they proposed.
22 MR. REED:
We now I think, are smart enough to 23 know what we will accept, okay, and we've put it in a 24 document and said, here's what we'll accept.
,(,)
25 MEMBER SHACK:
I mean, are you going to go NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 RHODE ISLAND AVE., N W (202) 234 4433 WASHINGTON. O C 2000S 3701 (202) 234-4433
354 1
back and change 95-05 so it's consistent with 10747 2
MR. REED:
Number 95-05 is consistent with 3
1074.
4 MEMBER SHACK:
No, you stick some arbitrary I
5 limits on those voltages that are more strict than what 6
you come up with in 1074, don't you?
I haven't looked at 7
it in detail.
Only Emmett would know those --
8 MR. REED:
I'd definitely have to --
9 MEMBER SHACK:
-- but my guess is that in 10 fact, 95-05 -- you would end up capping the voltages more 11 than you would if you followed 1074.
j 12 MR. MURPHY:
Emmett Murphy.
Under the DG-1074 13 approach there is room to have a repair criterion that f3
~s) 14 self-adjusts, if you will, as the circumstances change l
15 with the degradation, the corrosion rates, cycle lengths, 16 that kind of thing.
The DG doesn't envision a plugging 17 criteria that's necessarily fixed.
18 The DG also anticipates that the, from the 19 standpoint of the performance criteria that you're 20 evaluating the repair criteria against, that such a 21 criteria might be deterministically-bat.
or 22 alternatively, if you had the risk assessment, that there 23 would be a probabilistic basis for a structural 24 assessment.
r-'N
()
25 But it's important to also keep in mind that N EAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.
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355 1
the draft tech specs that we talked just yesterday, the 2
tech specs provide simply that you must do a forward look, 73
('~')
3 an operational assessment, and a backward look at 4
condition monitoring assessment.
5 It says that you should use conservative 6
evaluation methodologies to arrive at conclusions as to 7
whether or not you're meeting the performance criteria.
8 It says little else.
So the specifics as to the 1
9 methodologies would not be in the tech specs.
The 10 guidance for conducting these methodologies would be 11 contained in the reg. guide.
12 MR. STROSNIDER:
I think there's some 13 consistency -- there is consistency in the draft reg.
g)
'w /
14 guide, in 95-05, in terms of the way you develop empirical 15 correlations and treat the uncertainties and that sort of 16 thing.
17 But I think you're also correct, not having 18 done a line-by-line comparison, but if you look at the way 19 95-05 evolved over time, there are some things in that 20 letter -- for example, regardless of the voltage 21 amplitude, if you confirm indications with an RPC probe 22 you take them out of service.
So there's some additional 23 things that are in there which might not be captured in 24 the draft reg. guide, and partly because of the way the
- y i
)
25 issues evolved as that was developing.
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I think your original question though, there's what we were ultimately trying to achieve was, there's 2
,7-)
~
3 a regulatory framework where the staff would not have to 1
\\
4 review and approve every alternate repair criteria.
So we 5
haven't really accomplished that because of the need to go 6
look at the risk, severe accident portion of this.
7 You make an accurate observation though, that 8
it could be that the staff ends up reviewing each 9
alternate repair criteria on its own merit.
It could also 10 be that if someone comes in and proposer a performance-11 based approach that deals -- alternative criteria that 12 deals with the severe accident issue in a more generic 13 way, all right, and if we could find that acceptable then
/
)
N/
14 we might still get out of that box.
15 So your comment that though this review and 16 approval does not preclude a performance-based approach is 17 true.
I mean, we may be reviewing performance-based 18 methodologies.
So that's still a possibility.
But the 19 big point here is that we had hoped to get completely out 20 of this loop and we just haven't figured out how to get 21 there.
22 And I had just -- I think -- just one more 23 thought on that.
Certainly from the industry's point of 24 view I think performance-based is somewhat synonymous with j'~T
(,)
25 not having to come into the staff for approval of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.
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everything they do.
,y 2
MEMBER SHACK:
Oh, no, it was clear where they
(
)
3 drew the line.
Right.
4 MR. STROSNIDER:
Yes.
S MR. REED:
The next item then -- two items --
6 the November 20th letter was a list of issues regarding 7
the differing professional opinion.
I hope the discussion 8
we had yesterday addressed some of those and then also 9
we'11 be providing the documentation of what we presented 10 yesterday as soon as we can -- I think in three to four 11 weeks so we give an indication of when we'll provide 12 it.
13 I also note here that, on your agenda you have f')
'd 14 GSI-163 but I think the way -- what we're planning on 15 doing right now is, the document has a lot of raw material 16 in it.
It's basically what we did when we considered the 17 issues in developing the regulatory approach, and reser.rch 18 can -- I believe utilize the document as part of their 19 effort to address the issue of GSI-163.
20 As far as the terminology, reasonable 23 assurance, this is no longer in draft guide 1074, 22 MEMBER POWERS:
Chicken.
23 MR. REED:
It didn't provide any meaningful, 24 quantitative guidance so we took it out.
How's that for a fm
(
25 solution?
H EAL R. GROSS COURT REPORTERS AND TRANSCRtBERS 1323 RHODE ISLAND AVE., N W.
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MEMBER POWERS:
You correctly articulatt tha 2
problem and you --
73 t
i
~'
3 MR. REED:
Solved it.
4 MEMBER POWERS:
Well, what you've done is hide 5
it a little bit.
6 CHAIRMAN SEALE:
I'm going to blind-side you a 7
little bit.
8 MR. REED:
Okay.
9 CHAIRMAN SEALE:
What you've done here is to 10 put together an approach which is largely based on meeting 11 the chronic problems that historically seem to be in a lot f
12 of steam generator tubes.
That is, to a large extent, 13 you're doing things which respond to identified qY) 14 degradation mechanisms and so forth.
15 There's also the very real fact that in some 16 cases the cause of tube ruptures have been the result of 17 things that have happened in the very near, immediate past 18 of the operating history of the plant.
19 And an example that comes to mind is, what 20 happens when you lose a charge of demineralizer beads that 21 flood the secondary, get degraded in the high temperature 22 regions of the steam generator, deposit materials which 23 facilitate corrosion, and in a very short order you have a 24 new problem, based on a new mechanism, in a part of the
/~
(_h) 25 system that you have never had any problems in before --
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at least you had minimal problems with before.
2 That's not what you're addressing here though, 73 3
to a larg degree.
Somehow, there's got to be tie-in to 4
the -- what, the chemistry, the water chemistry process 5
for the plant and so forth?
And all I'm saying is, are 6
those issues going to be appropriately addressed in this 7
so that that connection is clear and --
(
8 MR. STROSNIDER:
In the examp'e that you gave, 9
part of the framework we've laid out here is that 10 licensees are expected to have a water chemistry 11 monitoring program.
12 CHAIRMAN SEALE:
Okay.
13 MR. STROSNIDER:
We haven't specified exactly p) i
-(-
14 what is supposed to be in that program.
Again, we're 15 referencing the EPRI guidelines we have talked about the 16 things that need to be included in it.
That is, what are 17 you going to sample for, how frequently, how do you do 18 those samples?
19 That all those things need to be included in 20 the program but we don't go to the point of saying, this 21 is what you sample, this is how frequently you sample it.
22 But again, with some objectivee of identifying out-of-spec 23 water chemistry early so that you can respond to it.
24 So with regard to that specific issue, I think
/~s(,)
25 there is that element of this program that hopefully would NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W, (202) 234-4433 WASHINGTON, O C. 20005 3701 (202) 234 4433 l
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give some early warning to that sort of thing.
But your em 2
obsarvation is correct.
We went back and what we were
(
)
3 talking about with this probabilistic performance criteria 4
for tube rupture, one of the observations was that roughly 5
half of the tube ruptures were due to things that people 6
weren't managing.
7 You know, in the early days there were a lot 8
of loose parts.
People have programs to manage that now.
i 9
And part of our discussions have been well, if our risk-10 informed, positional probability of failure, if we want it i
11 here, how much margin do we have to leave in there for the 12 unknown?
13 That's part of what got back to:
how do we k#
14 allocate different pieces?
We think a portion of that 15 needs to be for things we haven't anticipated in fact, 16 your defense-in-depth discussion.
17 Some of the inspection that we talked about 18 yesterday, which is somewhat prescriptive in terms of 19 initial sample sizes and that sort of thing, are intended 20 to identify the unknown.
But again, we get back to the 21 notion that you have to look at the whole program in its 22 overall elements in terms of inspection, leakage 23 monitoring, corrective actions, and the assessments that 24 go along with it.
()
25 All those things come together to provide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.
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reasonable assurance that we have tube integrity.
,q 2
CHAIRMAN SEALE:
Well, it --
(
)
3 MR. STROSNIDER:
And the acknowledgement that 4
some ruptures may still occur.
In that case you've 5
trained your operators, you've -- it's not a 100 percent 6
certain busineus.
7 CHAIRMAN SEALE:
Well, it certainly makes the 8
point that leakage monitoring is kind of the bottom-line.
9 MR. STROSNIDER:
Yes, we can't it would be j
10 an interesting -- we've gone back and taken some sort of 11 cursory look at well, how many ruptures do you think 12 you've avoided because you've detected leakage?
And I 13 can't really give you the numberc.
It's hard to say,
(
14 would it have gone to rupture or not, but we know there's 15 a lot of cases where leakage has indicated some 16 significant degradation and prompted timely action by the 37 licensee.
18 In some of those cases at least, I think we've 19 avoided ruptures and challenges to the operators.
20 CHAIRMAN SEALE:
And to close that loop I 21 guess, the other point is that some of the experiences 22 with these problems and what happens when you begin to get 23 leakage and get the kind of indications that show up in 24 secondary radiation monitors and so forth, that indicated
,-]
't) 25 the need to stif fen up the rec; irements in some of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.
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training and procedures to respond to there kinds of 2
things?
)
3 MR, STROSNIDER:
That's an area that's 4
addressed in the draft reg. guide.
It builds largely on 5
the EPRI guidelines which have been developed in the 6
recent past, based on the experience and looking at things 7
8 CHAIRMAM SEALE:
And that one in particular, I 9
reccll.
10 MR. STROSNIDER:
-- not just like absolu:e 11 leakage level, but trends in leakage level and how 12 frequently you have to monitor.
13 CHAIRMAN SEALE:
Sure.
Right.
C
14 MR. STROSNIDER:
Yes, you have to look at the 15 program in its total to see if you're going to capture 16 CilAIRMAN SEALE:
We mostly talked about the 17 chronic probable here.
18 MR. STROSNIDER:
Yes.
I guess my other 19 observation on that is, what we've tried to address in 20 these draft tech specs and in this regulatory framework is 21 not the specific degradation mechanisms but the problems 22 that were associated with managing those things -- that 23 is, uncertainty in non-destructive testing, uncertainty in 24 crack growth -- so that there is flexibility when new
,-\\
)
25 degradation modes show up, that these concepts should NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.
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still be applicable.
2 MR. REED:
That's all I had as far as issues I s
)
3 am aware of.
4 CilAIRMAN SEALE:
Any other -- any e>mments 5
f roni any of the committee?
Anything additional?
6 MEMBER FONTANA:
Yes, I think so.
I don't 7
know if 7've thought it all the way through yet.
8 Retrograding back to the reg, guide DG-1061 and using CDP 9
and LERF as criteria well, CDP woesn't have too much of 10 an effect here -- but I think it's fir.e with respect to 11 design, operation, things that you can actually do up to 22 the point of where -- we try to prevent failures, and it's j
I 13 great from that point of view, but when you're trying to
[h
(_)
14 assess risk, I think stopping at LERP may create a more, 15 apparently severe situation than really exists.
16 In other words, to do a risk calculation, if 17 you did carry out the -- if someone carried out the 18 calculation of #ission product release for transport, 19 looking at a specific plant which may have steam isolation 20 values or may, you know, or operator actions you can do to 21 release the primary system pressure, or there might be 22 ways of being the transport down for condenser, whatever.
23 Seems that doing a risk assessment by doing i
24 what amounts to a Level 2 PRA has a strong possibility of
(,)
25 maybe relaxing, or allowing the relaxation of some of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE (SLAND AVE., N W.
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requirementi that would be there if you were just using
, m.
2 LERF.
)
3 Now, the question is, some time in the future 4
can a licensee come in and having done these calculations, 5
possibly get a little relief?
Does this allow for that?
G MR. LONG:
Thia is Steve Long with the Risk 7
Assessment Branch in NRR.
The application can always be 8
made if -- the thing we're trying to deve. lop right now is 9
guidance on what we think would be sort of the best way to 10 make an application to us.
So we're not trying to 11 preclude that.
12 I know that Dr. Powers brought this up several 13 months ago in a subcommittee meeting, and I think his (V) 14 comment then was, he wasn't so sure that we actually had 15 the way of doing it adequately now.
So I think what we 16 really would have to do in order to find it acceptable is 17 to see calculations done with enough confidence that we 18 really felt we weren't looking at a large release.
19 MEMBER FONTANA:
Right.
20 MR. LONG:
And I'm not so sure that's, right 21 now, feasible to do.
I think it could be done in the 22 future and if it's successful then I think you're right; 23 we've shown we've been overly conservative maybe, here.
24 MEMBER FONTANA:
But there's nothing in here
()
25 that would preclude that?
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MR. LONG:
We'r, not trying to preclude it;
,m 2
we're just trying to say to the industry that right now we
\\ )\\
~
3 don't see a mechanism for making that argument to a degree 4
of quality that we could really rely on and say, this 5
really isn't a large release.
We can take it out of that 6
category and you're back to CDP where it's an order of 7
magnitude higher in acceptability of releases.
8 MEMBER FONTANA:
Yes, I thought, you know, 9
this is fine I think, as far as it goes but as you said, l
10 it doesn't preclude in the future if someone comes in with l
11 something that la acceptable.
I 12 MR. LONG:
We thought about trying to do those 13 ourselves.
We just don't feel we can do it yet, and we I
'd 14 certainly don't want to preclude anybody from doing it.
15 MEMBER FONTANA:
Thanks.
16 CHAIRMAN SEALE:
Okay.
Anything else?
[
17 DR. SHACK:
You haven't resolved yet how to 18 calculate the LERF successfully -- to a consensus 19 agreement.
20 CHAIRMAN SEALE:
Okay.
Anything else?
All 1
21 right.
I guess we need to go on.
22 MR. FT40 SNIDER:
Jack Strosnider, NRC sthff.
2I I guess the 2, ext thing on the agenda was some comments on 24 generic issue 163.
Tim Reed already told you I think.
)
25 about as much is they can give you on that.
Basically, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 HHODE ISLAND AVE., N W.
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that generic issue was established to address some of tha (n
different professional issues that came up.
It's been 2
1 x
/
3 th,re for some time.
4
/.t the same time that that generic issue was 5
identifid., NRR embarked on the rulemaking offort and the activities that we've been discussing the last several d
'r Maye, So basically the status of the generic safety issue a
is that they're relying on the work that we're doing to l
9 address the issue from a technical point of view.
And l
10 they'll have to administratively deal with that issue at l
13 least, you know, when we complete our work, i
12 So the bottom line there is that the technical 13 effort to address the issues is what's going on now.
It's
)
\\_/
14 a jcint 15 CHAIRMAN SEALE:
There is a status report on 16 that.
17 MR. STROSNIDER:
-- effort between NRR and 18 Research but it's just a holding place.
19 CHAIRMAN SEALE:
There's also the related 20 issue of 190, and I was wondering if there was any comment 21 you wanted to make about that?
22 DR. SINCH:
That's thermal fatigue.
23 MR. STROSNIDER:
Thermal?
I can't comment.
I 24 don't know the status of that.
,(,)
25 CHAIRM.'AN SEALE:
Okay, fine.
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MR. STROSNIDER:
- Sorry, r
2 CHAIRMAN SEALE:
Okay.
(yl 3
MR. STROSNIDER:
I want to just give some 4
summary, tl'en, some conclusions.
I want to go back and 5
just review very quickly.
In my opening statements I 6
mentioned that we had tcld the Commission we were looking 7
at four elements in our steam generator programs.
And one 8
of the key elements in that is a request for a change in 9
the technical specifications, okay, to address the issues 10 I'm not going to reiterate.
We've been through that.
11 That's a key point, and I just want to for a 12 second, put aside
- you know, we had a lot of discussion 13 yesterday about the legal aspects of it, the technical, i
T
'vl 14 the history, etc.
But I think from the regulator's point 15 of view I think we haue acknowledgement that the industry 16 is doing much more than what's in the tech specs in order 17 to ensure integrity.
18 And just from a common sense point of view, 19 tech specs ought to reflect what people have found that 20 it's necessary to do.
So we really believe that this is 21 an appropriate approach.
And you heard yesterday the 22 industry's perspective that they don't think a tech spec 23 change is necessary and that they think they can work with 24 the program under the Maintenance Rule or something to
('~h
(,)
25 that effect.
And we discussed that also, some of our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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concerns in that regard.
73 2
I think the only other comment I'd make here
)
3 is as I pointed out, that we actually have some commission 4
guidance in this area.
The Commission told us in the 5
staff requirementa memo, if you think the tech specs don't 6
really accomplish everything that need to be accomplished, 7
then fix them.
And that was fairly clear guidance.
8 So in terms of the implementation method, we 9
think that this is an appropriate thing to put out there.
10 I think that part of the industry concern, quite frankly -
because they haven't seen these draft tech specs 11
(
12 we've had technical meetings but actually it's been awhile 13 since we sat down and discussed some of that.
(
)
14 And I expect Mr. Callaway from NEI about 15 having a meeting like that in the future, because they 16 have a program which they're developing on some guidance 17 documents as you mentioned, and we want to make sure that 18 we're communicating well so they don't waste a lot of 19 resources and not address some of our concerns.
_0 But one of the main observations I wanted to 21 make here is that part of our goal is this meeting to show 22 that we think these items 1 and 2 are ready to go out for 23 public comment.
I think it's important to get them out 24 for public comment for some of the reasona I just
(~N
(,)
25 discussed.
The industry needs to see what's in these
]
j l
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documents and we need to get their feedback.
s 2
Now, as part of the public comment period it's
)
\\
3 quite conceivable that they'll come back in with their 4
alternative proposal as to how they think this ought to be 5
implemented, and that's fine.
That's an option.
That's a G
good way to address it in fact, because then we'll have it 7
all out on the table where we can look at it.
8 So the other point I wanted to make though, is 9
that I think again, as far as the industry concern, there 10 was a suggestion that the tech specs we're proposing could 11 again be out of date in the next two or three years.
12 We've been sensitive to that issue and tried to avoid 13 that, and I think we've tried to point that out in some of 14 what we've presented.
15 In terms of making i. performance-based, 16 dealing with how do you qualify inspection methods
-- not 17 telling people what inspection method to use, but -- we 18 don't care whether it's ultrasonics or eddy current or --
19 whatever works, so we tried to avoid being prescriptive.
20 At one point in time we had some discussions about the 21 tech specs actually referencing the regulatory guide or 22 other documents, which would in fact, make those documents 23 part of the tech specs.
24 The tech specs we have now and the Generic
~
(,/
25 Letter basically say, here's the objectives, go do it in N EAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1
370 1
your plant implementing procedures.
That provides greator 2
flexibility in terms of changing those procedures as n
)
3 necessary, but also it provides the enforceability that 4
the regulator is looking for, and that's something we 5
discussed in some prior meetings.
6 So we think we've got a good balance here.
We 7
think we need to get it out and let the industry see it.
8 CHAIRMAN SEALE:
One of the rumbles, if you 9
will, that seem to be in the background of all of these 10 discussions about tech specs and changes to tech specs and 11 so forth, is the concern for the long period of time it 12 takes to make a change.
One of the features of your i
13 performance-based approach is that you have provided a I\\)
14 mechanism in this different area of performance criteria,
~
15 where the industry can put together their version of what 16 the performance criteria are, or what they might be, and 17 work from that basis with you then, in a host adoption 18 mode, taking exception where you see that exceptions are 19 appropriate if the performance indication that comes out 20 is not up to what your expectations or your desires might 21 be, 22 I wonder if there isn't some way we can -- and 23 maybe you've just mentioned it, namely the idea of 24 referring to reg, guides or things of that sort
-- there n(j 25 isn't a way that the industry could get some relief so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.
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that this tech spec change process could be a little bit 2
less arduous and agonizing, c
t
/
'~'
3 MR. STROSNIDER:
Actually, we perceive that 4
there's a difficulty.
One of the things you might like to 5
do is, in the tech specs, reference either a regulatory 6
guide or an industry guideline document, with the notion 7
that you could change that regulatory guide or industry 8
document as approp" late, down the road.
9 CHAIRMAN SEALE:
- Yes, j
10 MR. STROSNIDER:
Unfortunately, the legal 11 interpretation, there is that, once you reference 12 something in the tech specs it's part of the tech specs, 13 and if you're going to change it, you need to come back in iN-14 for an amendment.
15 This is the reason that we try to avoid those 16 kind of references in the tech specs now, but in the 17 Generic Letter indicate that the expectation is that the 18 plant will develop implementing procedures to accomplish 19 those things that are in the tech specs.
20 So that's the way we are trying to address it.
21 It provides greater flexibility because a plant can change 22 their implementing procedures without a tech spec 23 amendment.
It's subject to inspection activities, but 24 that's the way we have to look at that,
\\(3 f,)
25 The difficulty we got into again, gets into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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dealing with some of the severe accident iscues, and you 2
know, trying to figure out performance criteria that you
,-')
~
3 can put in the tech specs -- if you had performance 4
criteria for these severe accident situations, put those 5
in the tech specs and then people could have a lot of 6
flexibility to change their repair criteria, etc., just so 7
long as they were meeting these.
8 We haven't figured out how to do that.
We 9
have provided the option for the industry to come
.n with 10 proposals and we're trying to develop some guidance in 11 that area.
So the option is there.
At this point in time 12 it will require staff review consistent with 1061.
13 I think there's a bigger picture question here
, _x
!\\')
~
14 that we touched on earlier, is this whole risk-informed is process of, at what point can you get beyond the staff 16 having to review all the 17 CHAIRMAN SEALE:
There's a measure of 18 unanimity at the technical level, that you need a little 19 bit more flexibility there.
The problem is, somehow 20 coming up with a device that meets the legal requirements 21 of tech spec constancy -- I don't know how to say it 22 MR, STROSNIDER:
But it gets back to -- if you 23 can address it technically -- I mean, if you've got a good 24 technical solution to this, we'll figure out how to put it
,n
(_,)
25 in the tech specs.
But we're still dealing with some NEAL R. GROSS COURT REPORTEAS AND TRANSCRIBERS 1323 RHODE ISLAND AVE. N W.
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technical issues here that I think that's it.
,x 2
so I guess the final, the conclusion, and what
(
)
3 we're really requesting from ACRS at this point is, we 4
provided items 1 and 2, we think they're ready to go out 5
for public comment.
We think it's imp rtant to get them 6
out for public comment.
7 We committed to the commission that we would 8
not send those out until we also have the DPO package l
9 addressing those technical issues.
And we gave you a l
10 status report on that.
We're hoping to have that l
11 completed in the next month or so and we'll provide that 12 to you.
13 And when we provide that I think we will be
()
s
/
14 requesting at that point, approval to go out with that 1.
package for public comment.
If we need to come back and 16 discuss the DP0 package some more after you've seen it, 17 obviously we'll do that.
And I guess probably need some 18 discussions with the main committee at some point, is that 19
-- in fact, we might do it then if that fits.
But that's 20 the next step.
21 So the ball's in our court still to finish 22 that DPO package and get it to the committee, and at that 23 point we'll be requesting to go out with this package.
24 That concludes what we wanted to cover.
()
25 Appreciate -- sort of a long day and-a-half, so we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVE., N W.
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appreciate four patience.
p 2
CHAIRMAN SEALE:
We've all got a large 3
investment in this sense, and I think we appreciate that 4
it's not been an easy task at all.
5 DR. KRESS:
Are you asking for any feedback 6
from us at this point in time?
7 CHAIRMAN SEALE:
Yes sir.
8 DR. KRESS:
I think they're on the right 9
track.
I do.
I like what I've -- well, I can't say any 10 more than that.
11 MR. STROSNIDER:
I appreciate that.
12 DR. KRESS:
I don't see any fatal flaws in 13 what you're doing.
I think you're it right, f3b 14 CHAIRMAN SEALE:
Okay.
Now, maybe we can take 15 care of a few other housekeeping items that you're 16 involved in.
Sit down and make yourself comfortable.
We 17 have a full committee meeting next week, and in that 18 agenda there's an hour-and-a-half for the steam generator 19 discussions and half-an-hour for the BWRVIP discussions.
20 Now, I think as far as the BWRVIP is i
21 concerned, we'11 handle that at this stage with just some 22 comments by the subcommittee chairman to the fuli 23 committee without imposing on the staff.
But of course 24 you're welcome to be here and if they try to pin me to the t, )
25 wall, why I'll be more than appreciative of any help you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.
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can give me.
fs 2
With regard to the steam generator di,cussion, 3
I think you very -- well, I think we've shared Dr. Kress' 4
comment that we think the approach is generally the right In your discussion this morning you mentioned the 5
one.
6 fact that there is this remaining, let's say, difference 7
in approach that the NEI people would like to suggest as 8
opposed to the tech spec change approach which you point 9
out, the Commission has already indicated an interest 10 that is, a desire to fix the tech specs.
11 But I think it would be very worthwhile for us 12 to be sure that the full committee gets an understanding 13 of the NEI's perspective.
And so we asked Mr. Callaway K-14 before he left this morning, if he would be willing to 15 appear at that time and give us a 15-minute summary if you 16 will, of the NEI alternative approach on this process.
17 We would like for you to make a short 18 presentation, sort of summarizing the situation now with 19 regard to the overall steam generator program, and I think 20 highlighting the presentation that Tim made this morning 21 with regard to responding to the previously expressed ACRS 22 concerns it would be a part of that.
23 MEMBER FONTANA:
With regards to the NEI 24 presentation, all I really heard was, we don't like it,
,Q
(,)
25 we've got a better one and we're going to work the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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Maintenance Rule.
I mean, I want to hear some more.
2 CHAIRMAN SEALE:
Yes, but the rest of the (s)
'^'
3 committee I think, needs to hear some of what they had to 4
say as well.
5 DR. POWERS:
But we also need to make it clear 6
to the rest of the committee that, what they will hear in 7
that 15-minute presentation is essentially equivalent to 8
what we've heard in a 15-minute presentation.
That there 9
is not right now on the table, an alternative that can be 10 scrutinized.
11 MEMBER FONTANA:
Yes.
12 CHAIRMAN SEALE:
But they're coming up short -
13
- they're talking about coming up shortly with some sort
\\~)
14 of NFI position if you will, that they will have voted on, 15 and that's likely to become a topic oi some debate in 16 various quarters, and I'm not sure that the full committee 17 ought to be blind-sided on that.
So I think a 15-minute 18 opportunity for them to make their presentation to the 19 full committee would be --
20 DR. SHACK:
Although in the balance between 21 the pressure vessel and the steam generator issues, I 22 don't know, it seems to me you'd be better off with a 23 split.
I mean, you know, much of the steam generator this 24 is, you know, a fine tuning of what we heard before.
/"N k,)
25 MEMBER FONTANA:
Yes, we've already heard it.
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DR. SHACK:
You know, the vessel stuff, the x
2 rest of the committee hasn't heard word-one of.
It seems
)
'~'
3 to me, you know, a 50/50 split might be more reasonable 4
than --
5 CHAIRMAN SEALE:
Instead of an hour-and-a-half 6
and a half?
7 DR. SHACK:
Half.
8 CHAIRMAN SEALE:
Okay.
Can we agree, 9
renegotiate that a little bit?
10 DR. SINGH:
We might --
11 DR. SHACK:
Can't do that at this point?
12 DR. SINGH:
That's too late because we have 13 two different days.
Unless we switch -- unless you want x/
14 to switch the BWR on the first day and then switch the 15 steam generator next day.
Because they're on two separate 16 days.
17 DR. SHACK:
I don't know.
Does anybody else 18 feel that that's the wrong balance?
19 DR. KRESS:
Yes, I do.
20 DR. POWERS:
I'd be real careful because it's 21 a little difficult to change the --
22 DR. SHACK:
Yes, it's going in the Federal 23 Register notice.
24 DR. POWERS:
Yes.
13
(.,_)
25 CHAIRMAN SEALE:
Well, we'll discuss that at NEAL R. GROSS COUR1 REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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the P&P meeting later today, 2
DR. POWERS:
It seems to me that we can 73
(
)
'~'
3 articulate the issues of the BWR vessel very succinctly, 4
and this is not a complicated fundamental issue.
It's a 5
complicated resolution.
6 CHAIRMAN SEALE:
Okay.
Any other -- do you 7
have an idea of what it is you'd want talk about on the 8
9 MR. STROSNIDER:
I think we'd respond to your 10 request to address -- explain how we're dealing with some 11 of those outstanding issues and give just a broader 12 picture of --
13 CHAIRMAN SEALE:
Yes, sort of the bottom line (N,
t e
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14 to where you're coming down?
15 MR, STROSNIDER:
Yes, and what -- the summary 16 that I kind of gave here at the end -- what we're pushing 17 for there.
18 CHAIRMAN SEALE:
All right.
19 MR. STROSNIDER:
And you'll get back to us if 20 you want something on the vessel weld examination?
21 CHAIRMAN SEALE:
Yes.
22 MR. STROSNIDER:
The staff is flexible, so 23 just let us know.
24 CHAIRMAN SEALE:
Okay.
Any other comments?
(q
,/
25 Any other further issues ve'd like to bring up with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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379l 1
staff in either area before we get --
7s 2
DR. POWERS:
We had thought that we might want I
)
~
3 to write a letter to the EDO on our thoughts on the 4
vessel.
To do that -- well, we actually intend to do that 5
and if we do, do we have enough time, a lot of discussion 6
to develop a meaningful letter?
7 CHAIRMAN SEALE:
Well, certainly that would 8
have to be the focus of the one-half hour we have so far 9
had allocated to that particular issue.
Whether or not we 10 can articulate those well enough for the whole committee 11 to be committed to a letter to the EDO is a very good 12 question.
13 DR. KRESS:
We would have to make use of the (3
sl 14 letter writing time.
15 CHAIRMAN SEALE:
Some, yes, true.
16 DR. KRESS:
That would narrow it, certainly.
17 MEMBER FONTANA:
How much time do we have 18 allocated for the vessel discussion?
19 CHAIRMAN SEALE:
Just half-an-hour.
20 MEMBER FONTANA:
Is that enough to -- I guess 21 that's enough to get across to the other guys what the 22 concerns are.
I guess a letter basically is going to 23 alert them that this is --
24 DR. POWERS:
Well, I mean, they're coming --
/
(_)i 25 MEMBER FONTANA:
-- use of the thing.
What?
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DR. POWERS:
They're coming back to the 7x 2
package on this and it's simply a mechanism of saying --
)
x/
3 anticipation -- here are the kinds of things that we would 4
like to see something said about in that package.
5 CHAIRMAN SEALE:
I think the real problem as 6
far as the rest of the committee is concerned, is not that 7
we can't identify issues that need to be in the response, 8
or that we would expect to be in the response.
The 9
question is whether or not the thing we can prepare and 10 agree to in the period of time that's presently available, 11 can stand any kind of scrutiny for completeness.
12 That is, if we give them a letter and then 13 start dribbling in additional questions on top of that as
'w) 14 we go further into the issues, have we really helped by 15 giving an incomplete discussion at this time?
So --
16 DR. POWERS:
They're the most important issues 17 in our mind --
18 CHAIRMAN SEALE:
Yes, but there may be others 19 that we haven't thought of --
20 DR. POWERS:
Except for those that we don't 21 list.
22 CHAIRMAN SEALE:
Yes, exactly.
So I guess I'm 23 not afraid of a letter except that we may get a little egg 24 on our face if it turns out we sort of left some important
(^T
(,)
25 things out of the discussion.
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1 MEMBER FONTANA:
Well, that raises one -- like rw 2
what would be in a letter?
Are we going to restrict the
(
)
~
3 comments to the request for reduced inspection, or are we 4
going to slip in the idea that these failure rates, these 5
predicted failure rates, are a little higher than we 6
always thought they were?
7 DR. SHACK:
Well, it seems to me 8
MEMBER FONTANA:
There's some real 9
implications --
10 DR. SHACK:
-- too, in an SER you don't really 11 want to rate, you know, that this is a work-in-progress.
12 It's more at this point, a question of whether you need a 13 letter for additional information.
Somehow I would think
(
)
k/
14 it would be easier to have staff talk to staff about it.
15 I don't know, is there something that --
16 CHAIRMAN SEALE:
That may be the other way to 17 do it; is for us to discuss a list of questions and 18 formally have the staff take it to your folks and let you 19 guys -- that's not a foreign way of doing things in the 20 past.
21 MR, STROSNIDER:
The thing that would be most 22 helpful to us I think is, we took some notes yesterday on 23 some of the questions that were raised and we'll follow up 24 on that with our assessment and we'll ask the industry to
(-
(_,)
25 look at it.
The list of questions we -- you know, we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N W.
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issued the RAI to the industry.
If there's some fs 2
additional things that we want to them to look at we'd l I
)
f
~#
3 like to get those things to them as quickly as possible.
f 4
So I'd be perfectly happy with a list of any 5
issues that you think need to be addressed that we haven't 6
- covered, Then we know we --
7 DR. KRESS:
I think that would be most 8
appropriate.
9 CHAIRMAN SEALE:
Yes.
We worry sometimes, you 10 know, we have performance criteriu too, and some people 11 wonder whether or not we give away too many things that 12 are not on the record.
But I think that's a trivial 13 concern at this time.
Maybe we should just try to get to t'
i 14 you a -- make sure you understand what our outstanding 15 concerns are so that you can pass those along to the 16 industry and have them include that in their revisions to 17 the 18 MR. STROSNIDER:
- Yes, I do think that's 19 everyone's benefit, because ultimately we will be coming 20 back saying, do you agree with this position or not?
21 CHAIRMAN SEALE:
Sure, sure.
22 MR. STROSNIDER:
And so we want to make sure 23 that your questions are responded to.
24 CHAIRMAN SEALE:
Fine.
Okay.
I think that's O
\\,)
25 probably what we would try to do.
Are there any other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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issues at this time?
Any questions?
f-~
2 Well, I want to thank you, obviously, you 3
spent an awful lot of time.
You've thought about these 4
things very deeply, and I think your comment earlier to 5
the effect that this is really one of the more intriguing 6
and productive, potentially, ways of applying the whole 7
1061 methodology and so on, is very much to the point.
8 It's a leading, precedent-setting activity in 9
many ways, and so we all have to be very careful in the 10 way we go about doing it, because those kinds of things 11 are hard to work your way out of once you get into them if 12 you don't want to be there, 13 With that, I'll adjourn the meeting and let
(,,\\
~
14 the committee members --
15 MEMBER FONTANA:
- Scatter, 16 CHAIRMAN SEALE:
-- scatter, relax, or 17 whatever it is they're going to do, 18 (Whereupon, the ACRS Joint Meeting was 19 concluded at 9:59 a.m.)
20 21 22 23 24
('h
(,)
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1M3 RHODE ISMND AVE., N W.
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O CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of Name of Proceeding: MATERIALS AND METALLURGY AND SEVERE ACCIDENTS SUBCOMMITTEES JOINT MEETING Docket Number: N/A Place of Proceeding: ROCKVILLE, MARYLAND l
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 l
typewriting by me or under the direction of the court I
reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
.M lbL CORBETT'R'INER Official Reporter Neal R. Gross and Co.,
Inc.
O NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 R1(ODE ISLAND AVENUE,NW (202)234 4133 WASillNOTON, D C. 20005 (202)234-4433
O DISCLAIMER PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS AUGUST 27, 1997 The contents of this transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards on h)i
(
AUGUST 27, 1997, as reported herein, is a record of the discussions recorded at the meeting held on the above date.
This transcript has not been reviewed, corrected and edited and it may contain inaccuracies.
Ov NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RilODE ISLAND AVENUE, NW (202) 234-443L WASmNGTON,D.C. 20005 (202)234-4433 I
.O O
O Steam Generator Generic Letter SG Tube Integrity ACRS Issues ACRS Materials and Metallurgy Subcommittee and Severe Accidents Subcommittee August 26,1997 Timothy A Reed Materials and Chemical Engineering Branch Division of Engineering NRR (301) 415-1462 u- _
.o o
O BACKGROUND: LIST OF ISSUES In meetings and letters, the following ACRS issues have been raised (based on 1
6-12-97 compilation of concerns):
Relationship of regulatory approach to risk (including suggestion to re-write of draft RG, recourse to the use of defense-in-depth)
Allowing licensees to consider risk versus just frequency -more realistic treatment of fission product releases (SG internals acting as a filter)
Performance criteria: (1) whether standards for complying with PC are clear, (2) structural PC and safety factor of three, (3) exceeding the operational PC, (4) basis for the allocation of conditional burst probability Recommendation that methods for demonstrating conformance with PC be approved vs the " pre-approval" approach DPO issues /GSI-163 Use of terminology " reasonable assurance" 1
.O O
O ISSUES THAT IMPACT CURRENT GENERIC LETTER Most of the above issues do not directly pertain to the staff's effort to issue the compliance-based GL for public comment: most involve either risk or the implementation of alternate repair criteria The issues that impact the current GL are:
Safety factor of three: Staff evaluated the industry proposal and determined that the code margin should be properly interpreted as a factor of three--(Emmett Murphy's presentation discussed this issue) 1 Exceeding the operational leakage performance criteria: Staff believes this i
PC is a reasonable threshold for the staff to become involved with inspecting the licensee's SG program-(Emmett Murphy's presentation discussed) 2 w
O O
10 REMAINING ACRS ISSUES Relationship of the regulatory approach to risk:
Revised GL approach is now consistent with DG-1061, other similar risk-informed approaches, and the PRA policy statement (questions regarding DG-1073 will have to wait until the DG is provided to ACRS)
Compliance GL is to ensure that current regulations continue to be met (GDCs, Part 100, and ASME code continue to be satisfied-i.e., defense-in depth is maintained)
Allowing licensees to consider risk versus just frequency -more realistic treatment of fission product releases (SG as a filter): The guidance being developed for DG-1073 is consistent with DG-1061-describes the calculation of LERF.
Performance criteria / Standards for complying with PC: the staff believes the DG-1074 guidance is sufficient 3
c ----
.O O
O.
REMAINING ACRS ISSUES CONT' Performance criteria / Basis for the allocation of conditional burst probability:
the staff is still assessing this as part of the development of DG-1073 Recommendation that methods for demonstrating conformance with PC be approved vs the " pre-approval" approach: The staff believes the DG-1074 provides ample guidance such that licensees following it can implement assessment methodologies without prior staff review / approval. Removing this element of the regulatory approach causes the approach to lose all of its performance-based characteristics.
9 DPO issues: The staff provided a status (previous presentation) and will provide the DPO document after management review. RES should be able to utilize the document to support the closeout of GSI-163.
Use of terminology " reasonable assurance": terminology has been deleted from DG 4
L
_