ML20235N140
| ML20235N140 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1611, NUDOCS 8710060403 | |
| Download: ML20235N140 (286) | |
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TRANSCRIPT OF PROCEEDINGS
_ UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l
SUBCOMMITTEE ON GENERIC ITEMS In the Matter of: ) l
)
EFFECTIVENESS OF NRC STAFF PROGRAMS )
REi GENERIC ISSUES AND UNRESOLVED )
SAFETY ISSUES )
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AMS R gE[:gpy 20Jol3emove from ACRSOfice
. Pages: 1 through 235
_ Place: Washington, D.C.
Date: September 30, 1987 O' Heritage Reporting Corporation Q(Ocial Reporters 3 870930 220 5 . .
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.() 1 PUBLIC NOTICE BY THE 2 UNITED STATES NUCLEAR REGULATORY C'OMMISSION'S 3 -ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 6
7 The contents of this stenographic transcript of the 8 proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or O 14 inaccuracies of statement or data contained in this transcript.
15 16 17 18 19 20 21 22 23 24 25 l
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION
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\/ 2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3 SUBCOMMITTEE ON GENERIC ITEMS
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4 5 n the Matter of:
G EFFECTIVENESS OF NRC STAFF PROGRAMS )
RE GENERIC ISSUES AND UNRESOLVED )
7 SAFETY ISSUES )
Wednesday 8 September 30, 1987 9 Room 1046 1717 11 Street, N.W.
10 Washington, D.C.
11 The above-entitled matter came on for hearing, 12 pursuant to notice, at 8:35 a.m.
(A.)
13 BEFORE: DR. CIIESTER P. SIESS Professor Emeritus of Civil Engineering 14 University of Illinois Urbana, Illinois 15 ACRS MEMBERS PRESENT:
16 MR. JESSE C. EBERSOLE 17 Retired head Nuclear Engineer Division of Engineering Design 18 Tennessee Valley Authority Knoxville, Tennessee 19 MR. CARLYLE MICllELSON 20 Retired Principal Nuclear Engineer Tennessee Valley Authority 21 Knoxville, Tennessee, and Retired Director, Office for Analysis and es 22 Evaluation of_ Operational Data
(_) U.S. Nuclear Regulatory Commission 23 Washington, D.C.
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,, ACRS MEMBERS PRESENT (CONTINUED): !
I] 2 MR. CHARLES J. WYLIE Retired Chief Engineer 3 Electrical Division
(') - Duke Power Company
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' 4 Charlotte, North Carolina 5 ACRS COGNIZANT. STAFF MEMBER:
6 Sam Durhiswamy 7
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3 Tk l' PROCEEDINGS 2 DR. SIESS: The subcommittee will assemble, please.
3 The meeting will come to order. This is a meeting of the 4 Advisory Committee on Reactor Safeguards Subcommittee on 5 Generic Items.
6 I am Chester Siess, subcommittee chairman.
7 The other ACRS members in attendance this morning 8 beginning on my left: Jesse Ebersole, Carlyle Michelson and 9 Charles Wylie and the cognizant ACRS staff engineer, Mr. Sam 10 Duraiswamy on my right.
11 The purpose of the meeting is to continue the 12 discussions we have been having on the effectiveness of the NRC g 13 staff programs that address generic issues - and unresolved
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14 safety issues which will be referred to hereafter as USIs.
15 The rules for participation in today's meeting were 16 announced as part of the notice published in the Federal 17 Register on Wednesday, September 16th.
18 A transcript is being kept and will be made available 19 as stated in the Federal Register. I will ask each speaker 20 first to identify himself or herself and then speak with 21 sufficient clarity and volume so that they can be readily heard 22 by the reporter and by those of us present, some of us who 23 don't hear very well.
24 We have received no written comments from members of I
, 25 the public, and no requests for time to make oral statements O
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d 1 from members of the public.
2 Does everybody have a copy of the most recent agenda? .
l 3 If you have, you will note that the scope has been somewhat 4 shortened from the agenda that was previously announced. We 5 will not have representatives here today from Tacony Power 6 Company. There were some foul ups in the arrangements. So we 7 have shorted the presentations, and we now plan to adjourn 8 without lunch by about 1:30. It will be no later than 2:00 I 9 can assure you.
10 The first part of the agenda that deals with the 11 identification, prioritization and resolution of USIs and 12 generic issues, presentations from research people, is
_ 13 unchanged.
14 The second part which involved in the previous agenda 15 participation by people from NRR and from Tacony has been 16 modified. There will be participation only by representatives 17 from NRR.
18 What was it, three weeks ago just prior to the 19 September meeting of the ACRS, I had arranged a meeting with 20 three of the NRR project managers to explore their role in 1
21 implementing generic issues and to see what we might learn from .;
j 22 them. We had them into the full committee. I intended to just 23 sit down with them and go over some stuff and see what they can 24 tell us. It turned out that Charlie was here, so the two of us 25 sat down with them, and we spent what, about three, three and O
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'l' half hours.
2 We had three project managers from the three Tacony 3 plants, Tacony, Catawba and McGuire. And it was a very 4 interesting discussion, and not ' all of it I'm afraid dealt
.5 with the generic issues. We had a chance.to see how project 6 managers work and how they interrelate to the resident 7' 'nspectors i and the utilities, and things of that sort, and 8 found it quite interesting. ,
9 We had three very experienced project managers, all 10- with I- think up.to eight years experience as project manager 11 and somewhat more of that in NRC. And we liave invited -- we 12 couldn't get.all three of them to come in today. They are busy 13 people, and.one of them is on jury duty I think. But one of O- 14 them'is coming in this afternoon or later this morning. It's 15 Helen Pastis, and Helen is project manager for the three Tacony 16 units. So we will have her in and she will tell us a little 17 bit about how'she operates at the utility on generic. issues, 1
18 and on anything else I guess if you want to talk about it.
I l 19 And then Ron Hernan has arranged to come in and take 20 us through the process of implementation from NRR's point of 21 view on I think a couple of items, and he will try to give us 22 sort of a general time table. It won't be plant specific, but 23 Helen will be there, and if any of them relate to the Tacony 24 plant, which is a nice, old plant, it's probably had a number 1
25 of things backed into it. So that's what we will try to do 1 0.
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(,/ 1 today.
2 At some point we have got to decide what we do next 3 and whether we still want to have a meeting with somebody from 4 a utility, or more than one. What I had hoped to get from 5 Duke, one thing was for them to give us by example a feeling 6 for the time and effort involved in implementing some of these 7 things. They are not done overnight. There is engineering, 8 procurement and all the other problems that go along with it, 9 because as you will see, some of these things take years to get 10 implemented. We may still want to do that, and since this 11 meeting is slightly abbreviated I suspect we could talk ACRS 12 administration out of another meeting somewhere along the line.
3 13 Then after that once we are through, what I propose 14 to do is prepare a fairly complete report back to the 15 commissioners in response to their specific request on review ,
16 of the effectiveness of the process, and I don't think we will 17 need a meeting. I would be willing to draft a report and get ,
18 comments back in writing, and go through as many cycles as we I
19 need. And if turns out that we really need a meeting to agree i I
20 on a report, we will try to arrange two or three hours )
21 somewhere.
l 22 And then we will take that report to the full 23 committee and let them decide what they want to do. They can 1 I
24 decide from the nature of the report whether they want to hear 25 directly from some people on the staff, of whether they want to O
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7 O 1 endoree it, treesmit it er whet. 1 thiuk we emeht to come en 2 with what we think should be our report, and let the full 3 committee either say those guys know what they are talking 4 about, we'll pass it on. Or , no, we would like to talk to the 1 5 staff or hear the staff on these particular issues, and we will 6 give them that option.
7 Any questions at this point?-
8 Now what we have done here for the first part of the 9 presentation this morning is to pick four items off of the 10 list. I think some of these -- Carl had some suggestions.
11 VOICE: They were pretty much picked from the staff's 12 list.
13 DR. SIESS: Some items, I think. But what we did was
('/ 14 'look at the staff's list and categorizing items in various ways 15 and we took a couple that took a long time to resolve and a 16 couple that were short. Some of them had required backfit.
17 Some of them didn't. Two of them were USIs, two of them were 18 GIs. There is nothing typical. I don't think anybody could a 19 typical, or four typical, or 10 typicals. Everyone of these 20 things seems to be different in some important respect. !
21 So we have got four items, and the intent is to take 22 them one by one and the staff to walk us through the process I
23 both in time and -- Sam says it's on the list, the resolution 24 and what's been involved, and one thing I would like to get a i I 25 feel for is in terms of time, how much of it is in the process l O
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8 i 1 and how much of it is technical, how much is administrative and 2 much is technical. And some things people just have to put man !
3 hours of, or man months on, and throwing more men at it might 4 help, and some of it is simply the process of getting reports 5 out and over here to be reviewed and over there to be reviewed 6' and getting agreement.
7- And there is some feel for where the time is 8 involved, because I think there is a feeling that time is of 9 the essence in ' some of these things, and if they drag on 1
10 forover, we haven't accomplished much. '
11 MR. MICHELSON: I'm wondering when the etaff talks l
12 about these four issues, for instance, that they would give
. 13 special attention to the question of how their resolution, how 14 they decided to apply the resolution to future plants versus l-15 plants already in existence, because I have some questions 16 about the applicability of future plants of some of these, and 17 how we decide that they are applicable or not and so forth.
18 DR. SIESS: Can you do that?
19 MR. WOOD: We can try.
20 DR. SIESS: Okay. let's start in then. We have 21 changed the order a little bit. We will take up A-49 first, 22 and that's Roy Woods, and then we will take up what, A-46 after 23 that and then 20 and 61. I 24 Some of the documents relating to these things-- l 1
25 you've got a package on each one of them, and you know what we ]
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2 MR. WOODS: I sent you what you have on mine.
3 DR. SIESS: Okay.
4 MR. WOODS: I think I know.
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5 DR. SIESS: Okay, so you know what we got, and you 6 can refer to it.
l 7 MR. WOODS: I sent you two things to talk 8 specifically to my slides. See that one on the front. And s l
9 then there is a thing that looks like this with a black band on !
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10 the top and the bottom, I'll tell you what that is when I get 11 into the talk. That's what I sent you.
12 DR. SIESS: Okay. So we have the two handouts from i 13 you plus the one that Sam passed out which has got the PTS 14 Executive 8560.
15 MR. WOODS: Right. j 16 DR. SIESS: Okay, I think we are set. Go ahead.
17 MR. WOODS: Okay, you have already given me a real )!
18 good lead in to where I wanted to start, and that is these l 19 things are all unique. There is no pattern. In fact, I can 20 hear from your talking about implementation versus resolution 21 and whatever, PTS doesn't even really fit that mold very well, 22 because -- well, I will explain that as I get into it.
23 But even that broad a contact of a formal method, 24 which is what my first point is, there is no formal method in 25 resolving these things. You take each problem as you see it, IIeritage Reporting Corporation (202) 628-4888 1
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.(, , l' you decide how best to work on it, how best told solve it.
2 I would point out to you that a generic method of 3 solving these things leads you to trouble. You end up with a i
4 forum that needs a date for a certain., aspect of the resolution, S and you're not doing it that way. And it's hard to explain to 6 a computer that you aren't doing it'that way and'you have no 7 date to fill into that fool blank that somebody put there, and 8 that gets very frustrating.
9 MR..MICHELSON: Excuse me. -As you go into this one I 1
10 and the other examples, would yotF also make it clear what your 11 process is to handle the problem of partial resolution. This 12 is a case where you have resolved a part of the issues, but, I l
n 13 there is another part that you didn't really resolvo. And how U 14 is it stored away and highlighted and reminded to readers as 15 they look at your resolution. , ,
16 The fact that, okay, here's the resolution, but here l 17 is the part we didn't resolve, and perhaps here is how it's 18 going to be handled.
19 MR. WOODS: I think that's throughout this talk. I 20 think you will have that when I finish.
21 MR. MICHELSON: Okay, thank you.
22 DR. SIESS: Now that's addressed to all the speakers. ,
23 MR. MICllELSON: Yes.
l 24 DR. SIESS: Not just Mr. Woods.
i l 25 MR. WOODS: Well, I can't answer for them.
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1 DR. SIESS: No, but.I just wanted them to be sure 2 'they listened.
3 MR. WOODS: Okay, we started out - . this is an 4 administrative talk. I'm not going to -- I'm going to try to 5/ stay as much as I can away from the technical issues involved 6 in PTS, because you gentlemen have heard that many times.
7, So, for example, this particular event started with l
l 8 some what' if . questions that followed a 1978 event which 9 happened to be Rancho Cico, but I am not here to talk about s
10- Rancho Cico, some deterministic calculations that were done.
11 Following that event indicated that indeed under different l
12 circumstances it appeared that that event could have failed the 13 -vessel.
O 14 However, the. risk was not known because no one really
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15 knew how likely it was'that such a thing would happen again 16 under worst conditions, and that this was no way to, with the 17 information that was) 'known at that tMme , to put some kind of 18 risk number on it. So you . didn' t know whether expensive 19 extensive correctihe actions dere required, or whether it'was
,/ 20 just -- whether'It was okay.
i 21 And to make the point that all these are different, 22 what I want to say here is ,they decided which particuler 23 technical subjects were going to cause the most -- had the most
, ~I s 24 uncertainty associated with them, and they wanted to get a test 25 manager who would be more familiar with those areas.
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- q it 32 0 1 ^#d wnet - 1' eeries ree117 le mete 11er9 1ce1 eseecte 2 and systems aspects of these plants were heavily involved in 3 pressuriz(d thermal shock, and it seemed like the metallurgical 4 aspects were under better control than the systems aspects, so 5 they wanted a systems person to help to run the thing.
6 And they came looking for me, I guess, at least I wah 7 found outside the Crown Books in Bethesda.
That's where I"was a !
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8 first approached about thite.. thing. So there isn't even a 9 formal process to g1 out and look for a test manager, i
10 DR. SIESS: Going in or coming out?
1 11 MR. WOODS: I thiik 1~had come out, and I'm not going (
i 12 to tell you what I was doing in there.
I 13 Paul Noran who.a:tually opproached me,'so the two of 14 us -- the two actors in.that little meeting was stJll with this 15' project. Heissittingbehi(.dyouthere.
16 Okay, well, after I wbs recruited as test manager --
t 17 DR. SIESS: 1,et me interrupt you a moment.
1R MR. WOODS: Sure, aa ahead.
g f >19 DR. SIESS: Long b2 fore this event, we knew that you
'/ 20 shouldn't put pressure on a cold vessel. That was part of the 21 issue
'22 MR. WOODS: Right.
23 DR. SIESS: So we knew that was bad. We didn't know 24 how bad, but the whole process was designed to avoid that, 25 right? i 1
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'6 1 MR . - WOODS: That's a slightly different issue.
2 Putting pressure on a cold vessel is an LTOP issue.
3 DR. SIESS: Okay, this is the thermal shock.
4 MR. WOODS: Right, this is the issue.
5 DR, SIESS: This now involves in the temperature, 6 transmission through the thickness.
7 MR. riOODS: This involves the transient where you 8 start out hot, and you -- that was the unique aspect.
9 We did know about the one you are talking about.
10 DR. SIESS: Now there were some questions in terms of 11 the metallurgy but not large ones there.
12 MR. WOODS: There were certainly questions regarding 13 the metallurgy but people felt that they knew -- if you could 14 specify a pressure and temperature history for the vessel, they 15 knew pretty well how to calculate what the metal would do. But 16 what you didn't know is how likely the various transients would 17- be that would be the input to the calculation.
18 DR. SIESS: If it came up probablistic type thing, 19 could it happen again? l 20 MR. WOODS: Right, if you can --
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i 21 DR. SIESS: And under what circumstances. I i
1 22 MR. WOODS: If you can tell me the event, the i l
23 metallurgists can calculate it, but we couldn't tell them the 24 event.
25 DR. SIESS: Okay.
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14 O 1 MR. WOODS: ned thet e where the sveteme eeeecte ceme 2 in.
i 3 DR. SIESS: Okay.
4 MR. WOODS: I guess I have to get into it that much 5 in order to even tell you how we resolved it. ,
6 DR. SIESS: Okay, the metallurgy end of it was 7 relatively -- it was fairly well know and relatively straight 8 forward.
9 MR. WOODS: We believe that it was better understood 10 than the systems aspect which would be to tell the metallurgist 11 what transient to calculate in the likelihood of an event.
12 MR. EBERSOLE: Let me ask a question. It would have 13 appeared on the surface that Babcock and Wilcox plants which O 14 are super heat plants that the hypothesis of a secondary system 15 failu e which would depressurize to low pressure and 16 temperature, followed by a rather probable or at least a 17 believable transient which is overfill of the secondary side 10 from the main feedwater pumps?
19 MR. WOODS: Yes.
20 MR. EBERSOLE: And continuity of function of the main 21 coolant pumps which is reasonable postulate, would produce 22 exactly the situation which would be worse, which is 23 overchilling of the primary lube. And in turn, a low 24 temperature, high pressure transient on the primary vessel.
l l 25_ Wasn't that fairly well known far in front of this l .
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2 MR. WOODS: I'm sure it was, but I am only been 3 involved in it since 1981, and I'm not really going to be able 4 to take it way back.
5 DR. SIESS: I'm not sure I understand.
6 You think they should have known this before it 7 happened at Rancho Cico?
1 8 MR. EBERSOLE: Oh, glory, yes. !
9 DR. SIESS: Well, that may be too.
10 MR. EBERSOLE: Which indicates, you know, do we have j i
11 to wait for things to happen.
12 DR. SIESS: Then there would never been a generic 13 issue.
O 14 MR. EBERSOLE: Yeah. l I
1 15 MR. WOODS: I think that's beyond what I can address. )
1 16 MR. EBERSOLE: Well, it's kind of a stigma on our 17 business to have to wait for things to happen to identify them.
l 18 DR. SIESS: Yes, but if we didn't have to wait, we l 1
19 wouldn't be doing this at all.
20 MR. WOODS: Well, the point I'm making here is simply 4
21 that these things are discovered in various ways. The best way l 22 would be the way you are saying, that you have already thought 23 of it just from basic principles, but that's not the way we got 24 into this one. So for whatever that's worth, there you are.
25 MR. EDERSOLE: I'm quite certain that it was well f~
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l 2 MR. WOODS: I wouldn't argue with you, but I'm 3 telling you that's --
4 MR. EBERSOLE: It's just the fact that we are only l' 5 triggered by physical events.
6 DR. SIESS: Not only. There must be an awful lot of 7 things that are done right in these plants, or we would have
! 8 more generic issues than we have.
9 MR. MICIIELSON: I thought this particular issue was 10 more directed at the modes 4 and 5 kinds of operations as 11 opposed to normal power operation where indeed the transients 12 were understood. Generally, they came out a little bit above 13 where they were really troublesome from the pressurized thermal
'O 14 shock viewpoint, although some later calculations indicate the 15 problem perhaps is present there too. But I thought this was 16 more for the off normal where the vessel was partially cold 17 a1 ready and then you came in and pressured it again.
18 MR. WOODS: No, that's the LTOP event.
- 19 MR. MICHELSON: That's a what?
l 20 MR. WOODS: The low temperature, overpressurization, 21 LTOP.
23 MR. WOODS: And that's a different issue. It has --
24 MR. MICHELSON: That's a different generic issue than 25 this one.
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17 1 MR. WOODS: Yes, indeed.
2 MR. MICHELSON: This one is strictly the full power 3 operation generic issue.
4' DR. SIESS: Well, this is a transient where there is 5 a temperature gradient through the wall.
6 MR. MIC11ELSON: Well, those are considered transients 7 too. They are a more operating mode at the time, that's all.
8 MR. WOOD: Well, but the set of transients will get 9 you into it, and the conditions you are in to get there are so 10 different that we did indeed handle it differently.
11 MR. MICHELSON: So you treated that as yet another 12 generic issue.
13 MR. WOODS: That's correct. It wasn't a USI, was it?
O' 14 VOICE: Well, that one was resolved. My god, I 15 worked on that easily eight or nine years ago, and I think 16 every plant has had the new tec specs that handle that one 17 double acting pressure lease.
18 DR. SIESS: Bob, how does that differ from this?
19 That's the point. ,
20 MR. WOODS: Yes.
21 VOICE: We didn't have a formal process.
22 DR. SIESS: I mean why wasn't the pressurized thermal 23 shock issue identified as a part of the low temperature 24 overpressure issue?
25 VOICE: Oh, because the events that were, and that o lieritage Rcporting Corporation l
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( / 1 was keyed by events too. We were seeing events, and the most 2 common one was someone would inadvertently start a charging 3 pump while they were in cold shutddwn with a pressurizer full.
4 Only the B&W plants, if I' recall correctly, all is kept the 5 gas space and the pressurizer. GE and Westinghouse had water 6 solid pressurizer.
7 DR. SIESS: --
the phenomenon, why wasn't this one 8 subsumed into that? There's a difference somewhere. Was it 9 the change of temperature, rate of change of pressure.
10 VOICE: At the time that we were --
at least that I 11 was involved in low temperature over pressure protection, we 12 just weren't think in terms of transients starting and 13 operating power.
14 MR. MICHELSON: Well, thermal shock is thermal shock.
15 It doesn't have to be much of a gradient. If you put enough 16 pressure on, it can be --
17 MR. WOODS: LTOP is not thermal shock.
18 MR. MICHELSON: No, it isn't. It doesn't even have 19 to be thermal shock. It just has to be a gradient. of zero 20 through it, that's all. It's the uniform temperature.
21 MR. WOODS: Well, I didn't mean to get into a 22 discussion of pressurized thermal shock phenomena but --
23 MR. MICllELSON: Oh, just trying to find out, you 24 know, why this was separate from that.
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'O 1 eaocx 1 ve1 vee e te veretere ereaie t ecro e the veeee1 2 because you start from a hot operating condition.
3 MR. MICHELSON: Okay.
MR. WOODS:
4 LTOP does not. You start from a cold 5 shutdown condition.
l 6 MR. MICHELSON: Well, our various stages of shutdown 7 you can get into it also. Our various stages of startup --
8 MR. WOODS: Right, but if we --
9 MR. MICHELSON: And those apparently aren't covered.
l 10 This is only full power operation.
11 MR. WOODS: This is your meeting but that's not what 12 I thought we wanted to talk about.
13 DR. SIESS: Yes, we are getting into an area that the l
-O 14 subcommittee I guess has not pursued at the other end of the 1
15 process of how generic issues are identified.
16 Michelson is raising the question of why --
both 17 Ebersole and Michelson are raising the question of why did we 18 have to wait until an incident to identify the generic issue.
19 Now that is a subject we simply by-passed.
20 MR. MICHELSON: Well, I think this gets into the 21 question of the scope, too, of the generic issue. Apparently 22 this is only full power operation, then there must be another 23 generJ c issue which covers transients at other than -- other 24 than at the full power operation.
25 MR. WOODS: This is not only full power operation.
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20 O 1 Whet 1 ehoeia heve eeia th1e 1e het overetion, where the veeee1 2 is hot.
3 MR. MICHELSO!1: Okay.
4 MR. WOODS: Decause you can be at hot standby, and 5 that's even worse as a matter of fact.
6 MR. MICllELSO!J: Well, you can have thermal gradients 7 in vessels down to room temperature almost.
8 MR. WOODS: We can have a meeting on that, but that's 9 not this meeting.
10 MR. MICHELSON: Okay. Well, it's a part of the scope 11 question.
12 DR. SIESS: Well, I guess I am not sure. If it's 13 part of the scope question, then I think we ought to address 1 0 14 it, Bob. But 1 guess I think it -- if we can get it down to 15 some level that this committee can address rather thari the 16 committee that addressed the resolution of PTS, fou know, I 17 don't think we can take on the job here of reviewing the 18 resolution of every one of the generic issues.
19 What we have got here are some examples. Now if 20 these examples can bring up questions regarding the scope, I 21 think we ought to explore them to the extent that we have the 22 people here that can respond. But I'm not sure that you are 23 the man that can respond on --
24 MR. MICHELSON: Well, I guess it's very simple and 25 straight forward to state, what is the scope of the PTS rule?
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21 hf 1 MR. WOODS: The scope of the PTS rule is to handle 2 issues involving what we define as pressurized thermal shock 3 and the. aspects of pressurized thermal shock are a hot vessel l 1
4 which is suddenly cooled while at pressure or repressurized.
5 So you have the thermal gradient across the vessel which causes 6 a thermal stress, and you have in addition to that, 7 superimposed on that the pressure stress due to the internal 9 pressure, and the two together are ever so much worse than 9 either one separately, and they can drive a crack all the way 10 through the vessel if you have a sustained severe cool down. i 11 MR. MICHELSON: Is hot defined in the rules 12 comewhere?
13 MR. WOODS: No.
O 14 , MR. MICHELSON: So there is a little question only on 15 whether hot means 212, or whether hot means 546'.
1 16 MR. WOODS: I don't think it's even a question, 1 8 17 because it's rather clear what type of transients are 18 concerned. And if you could get into this kind of condition 19 from 100 degrees Fahrenheit, it would have to be considered.
20 It turns out I don't believe you can, because you don't have l
21 the thermal gradient. So you would not -- you just wouldn't be 22 able to calculate those as part of the analyses I will talk l' 23 about if I ever get to it.
l l 24 MR. EBERSOLE: Let me ask you a question.
25 DR. SIESS: Just a minute, please.
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( 1 Somewhere in the resolution -- I guess what Mr.
2 Michelson is getting at and I will, maybe we are jumping ahead 3 to what is the form of the resolution.
4 MR. WOODS: I'll get to that.
5 DR. SIESS: And it might be better if we started with 6 that. I'm not sure.
7 MR. WOODS: Okay.
8 MR. EBERSOLE: Well, let me ask in that connection, I 9 tried to put this together in maybe three pieces. I think we 10 can all understand rather easily what the potential pressure is 11 going to be if you pressurize the vessel from the high pressure 12 injection pumps,.and they keep on running up to zero flow. So 13 we know what the pressure potential is.
O 14 The other two parts of this problem, I think, is --
15 DR. SIESS: Excuse me, Jesse.
16 MR. EBERSOLE: Yes.
17 DR. SIESS: We have got to get our scope on this 18 subcommittee.
19 MR. EBERSOLE: Well, I am getting -- there are two 20 pieces --
21 DR. SIESS: We are not reviewing the resolution of 22 generic issue. This was reviewed by the committee. We are 23 looking at the process.
24 MR. EB$RSOLE: The scope.
25 DR. SIESS: And this is simply an example. Now if we Heritage Reporting Corporation (202) 628-4888 L_____________
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. 1 O- 1 ooe't tatex thet the 2eeett = -ee detteed prover 17 thet 1e 2 really something that should have come up when the committee f i
3 reviewed it before. i 4 MR. EDERSOLE: Well, all I want to do is just take 5 the scope.
6 DR. SIESS: Let me finish.
7 We don't think it was resolved properly, but I don't 8 think we can change the definition or change the resolution. j 9 If we identify a problem, we could stop, go on to something 10 else and write that up. But we can't go back and resolve this .l 11 problem. !
12 MR. EBERSOLE: Well, is he going not tell us ---
13 DR. SIESS: We are supposed to know what the 14 resolution is. This is an old issue. It was resolved in 1985.
15 And all we asked him to do today was to go through the history J
16 sort of and tell us what they went through. If we disagree 17 with the resolution, this is a little late to be doing it.
18 MR. EBERSOLE: Well, the ambiguous part of it is it's I J
19 the temperature transient, the profile, whatever that is, and 1
20 the metallurgical character of the material, copper and so I 21 forth, which has been brittle.
1 22 MR. WOODS: That's correct. !
23 MR. EBERSOI.E : That's part of the resolution.
24 MR. WOODS: If you want what the res'olution is, i'
25 that's what this second handout is. In fact, I was going to (o
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2 What you have here is -- well, the whole thing will 3 be out of context, but you have a 1982 version of what we 4 proposed as the resolution, and you have a 1985 version. And 5 the point is they'are the same. We went through a three-year 6 process of going through a bureaucracy, and we didn't change 7 anything. It took us three years to do that. That's what I l 8 want to talk about today. I don't --
9 DR. SIESS: All right, but what is the nature of the 10 resolution?
11 MR. WOODS: The nature of the resolution is there is .
12 a PTS rule --
13 DR. SIESS: Is it a restriction on operation? Is it i
14 a set of calculations you must go through? Is it a physical 15 change to the-plant. That's what I'm getting at by the nature 16 of it.
17 MR. WOODS: The resolution is a PTS rule. The rule 18 has several requirements. It requires all the plants to come .
19 in and tell us their state of embrittlement then and projected i l
20 into the future.
21 DR. SIESS: Problems with the material.
22 MR. WOODS: Yes, the material properties. It j 23 requires them to tell us about their plans to reduce the 24 fluence so that they slow down the embrittlement rate, and it 25 requires them if they go beyond a certain embrittlement level, Heritage Reporting Corporation (202) 628-4888
25 O 1 it re2uiree extene1ve eeeireee end everove1 by the Commieelon 2 before they are allowed to operate beyond that level of 3 embrittlement.
4 DR. SIESS: So that evolution was entirely in terms e 5 of the vessel properties?
6 MR. WOODS: Correct.
7 DR. SIESS: Nothing in terms of operating procedures 0 or conditions. -
9 MR. WOODS: Not until you get beyond that screening 10 limit that's specifJed in the rule. There is no prior 11 requirement other than to tell us what the embrittlement level 12 is and try to slow it down.
13 DR. SIESS: And then you decide whether to shut them O 14 down.
15 MR. WOODS: There is no requirement, or no mechanism 16 for shutting them down until they get to that screening limit.
17 THE COURT: So the resolution was strictly in terms 10 of material properties?
19 MR. WOODS: Correct.
20 DR. SIESS: And in arriving at that resolution 21 somebody went through all -- presumably -- enough scenarios --
22 MR. WOODS: Correct, we --
23 DR. SIESS: -- that any conceivable scenario material 24 properties stayed in certain limits, this would not be a ,
25 problem; is that right? ,
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1 MR. WOODS: Correct. We had $6 million spent at Oak 2 Ridge going ~ through all sorts of scenarios and deciding that 3 this level was safe. If they don't go beyond that level.
4 DR. SIESS: All right. So part of the scope then is 5 scenarios.
6 MR. WOODS: Very much a part.
7 DR. SIESS: And I think the kind of question on scope 8 then, are you satisfied that all the. scenarios have been 9 thought of?
10 MR. WOODS: Of course not. But we tried as hard as 11 we could.
12 MR. MICHELSON: Just on that particular point, if you 13 come across a new postulation of a cause for pressurized
'- 14 thermal shock, how is that incorporated, or how is that handled
-15 when you have already resolved the issue. Is it a new issue 16 then, or how do you handle it.
17 MR. WOODS: If we came across a new -- if the 18 transient were to happen tomorrow that suddenly made up think, 19 oh, boy, we didn't think about it. That could be a major 20 issue. We would have to reopen it if we thought it was a big 21 enough issue -- l 22 MR. MICHELSON: Well, is that the process? Do you 1
23 reopen the issue or do you create a new one? l 24 MR. WOODS: I think we create a new one.
25 MR. MICHELSON: And the new one will be identified as lO Heritage Reportinq Corporation i
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27 O 1 e eew eevect or the erevioee 1eeee, 1e thet r1 9nt7 i 2 MR. WOODS: I don't know. That's beyond me.
3 MR. MICHELSON: I just wondered about the process 4 which is what we are looking at.
5 MR. STEPP: Ron Frohm Stepp.
6 It would be a new issue and we would identify it as 7 part of the issue we were discussing here.
8 MR. MICHELSON: So when I read then preamble to this 9 new issue, it would tell me, well, this is the old issue with a 10 new wrinkle on it, and here is how we are going to handle the 11 new wrinkle.
12 MR. STEPP: That is correct.
13 MR. WOODS: I have another generic issue now that is O 14 a follow on from something that was previously done, and that's 15 certainly in the preamble, but I can't guarantee you that the 16 man 10 years from now who writes it up would -- he certainly 17 should. It would be the intent.
18 MR. MICllELSON: I just wondered what the intent was.
19 I don't expect you to guarantee future actions.
20 MR. WYLIE: Mr. Chairman.
21 DR. SIESS: Charlie, go ahead.
22 MR. WYLIE: Perhaps we ought to let Mr. Wood go on 23 through the process and start it, and then when we get to the l 24 resolution if we want to discuss it further, we can discuss it.
25 MR. WOODS: This usually happens and I think I have a o Heritage Reporting Corporation l (202) 628-4888
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- Q) 1 talk' prepared that will answer what I thought you wanted, and 2 it does have things in it that you are asking me, but I'm not 3 going to give it in very good order here.
4 DR. SIESS: Let's go ahead and try. The thing is 5 that what I want and what somebody else wants are not 6 necessarily the same thing.
l 7 MR. WOODS: Yes.
l 8 DR. SIESS: So_you will just have to do the best you 9 can.
10 MR. WOODS: All righte Well, that's what I am here l
11 for.
12 Okay, I was trying to say then after I got involved 13 with this, this slide shows you the early work that had to be
, I l 14 done and it involved some answering a rather critical report 15 that was already on the street. We were getting some bad press
! 16 and I had to --
l 17 DR. SIESS: Excuse me. As an expert, what was your l
10 expertise? Metallurgy?
19 MR. WOODS: I came from inspection and enforcement, 20 and I was following the operating events at Westinghouse 21 reactors.
22 DR. SIESS: So it was systems --
23 MR. WOODS: Systems aspects.
24 DR. SIESS: Systems rather than metallurgy?
l 25 MR. WOODS: That's right. That's why they approached O
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() 1 me outside of Crown. Books because --
2 DR. SIESS: I just wanted it set straight.
l 3 MR. WOODS: Okay. So the part of the formal process 4 that you do have is you go through a process of designating an 5 issue as an unresolved safety issue, and that involves 6 Commission approval of the paper that you write, which we did 7 in December of '81. So that is the official beginning of the 8 USI A-49, December of '81.
9 You can say that 'we should have done it 10 years 10 before. Fine. No argument, but that's when we started this 11 unresolved safety issue.
12 THE COURT: But the incident occurred in '78.
13 MR. NOODS: The incident was March of '70, I believe.
14 THE COURT: What went on in those three years?
15 MR. WOODS: I don't know. I wasn't there. I was 16 doing something else.
17 THE COURT: Anybody know what went on in those three EndT1 18 years?
19 MR. NORIAN: I think'that the accident at the Three 20 Mile plant just kind of put a hold to a lot of staff work. It 21 was not until after that was kind of cleaned out, and in 1980 22 the staff began to think of trying to come up with a new bunch l 23 of issues and this was identified. It was after that time that 24 this the staff began to work on this kind of stuff.
25 MR. WOODS: In fact, there was some pressurized l
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30 t 1 double shock aspects of the TMI accident. That was one of the 2 other events. I suspect that the TMI event triggered this in 3 more than one way.
4 MR. WYLIE: Do you know whether any letters or 5 bulletins went out during that period to make the licensees 6 aware of the problem?
7 MR. WOODS: I do not believe so. I do not believe !
I 8 think that it was really gone into very extensively during that {
9 period. I do not know.
10 MR. WYLIE: I mean notices.
11 MR. WOODS: I do not know for sure.
12 DR. SIESS: I find that rather strange. There is 1 1
i
'13 something that ends up being a USI which is the top category. ;
O 14 lt took three years for somebody to realize that it was 1
l
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15 important.
16 What kept it alive during those three years, does 17 anybody have any institutional memory here or documentat. ion?
18 MR. NORIAN: I think that some people on the staff 19 just kept raising this as a problem.
20 DR. SIESS: No formal methods for establishing 21 generic issues then or was it too formal?
22 MR. NORIAN: There was a process that was begun about 23 1980, and we went. through a whole bunch of issues at that time.
24 We identified A-45 through A-48, but A-49 was not picked up at l 25 that time.
l O l Ileritage Reporting Corporation (202) 628-4888 1
31 1 DR. SIESS: What was done out at Rancho Seco, 2 anything, or on the plant specific issue, what anything done 3 about this?
4 MR. NORIAN: I am rather vague on that, but I think 5 that for that plant quite a bit was done. Rancho had come in 6 and tell us why it was okay for them to restart that plant.
7 DR. SIESS: That was not generic?
8 MR. NORIAN: Not generic. But at least for Rancho, 9 they had to come in and explain.
10 DR. SIESS: Their basis was restart, was it anything 11 like the resolution that we finally came up with on EPS?
12 MR. NORIAN: I think that the main concern at that 13 time was to show that for that transient that no damage was 14 done to that vessel. And the main thing that I think. that 15 saved them at that time was the fact that the vessel was so 16 new.
17 MR. WOODS: That is the nature of the what if 18 question, what if the vessel had not been so new.
19 MR. EBERSOLE: Chet, way back in history, I think 20 Dave Oakrey, the little match, but it was in the wrong place.
21 He was postulating a vessel failure at the LOCA, and that 22 prompted a reconsideration without the LOCA, and that,is what 23 really gave birth to this thing.
24 MR. WOODS: But with the LOCA, of course, you do 25 not --
O IIeritage Reporting Corporation (202) 628-4888
32 1 MR. EBERSOLE: You do not have the pressure, you do 2 not have the pressure. But he was going to have pressure 3 because of thermal shock.
4 DR. SIESS: Thermal shock has been around, 5 pressurized thermal shock.
6 MR. EDERSOLE: At that time, the influence of l
7 secondary systems on primary systems were very weakly 8 attended. j 9 DR. SIESS: But the PTS is different from just 10 thermal shock.
11 MR. WOODS: We were indeed worried about thermal 12 shock. And it turns out that it takes the pressus.e to force 13 the crack the rest of the way through. So with the large LOCA, 14 you do not have the pressure and you do not get the same result 15 as you do when you start looking at PTS.
16 MR. EBERSOLE: Right. But this was the evolving 17 influence of the secondary on the primary system that was 18 occurring at that time.
19 MR. WOODS: That is right, that is correct. It took 20 awhile to realize that it was a problem. That is a fact.
i 21 DR. SIESS: Your previous slide mentioned the what ?
22 ifs. The what its did not seem to get anywhere for about three i
23 years. I 24 MR. WOODS: That is correct. They did not get far 25 enough to make it a USI, that is for sure. I do not know what f i i
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33 q-Q 1 they did accomplish.
2 DR. SIESS: It probably was not even a generic issue.
3 MR. WOODS: No, I do not think it was.
4 MR. EBERSOLE: Well, it was in the era when the 5 seawater was not classified as a critical system.
6 DR. SIESS: Yes. And it was in the era of post-GMI 7 when everybody was worrying about TMI and nobody was worried 8 about this.
9 MR. WOODS: The points that I guess that I wanted to 10 make on this slide are that there were large efforts underway 11 at the time. When we finally got cranked up on this, it.did 12 become a pretty big offort. I think that we have probably 13 spent twenty to thirty staff years of-NRC time. You wanted to
' 14 know what it cost, you know, personnel- wise and dollar-wise.
15 We spent about $6 million at Oakridge National Lab doing three 16 full-blown PRA calculations and PTS risk at three 17 representative plants, j l
18 That was done through e different office. I am in !
19 research now, and then I was not. That was done through 20 research then. There were lots of people who were working with 21 me on this. We had directly in NRR a contract with Pacific )
i 22 Northwest to do some calculations which I call consequences )
I 23 here, but really it was like, okay, so the current goes through
)
l
. 24 the wall, what does it mean, does the vessel fail, does the i
! 1 25 core melt, does the containment fail, that kind of calculation
} Ileritage Reporting Corporation (202) 628-4888
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( l' which we did.
2 (Slide) 3 The most important point on this slide though is that 4 during the early part of this during the initial work, during 5 the year when we actually resolved this, we had a very 6 extensive participation from the industry owners groups. We 7 had all three PWR owners groups meeting with us probably on a 8 monthly basis, an they were doing calculations and they were 9 participating.
10 So when we got through with this thing, they already 11 knew what we were doing. They had already had their input.
12 That becomes important on a later slide. And just as an aside, 13 we also to make things interesting, we had a congressional 14 hearing on PTS during that first year.
15 MR. MICHELSON: When did they converge on what the 16 magnitude of the initial defect was or have they?
i 17 MR. WOODS: When did who converge?
18 MR. MICHELSON: The whole study. There has to be an 19 initial defect, does there not?
20 MR. WOODS: Right.
21 MR. MICHELSON: And is that standardized now?
22 MR. WOODS: We just basically assumed that there is a ,
23 defect, and that is one of the biggest undercertainties.
24 MR. MICHELSON: I know. What is of a certain size k
- j. 25 now that we all agree to?
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'l 35 O. 1 un. wooos: ne, -e 1oex et tue wne1e eeectrem et 2 sizes that it might be, and assume that the worse size is 3 there. At least you do that deterministically. When you are 4 .doing a probabilistic analysis, you take in effect size of 5 distribution which comes out the Davis-Marshall report, as I 6 understand it.
7 DR. SIESS: Is the crack size of any relation to what 8 it detectable in the inspection?
9 MR. WOODS: It has a relation, but unfortunately it i
10 is the smallest size cracks which you cannot be assured you 11 will detect, and that is why we have an issue. If you were 12 sure that you had no cracks, we would have no PTS issue, which 13 I think you know but now it is on the record. Okay. I think 14 that I am through with that one.
15 (Slide) 16 Now remember, we declared this as a USI in December 17 of 1981. During the following year up until November of 1982, 18 based on the stuff that I just told you about, the twenty to 19 thirty personal staff years, and the Oakridge stuff and the PNL 20 stuff, plus some part of the heavy section steel technology 21 program at Oakridge. And I do not know how much of that $10 22 million per year to attribute to PTS, so I do not know how to 23 give you a total number. That is the point there.
24 But based on all of that stuff, we put together, we l 25 the staff, largely using the industry owners group stuff LO Heritage Reporting Corporation (202) 628-4888 l
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n I 36 o)- 1. reviewed by us and changed, but nevertheless that is where it.
i 2 came from, we put'together what we thought was the resolution l
~3 of pressurized thermal shock. And it was published in Circular 4 82-465. The top page which you have on this handout is a -
4 1
5 compilation of some of the interesting parts from that 1982 6 document.
- 7 DR. SIESS
- It was done in about six months.
8 MR. WOODS: It was done in about a year.
9 DR. SIESS: The test action plan was April 1982.
10 MR. WOODS: But the test action pian is something 11 that you write and it does not mean that you are not already 12 working on some of the things that are going to be in it while j- 13 you are doing.it.
14 DR. SIESS: So then you would be counting then from 15 December 1981.
l 16 MR. WOODS: I am counting all of this from December 17 oi 1981 when we officially declared this as a USI. Just 18 arbitrarily, you can start it from anywhere you like, but that 19 is the official.
20 DR. SIESS: So in about a year, you had that stage of 21 resolution.
22 MR. WOODS: In about a year, we had this stage of i 23 resolution which describes e rule that we thought that we !
24 should implement and that we recommending implementing, which 25 would establish a screening lire.it, encourage voluntary flux lieritage Reporting Corporation (202) 628-4888
37
.( -1 reduction, would require building reporting, and would require 2 extensive analysis and Commission approval to operate over 3 that limit. That is on the first page here from that .1982 4 document.
5 And with the ACRS in further agreement at a December j l
6 9, 1982 meeting of the Commission, we were told we like it, go I 7 do it, go make a rule, one year.
8 How the next one tells you having done that it took j j
9 us until July of 1985 to do it, and that is what I mainly came 10 to talk to you about, what does it take so long to get 11 something done once you decide what you want to do. I do not 12 have all of the answers, but I will share with you what I do 13 know.
.14 So what I am showing here is it took us until July of 15 1985. This is the details of getting to July of 1985, and I 16 start it with the lapse time of twelve months. That matches 17 this December 9, 1982 Commission approval . date. And it is 18 twelve months there at the starting point, because remember we 19 designated as it as USI a year before that in December of 1981.
l 20 So I have just kept you from counting on your fingers like 21 everybody was doing in the earlier version of this slide.
22 If you can follow through. Okay, so we were told 23 December 9th to start it. We wrote a proposed rule package
~24 which took that particular format and turned it into a 25 Commission paper saying okay, this is a rule that they want you O
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Y 38 h 1 to approve. That took us abnu t ' a month .
1 2 Then we started through the process thatf1 found kind 3 of disappointing I guess. We reviewed it and we changed it, 4 and we took to another office, and we reviewed it en'd changed 5 it again, and we took it to another office. At about that 6 time, there was a disaster on the bus where 1;got on the' bus 7 one day and I was talking to my boss about this, and some guy 8 behind us said, gee, I was not on the approval list, and 1 9 turned around and said who the hell are you, and that could 10 have been a disaster depending on who it was, but it was not 11 too bad of a disaster.
12 So that is the kind of state of mind that you get to 13 when you find out how broad the system is and how many people O 14 do have a legitimate action with these things. It is quite 15 extensive.
16 So we finally got all of that squared away. By the 17 way, the disaster did not slow us down any. That all turned !
l 18 out to be a big help. We got concurrence about our own staff, 19 our staff lawyers. We brought it your folks, and took it to 20 the CRGR. / I 21 On July 25th of 1983, we had another second paper i
22 which we sent to the Commission which said okay, here is a
/
23 rule, we want your permissi6n to publish it for public comment 24 which is the first major, step that you go through when you are 1
25 doing a rule. And then I will show you the details of what l O
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4 39 l' < happened to it then. Let's ree, where am I Ch, okay, I moved i ;
2 it,up'too far. I 3 It took this long to get the first Commission 3, 4 approval, and that was Chairman Paladino 's . So that took two 5 nonths, and it took more months before we had the last ;
\ /
r 6 Commisalon's approval. And then it took another two mont.hs 7, before we had a formal document back from the Commission saying q l
0 here is,the unified recommendation, this is what the Commission 1 9 as a collegial body wants you to do. That was our permission 0 to. publish it.
3 .
1L We publishMi it then having gotten the permission at
.t 12 the last of the month. jIt takes that long to mail it and get t 4 13 the Federal Register to' yublish it. That was three months, a l O 14 ninety day public g mment period, which actually lasts longer 1
15 than that probably(I because the comments keep dribbling in for e
l 16 another month ard a half, i' 17 MR. EDERSOLE:- I would like to ask you nince you are 18 telling us how long it took and since it comes to us merely in 19 the form of two numbers, 270 and 300, what the hell were they j 20 i guing about all of this time, whether those numbers are right I 21 've not?
22 MR. WOODS: You are asking the wrong man. I would 23 like to know that, too.
I
, 24 DR. SIBSS: They do not necessarily argue. It just 25 takes them time to read it and decide.
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MP.. EBERSOLE: Were there other elements under 2 consideratiori'besides these two numbers?
3 MR. WOODS: Well, the readon that I gave you that f1 s 4 paper that you are holding there is so that you can judge for 5 hourselfwhethertherewereanysignificantchangesmadeduring 6 1,[h ts time. I believe that there were not. So I do not know 7 wh,>y it takes that long. It should not take the long, everybody 8 has a staff and everybody has lawyers.
9 MR. EBERSOLE: That is what it is, two numbers.
10 MR. WOODS: It takes awhile to go through.
11 DR. SIESS: 1 think that it would take that .long to i
12 issue-a' rule that had nothing whatsoever to do with safety.
13 MR. WOODS: It would take largely that long. And.one 14 point-thac I want to make with this is this was a rulci that
+
15 everybody<Iwas supporting. Every pretty well realized that we 16 had some that we needed to do something about including the 17 industry, yes.
18 DR. SIESS: Including the industry.
19 MR. WYLIE: By the way, it is two numbers, why could 20 it not be one number?
21 ', DR. SIESS: That is a technical issue. I 22 MR. EDERSOLE: Why did it take nine months to write a l I
23 final package when you did not make any significant changes and 24 you had already been through all of the public comment? '
r 25 DR. SIESS: Down to the 29 to 387 t
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41 0 1 MR. E8ERSOtE: vee, 1 themeht thet it whet we were i 2 discussing.
3 DR. SIESS: ir<. ll , he is just at that point when he 4 got interrupted.
5 MR. EBERSOLE: Oh, I thought that he was giving us 6 the answer.
7 MR. WOODS: I do not know the answer.
(
8 DR. SIESS: Let him get down to the last item, and 9 then we will go back a 31ttle bit.
l l 10 MR. WOODS: Okay. Well, let me see, where are we, 11 okay. We published the proposed rule and we got through the
! 12 public comment period, and that lasted a little bit longer.
13 And then my point here is that you take the public comments 14 which really were not significant because we had had the owners l 15 - group participation and so forth, and that would be the main l
16 parts of the public that are going to really going to say, oh, l
1 l 17 no, you have got to do it some other way. They did not do 1
18 that. They supported us, largely supported us.
19 And so then you start back through the whole system.
l 20 And the reason that I wrote it this way is because it is like 21 one of those repeats in music, I am not a musician, but you 22 just go back up to the top and you start town through again.
23 You do not have the disaster on the bus this time, but 24 otherwise it is about the same.
i 25 DR. SIESS: The nine months is not just to write it?
Heritage Reporting Corporation (202) 628-4088
42 1 MR. WOODS: No.
2 DR. SIESS: There are two more bullets behind it.
3 MR. WOODS: In fact, I wanted to make the point that 4 we wrote it in a month. So at that point, we had it. It was, 5 you know, in your hand.
- 6. MR. MICHELSON: It did not go all the way back 7 through the Commissioners again, because that is from 30 to 42.
8 DR. SIESS: That is right, but it had to back through 9 all of the offices.
10 MR. MICHELSON: Yes, but with no significant change.
11 The offices did not do much with it.
12 MR. WCODS: I beg your pardon, it did go back through 13 the Commissioners.
O 14 MR. MICHELSON: The 30 to 42.
15 DR. SIESS: He is looking at the 29 through 38 16 interval. j l
17 MR. MICHELSON: I am looking at nine months in there )
l 18 to write a final rule when no significant changes are made j 19 which means at all of the offices looked at what they had 20 already agreed to.
21 DR. SIESS: Dut that nine months corresponds to the 22 12 to 19 up above, right? !
23 MR. MICHELSON: Yes, I would think so.
24 DR. SIESS: It took seven months, and this time it 25 took n.ine.
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43 O 1 MR. - M1CREtSOn: 8et thie time there were no chen2es 2 from it took seven months to do before.
3 MR. WOODS: Wait a minute, .I am not getting the same 4 thing. Okay, let's see.
5 DR. SIESS: Well, if you look up at the first item 6 that you started out, wrote proposed rule.
7 MR. WOODS: Right, I see.
8 DR. SIESS: Then the 29, you wrote the final rule.
9 MR. WOODS: Right.
10 DR. SIESS: And the 12 to 19 would take it up to the 11 point where it went to the Commission just like the 29 to 30.
12 MR. WOODS: Okay.
13 DR. SIESS: So the seven anonth cycle up at the top.
14 And Carlyle's point is that the thing was not changed and this 15 time it took nine months to get it through the process.
16 MR. MICHELSON: That is what appears from just a 17 simple listing.
18 MR. WOODS: Well, one of the reasons is because in 19 the first time block that you are talking about it took us a 20 month to write the rule. And in the second time block that you 21 are talking about, there is a forced three month public comment 22 period.
23 DR. SIESS: It starts with 29, the public comment
- 24 period ended. We are going from 29 to 38.
25 MR. WOODS: Okay, I see.
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1 MR. MICHELSON: I guess that they have to write up 2 the public comments, of course. But since you said that they 3 were not that significant or complicated, it did not take long 4 to do that. Something happened in there that it took longer.
5 DR. SIESS: It takes time to write them up.
6 MR. WOODS: There is no major thing that I can point 7 to. It takes awhile to digest 180 different public comments 8 and get everybody to agree that you have handled it properly 9 and send back through the system.
10 MR. MICHELSON: But you said that they were not 11 significant.
12 DR. SIESS: Somebody has to decide that they are not 13 significant. Somebody else has to agree that they are not O 14 significant.
15 MR. WOODS: Lots of somebody elses.
l l 16 DR. SIESS: The word that I have heard used in 17 relation to this is bureaucracy.
18 MR. WOODS: Well, I guess that I have made all of the 19 points that I have wanted to on this.
20 DR. SIESS: Now let me ask you something.
21 Was anything being done about pressurized thermal 22 shock by the industry during this period?
l 23 MR. WOODS: Yes. During this time period that all of 24 this was going on, this paperwork, there was indeed a very 25 large effort on the way by the industry to reduce affluence, O
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45 1 and to delay or avoid the problem. In fact, I would have to 2 say that as of today we have a rule that sort of sets an upper 3 limit, but the things that have really been accomplished out 4 there in the field are that most of the plants or probably all 5 of them are operating at a significant lower rate than they 6 were when we started this project. That is the thing that we 7 have really accomplished in the true sense in the real world.
8 DR. SIESS: The things that they had to do to meet 9 the limits set by the rule. The rule did not require them to 10 take certain actions. The rule stated certain limits, and they l 11 knew what those limits were going to be, and they started doing 12 the things that they had to do.
13 MR. WOODS: Right. The rule also strongly encouraged l
O 14 them to avoid exceeding that limit.
15 DR. SIESS: But encouragement.
16 MR. WOODS: Well, there is encouragement and 17 encouragement. They could see the reasons for it themselves, 18 and we encouraged it, and they did it.
19 DR. SIESS: Would you say that by the time that the 20 rule was finally issued that most people were in pretty good 21 shape to prove that they were in compliance?
22 MR. WOODS: Yes, I would say that.
23 DR. SIESS: And if the rule had been issued in 13 24 months instead of 43, it would have ended up at about the same 25 place?
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46 1 MR. WOODS: It would not have not truly made a lot.of 2 difference. The fact that the rule was in process and the fact ,
3 that they knew that the rule was coming really was probably'as 4 significant as actually having the rule. So.I do not think 5 that in this case that this long process hurt the safety.
6 DR. SIESS: Now I think that we could find some
- 7. examples where the industry jumped the gun and they got stung 8 because things changed. I assume that they had a high level of 9 confidence that the rule was not going to change that much.
10 And if it did change, they were still going to have to'do the 11 things they did.
12 MR. WOODS: I think that is true.
q 13 DR. SIESS: They were out to reduce the affluence.
b 14 The numbers might come out different, but still they better get l
l 15 that affluence down.
16 MR. WOODS: I think that any responsible utility 17 would know that it should not and probably would not be allowed 18 to operate its plant at a very high level and he would want to i l
19 avoid it, and we encouraged it. It was something that he was 20 going to probably do maybe later when it is less effective, but 21 probably do anyway. But I have no way of knowing that for 22 sure. )
23 I think that the rest of the points on this have been
, 1 24 covered. I was going to raise questions at this point which 1 25 you have already raised. Were there significant changes? I do q u V
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1 not think so. You have got the before and after there in front 2 of you that you can look at later.
3 Were the changes worth the time required? In this 4 case, I can only answer for this case. I do not think that 5 they were. I mean I am not in charge of what kind of process 6 that a democracy ought to have to create a new rule. It 7 probably does require public comments. In this case, they were 8 not worth the time. In other cases, that is up to someone 9 else. I cannot say.
10 DR. SIESS: Well, the Commission and the staff do 11 have available to them procedures for taking care of things 12 much more rapidly than this, if they are significant 13 decisions.
14 MR. WOODS: And one of the unique features of this 15 one is that it was a perceived future problem. It was not a 16 present earthshaking problem, because the plants were not that 17 embrittled yet as of that date. They were going to be in the 18 future. So you were trying to do something to prevent a future 19 problem.
l 20 Okay. I guess that I would like to make this point.
21 Why does it take so long? In a nutshell, it takes so long 22 because it is a very large group. You called it a bureaucracy. f l
23 That is true. It certainly is. I 24 How the people who have a legitimate interest in this 25 kind of issue administrative 1y and technically are widespread.
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i 1 They are in many, many parts of the organization, and simply 1
2 none of them want to be left out. The ACRS is an example. I l
3 They were very cooperative, and they did not want a delay if 4 anything. They would not want to be left out. They should not S be left out. You know, you have a statutory obligation to look 6 at this. But so does everybody else, and there are lots of 7 them.
8 DR. SIESS: Well, actually this involved a rule 9 making.
10 MR. WOODS: Yes, it did.
t l 11 DR. SIESS: I am not sure that all of the examples 1
12 here end up with rule making.
13 MR. WOODS: I doubt if they do.
O 14 DR. SIESS: If it had involved only a SRP change or a 15 regulatory guide, I would assume that the time involved in what 16 'I would call almost the administrative chain would have been l 17 significantly less.
18 MR. WOODS: Right.
19 DR. SIESS: But not zero.
20 MR. WOODS: You do not have to go out for public 21 comments for that sort of thing, as I understand, and you do 22 not have to go through Commission approval.
23 DR. SIESS: Well, reg guides go out for the 24 comments.
25 MR. WOODS: Reg guides do, yes. In fact, let me l
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1 ti 1 a het e1e="ed, aece" e the verr et 11oe were-
>O 2 (Slide) 3 MR. WOODS: The rule says that you have got to do 4 extensive analysis when you get up close to this embitterment 5 limit, and then there was a reg guide that we only recently 6 published to tell people in more detail how to do thoss 7 analyses.
8 MR. EBERSOLE: Let me ask you~Phis question. These 9 two numbers here, _there is no definition of the uncertainty, 10 and how is that allowed?
11 MR. WOODS: The two screening limit numbers?
12 MR. EBERSOLE: Yes.
13 DR. SIESS: That is technical issue on the 14 resolution.
15 MR. EBERSOLE: But without some definition, I do not 16 know what this means unless there is some uncertainty.
17 DR. SIESS: You are just about three years late.
18 MR. WOODS: There is a report that does discuss the 19 uncertainty at great length. I have just xeroxed one page for 20- you.
21 MR. EBERSOLE: It just does not show here, okay.
22 MR. WOODS: It does not show there, no.
23 MR. MICIIELSON: On these extensive analyses that are 24 required if you are approaching or exceeding the PTS limit, are 25 these the analyses wheroin you go through the various O
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50 1 postulated transients to show what the true problem would 1
2 be?
3 MR. WOODS: Yes.
4 MR. MICHELSON: And you do not even need to go 5 through those analyses I guess until you approach or exceed 6 that.
7 MR. WOODS: The whole process that we went through 8 was to do that sort of calculation for the plants that are out 9 there. And based on those analyses, we believed that it is 10 adequately safe to operate genericaJ1y as long as you stay 11 below these limits. It may be safe to operate above those 12 limits, but you need a plant specific if you are going to, and 13 that is what these analyses are for. It is that required plant O 14 specific.
15 MR. MICHELSON: You apparently. issued instructions on 16 how to do these analyses. 4 I
17 MR. WOODS: That is what the reg guide is, that is 18 correct. )
l 19 MR. MICHELSON: And if you decide later than maybe 20 there are more analyses or a different kind of analysis needed 21 then you revise the reg guide, would that be the process?
22 Because you do not need to change the rule, you just need to 23 change the analysis process to verify compliance with the .
24 rule.
25 MR. WOODS: Well, as a matter of fact, that is A
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51-O t j 1 certainly true. But one thing that is in the mill now is one 2 of the features of the rule is how do you determine where a 3 plant is with respect to the embitterment limit. There is a 4 'certain correlation that the rule specifies that you must use.
5 There is now on the street for public comment a different 6 method that is advertised as being a better method to do that.
7 And we are going to have consider changing the rule to 8 incorporate that better method. So there is a rule change in 9 the process.
l 10 MR. MICHELSON: But you can keep changing the 11 analytical process to verify compliance by just changing the
.12 regulatory guide.
7 13 MR. WOODS: You could, but the analytical process 14 that is in the reg guide is not described so t. specifically that 15 you are likely to have to change it. It says use good methods 16 and do good work and show what the risk is.
17 MR. MICHELSON: That is why I said the reg guide 18 which presumably gives more detail on how to do this.
19 MR. WOODS: It does, but we purposefully tried to 20 keep it --
21 MR. MICHELSON: Still very vague?
22 MR. WOODS: Well, I would not characterize it as very 23 vague.
24 MR. EBERSOLE: Well, what you are saying is really 25 the rule doos not mean anything if the reg guide can be i
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52 0 1 eregered to grodece the enewer eccordine to whetever roete thet 2 you define. It does not mean a lot if I have got a recipe with 3 which to produce it.
4 MR. WOODS: The rule says that you have to do a 5 really extensive analysis.
6 DR. SIESS: I know, but it also says that the staff 7 has to approve them, Jesse.
8 MR. EBERSOLE: But it also says that these numbers 9 here are meaningless without the associated aspect of the 10 guide.
11 MR, WOODS: The issue that you are raising is that 12 when somebody does one of these analyses and he says okay, I am
, 13 going to exceed 270, and I am going to go to 4000 degrees, and k'
14 he comes in and he says will you approve this thing that it is 15 okay. That is up to the future men, I cannot answer you. I 16 cannot answer you.
17 DR. SIESS: Well, Jesse, if the staff is incompetent !
I 18 and the applicant is corrupt, he can bust his vessel. I am 19 afraid that is true.
20 MR. NOODS: You are counting on the review process in 21 the future.
22 DR. SIESS: The ACRS approved this, and I do not 23 think that we want to completely review it here. Thank you.
24 This has been useful.
25 MR. WYLIE: Let me ask a question.
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l' DR. SIESS: Okay, sure.
2 MR. WYLIE: If this came up today, this type of .
3 thing, would it be handled any differently?
4 DR. SIESS: I thought that he said that it would take 5 longer today.
6 MR. WOODS: I think that it would take longer today, 7 because there are now more, you called it bureaucratic, more 8 requirements. The backfit analysis we did not have then, for 9 example.
10- MR. WYLIE: It would take more internally to begin 11 with.
12 MR. WOODS: Yes.
13 MR. WYLIE: What about in the interim today though, O 14 if this came up, a bulletin would be issued today if something 15 like this came up, would it not?
16 MR. WOODS: The very latest push is to have a lower 17 count of USIs, because that is apparently is taken to indicate 18 how safe the plants are, how many USIs you have on the books.
19 DR. SIESS: All right. Now I have no preference on 20 the order, but we are going to take a five minute break.
21 (Whereupon, a recess was taken.)
22 MR. ROSA: Well, first I want to thank you for 23 approving the change in sequence here. I have got a commitment l
24 to help send Frank Shroeder on his retirement. at noontime 25 today.
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54 O 1 The difference between 119htenino etrohee end EMP le 2 essentially in the duration of the pulse and the rise time. An i
3 EMP pulse is on the order of, I believe, one nano second. And l
4 a lightening strike pulse is probably around a couple of mille-5 seconds.
6 MR. EBERSOLE: As long as you are extending this, l
.7 could you also say something about the effect of a severe 8 arcing within the building, for instance, say a switch gear, 9 wherever, and how does it relate to electro-magnetic pulses?
10 MR. ROSA: If -- you have read the Sandia Report and 11 our own extension of it, that addressed the effects of signal 12 upset, and it is documented there, that the response to EMP 13 within the plant, is generally less than -- the peak O 14 response -- is generally less than the operational voltage, at 15 the points of interest. So, it is not expected that there will 16 be what you call significant arc-over.
17 There was one comment made --
18 MR. EDERSOLE: No, I think that what my question is 19 directed to more is the effect of EMP on the solid state 20 devices in terms of control actions and oo forth.
21 MR. ROSA: With regard to the most sensitive devices, 22 that is the solid state stuff, it was established by the study l 23 team that the response at the device, itself, was generally 24 much less than the threshold damage volt.
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( 1 solid state component, I am concerned about it causing unwanted 2 . actions during the emission of the pulse.
3 MR. ROSA: Okay, we, .in enclosure three to the staff 4 report to the Commission, at Sec 83367, I believe, we examined 5 that. And using the results of the Sandia Study, we inferred 6 from that, that there would be no significant effects due to 7 signal upset.
8 Now, the reason for that, basically is this, that the 9 response EMP response of the circuitry inside the plant, is 10 generally of about 10 micro-seconds duration. And it is a 11 dense synasold or a summation of the dense synasoids, of that 12 duration.
13 And the response time of even the most, the fastest O 14 elements that you might find in control circuits, is about 10 15 mille-seconds.
16 MR. MICHELSON: Well, is that true of solid state 17 controlled circuits? It is true of electro-magnetic devices.
I 18 But is it true of solid state controls such as in the new 19 plants?
20 MR. ROSA: Our evaluation --
21 MR. MICllELSON : I am trying to get an idea, you know, 22 of the scope of this resolution and how you made it clear what 23 the scope was, and how, and whether or not, you even included )
24 fast response, solid state circuits, which we have in many 25 plants now?
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i 1 MR. ROSA: Well, let me state this first.
2 The Sandia Study, I am getting to that in the next 3 ' slide. 1
,4 MR. MICIIELSON: Okay, you got the thrust of my 5 question and you don't need to answer it now. I will look for 6 it d'uring the presentation.
.7 DR. SIESS: Is lightening still an issue somewhere?
8 MR. ROSA: No, I don't believe that lightening is 9 still an issue. We have taken the position that the protection 10 against lightening provided by the application of conservative 11 industry standards'is sufficient.
12 Now, there are plants that have experienced some 13 spurious actuations, and scrams even, and some damage to, I O 14 believe, inverters.
15 DR. SIESS: Was the Reg Guide ever issued?
16 MR. ROSA: The Reg Guide was never issued. It was 17 dropped and as far as I know, there is no intent right now, to 18 reactivate that.
19 MR. EBERSOLE: Well, you mentioned a while ago, you 20 said that the principal difference was that the lightening 21 strike was a longer duration and not as steep and it implied to 22 me, that really lightening was more of a problem than this 23 thing.
24 Is that correct? It can get deeper in the system and 25 do more permanent damage to diodes and other things.
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- h. 1 DR. SIESS: Well, we have established that it is not l 2 now'an issue. I think that if we want to raise it as an issue, 3 we go through --
4 MR. EBERSOLE: Well, it goes deeper into the plant 5 and it can do more damage, is what I think that I heard you 6 say.
7 MR. ROSA: I believe that experience thus far, 8 indicates that where a lightening strike impinges on circuitry 9 that is within the plant -- there have been instances of 10 strikes on the containment, in the penetration area, that have 11 caused some spurious scrams and damage to the instrumentation.
12 But beyond that, --
13 DR. SIESS: But that is a separate issue.
O'^' 14 MR. ROSA: That is a separate issue.
15 DR. SIESS: Then a partial answer to what Mr.
16 Michaelson was asking, do you think that the definition of this 17 issue and its resolution makes it clear that lightening is not 18 covered by the resolution of this issue?
19 MR. ROSA: That is right, lightening is not covered 1 20 by the resolution of this issue.
21 MR. MICHELSON: Now, is internal EMP generation 22 covered, internal to the plants?
23 MR. ROSA: Are you talking about EMP pulse --
24 MR. MICHELSON: Electric arcing, or walkie talkies 25 would be the opposite extreme in terms of energy levels. The ;
l O
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58 O 1 who1e eeectrum -ithin the vient thet cou1d de senereted, ere 2 those a part of this?
3 MR. ROSA: Those are not a part of this issue.
4 MR. MICHELSON: Now, if they are not, where does it 5 say in this issue, this is not a part of this issue, you are l
6 going to have to either make it an issue, or do something, but 7 it clearly is not.
8 Why don't we come out and say, what is covered and 9 what is not covered?
- I 10 DR. SIESS: The background says that it is weapon, 11 nuclear weapon detonation.
12 MR. MICHELSON: Yes, which are you reading now?
13 DR. SIESS: I was just reading the SECCE.
O 14 MR. MICHELSON: Yes, and that says, really it is 15 nuclear weapons that you are worried about.
16 DR. SIESS: But is there anything in the formally 17 stated reso1ution, that limits it to nuc1 ear weapons 18 detonation?
19 MR. ROSA: It limits it to nuclear weapons and to 20 pulse generators that might be used --
21 DR. SIESS: External?
22 MR. ROSA: -- external to the plant.
23 MR. MICHELSON: Okay, now, the internally generated 24 EMP, has that ever been brought up as a generic issue?
25 MR. ROSA: It has been -- we have been aware of it, O
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59 (Oj 1 but as a generic issue, I don't believe that it has been 2 brought up.
3 MR. MICHELSON: Okay, because I hear the answer from 4 time to time, being this Sandia work and so forth, and I think 5 that it was even inferred today. And I am not sure that that 6 Sandia work covered all of these internal sources, and what 7 effects they may have, particularly on newer plants. And this 8 again, is a question of making clear when you read these i 9 documents, what the scope is. ,
10 MR. ROSA: Can we go on?
11 MR. EBERSOLE: One more moment.
12 You are, I am sure, acquainted with the Henford Plant g 13 and spiking of the diodes? What spiked them and is it any 14 relationship what happened to them, what we are talking about?
I5 MR. ROSA: I am not all that aware of that incident.
16 MR. EBERSOLE: Oh, it locked up the SCRIM system 17 because they punctured two of them in a series which were 18 thought to be redundant.
19 DR. SIESS: It wasn't an electro-magnetic pulse from 20 nuclear weapons.
21 MR. EBERSOLE: IJo , I am trying to find out, though, 22 how clore we are to that.
23 MR. ROSA: I am not aware of the details of that 24 incident, so that I cannot answer the question.
25 MR. EDERSOLE: Okay.
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60 1 DR. SIESS: And you don't really know whether the 2 Sandia stuf f would apply to internally generated EMP, if it 3 came up as an jssue, somebody would look at it?
l MR. ROSA: I believe that parts of the Sandia results-4 5 would be applicable.
6 DR. SIESS: But the issue has not been raised, and-it 7 is not on the books now?
8 MR. ROSA: That is right.
9 DR. SIESS: Okay.
10 MR. ROSA: The nature of the resolution is depicted l 11 here. As you all know, I believe, the issue was first raised 12 by Demetrius Basdekas'in 1976, and it is documented in NUREG 13 0153, issues 27. And now, at that time, the Staff relied on an ,
O. 14 Oak Ridge report, I believe, authored by Randy Barnes, which, 15 in offect, reached the same conclusions as the Sandia Study.
16 However, it was questioned, its rigor was a question i
raised by certain people and therefore, it was decided that a 17 10 new study, more rigorous, would be undertaken to resolve this 19 issue.
20 It was held in abeyance between 1976 and 1979, when 21 it was raised again by Mr. Basdekas, in a letter to the 22 Commission, and also to various members of Congress, and maybe 23 even the President.
24 At that time, the Commission directed the Staff to 25 undertake a study.
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61 1 DR. SIESS: At what point was it designated a generic 2 issue?
3 MR. ROSA: I believe that it was not designated a 4 generic issue until some time after that, and I don't know the 5 date.
6 DR. SIESS: When did we begin having generic issues, 7 does anybody know that?
8 MR. ROSA: I defer to Ron Frahn.
9 MR. FRAHN: The formal process I guess wa.a developed 10 in what, 1978?
11 MR. ROSA: I think in 1978.
12 DR. SIESS: That is good enough.
13 MR. ROSA: Shortly after the Commission authorization 14 for the study and the Staff undertook to contact the Defense 15 Nuclear Agency and be briefed on what the Defense Department 16 had been doing in regard to EMP.
17 And then we sat down and wrote a scope of work for 18 projected program to resolve it. And we also had meetings with 19 Sandia National Laboratory at the time and the contract with 20 Sandia was an issue in August of 1980.
21 And the Sandia was the prime contractor and it did 22 the systems analysis. There were three subcontractors; IRT 23 Corporation, Boeing Aerospace, I believe, and Booz Allen. And 24 all of the people involved, all of the entities involved in I 25 this program, had done similar work for the Department of I
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2 MR. EBERSOLE: We are supposed to, kind of, I think !
3 here, understand the evolution of these things and how they got 4 started and what we did with them --
5 DR. SIESS: No, what we did with them, but not how 1
.t 6 they got started. j j
7 MR. EBERSOLE: Okay, what we did with them,' and well-8 we talked about how we got started on the others.
9 I go back now to the Henford spiking of the diodes.
10 And it was due to some spike, okay?
11 DR. SIESS: Jesse, it was not due to a nuclear 12 weapons detonation.
13 MR. EBERSOLE: I know, but I am talking about the O 14 generic aspects of the generic items. If the phenomenon which 15 was damage, in this case, was due to a phenomenon, I don't 16 know, to this day, but that we don't have series diodes that 17 are protecting trip circuits.
18 DR. SIESS: Right, and I think that the question of 19 what are generic issues, is beyond the scope of this Committee. l 20 We are supposed to look at the effectiveness of the procedure 21 for resolving generic issues, not for generating.
22 MR. EBERSOLE: Or the meaningfulness of the whole 23 process.
24 DR. SIESS: ACRS is entitled to generate all the 25 generic issues it wants. We have a standard procedure for it, O
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63 1 and any member can bring it up.
~2 MR. EBERSOLE: But you understand, Chet, that I am 3 just saying that the damage phenomenon has happened.
4 DR. SIESS: Well, then bring it up at an ACRS meeting 5 as a generic issue. We cannot --
6 MR. EBERSOLE: This if 15 years old.
7 DR. SIESS: -- we cannot do it at this meeting.
8 Bring it up next week.
9 MR. ROSA: The time from the authorization of the I'
10 study until August of 1980, when we let a contract to Sandia 11 National Laboratory was taken up by the work involved with 12 setting up the program, talking to Sandia and arriving at a.
, 13 scope of work that we considered trackable. And I think that 14 the fact that we did that work contributed significantly to the ;
15 outcome.
16 Now, the Sandia program scope was limited to' the 17 survivability of safe shut-down systems. It was based on the 18 worst EMP configuration of EMP pulse intensity and its relation 19 to the plant.
20 And we obtained the worst case EMP in pulse 21 intensity, of field intensity from DNA. They told us that that 22 is what they used in their own work and the configuration 23 assumed was such that it would result in the optimum excitation 24 of the circuits internal to the plant, even though that is not i 25 possible, in even one plant.
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- ] . 1 Now, permanent damage failure was the criterion used 2 to assess the survivability of the systems. And there was a 3 peer review panel which interacted with the Staff and its study 4 team from prior to the -- well initiation of the Sandia 5 program until its completion.
6 MR. MICHELSOti: This scope . now brings up the basic 7 question that we discussed a little earlier. Your criterion 8 was, if not permanent damage was done, it was okay. And if is 9 inadvertent actuations or whatever occurred, that was okay, as 10 long as it did not damage the equipment until you could realign 11 it or whatever and get it into operation.
12' is this permanent danage failure criterion very 13 clearly highlighted somewhere in the resolution, that says, 14 this resolution is based on no permanent damage shall be caused.
15 but temporary and inadvertent is --
16 DR. SIESS: The scope was extended if you,look down 17 at the next level.
18 MR. ROSA: Yes, if you look down to the next item.
19 DR. SIESS: So let him get through the final 20 resolution and then we will go back.
21 MR. ROSA: The conclusion of the Sandia study was 22 that the safe shut-down capability would not be disabled. The 23 Sandia study team also recommended further research and 24 investigations including engineering testing to verify the 25 damage threshold calculations that were made.
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C 1 Now, the Staff wrote its report to the Commission in 2 September of 1983, and the time between February of 1983, and 3 September of 1983, the first part of that time was taken up in 4 writing the Staff report. And however, a good part of it, was 5 taken up in obtaining a review and concurrence from primarily 6 the Office of Research.
7 The Staf f . did not go along with the Sandia study 8 team's recommendations for further research and our Office of 9 Research did not want the report to preclude further research 10 and this went around and around for about three months. And 11 finally, NRR prevailed and our recommendation is as cited below 12 here.
13 Now, in the Staff Report, we extended the scope to O 14 include signal upset effects. And that was done through an 15 evaluation that I happened to make myself. And it is 16 documented in enclosure three, to that SEECE 83367.
17 It is a purely qualitative assessment. And it is 18 based primarily on the fact that the Sandia study indicated 19 that the peak response in the circuitry internal to the plant 20 is generally much less than operational voltage levels.
21 And, one other fact, a comparison of the response 22 duration, the EMP response duration, which is about 10 micro-23 seconds, to the cell test characteristics of the most sensitive 24 systems we have in the plant, that is the Westinghouse solid 25 state logic protection system, and the GE reactor protection Heritage Reporting Corporation (202) 628-4888
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. v) 1 system, the solid state version, which is now, I believe, in 2- the Clinton Plant.
3 Now, in both of these systems, there is a scheme for 4 pulse' testing the logic.' Wherein a pulse of about one mille- / /
< ., /
5 second in length,. and 12 to 15 volts in amplitude is inserted J
6 at the interface'betpee'n a sensor and the system.
7 And the output of the system, tfien is compared to 8 what -- the output is compared to what the output should be, 9 given every combination of logiclinputs.
- 10. The system does not result. In operation of any of the 11 outputs -- either the meters, recorders, or any of the relays 12 and scram drivers in the case of the Westinghouse system.
13 MR. MICHELSON: Those systems are after the fact, of
,e s
'\) 14 course, the electro-magnetic pulse will cause the actuation of 15 the systems and then the tester comes back and says, well, no 16 damage was done to the devices, but the actions have already 17 been carried out.
18 So that doesn't. help you at all, I don't believe.
i 19 Unless you are looking for damage.
I 20 MR. ROSA: What that tells us is that if a one mille-21 second pulse, 10 volts and 12 to 15 volts in amplitude, will 22 not affect the output of this system, then a 10 micro-second 23 EMP response will have even less effect.
24 MR. MICIIELSON: I thought that the response on that 25 system was 500 picro-seconds, not one mille-second. That is O
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67 O 1 what GE says that it is, and I don't know.
!v <
l !/; d.k. 2 DR. SIESS: That is still 50 times the 10.
- l. "// They use a one mii.le-second test pulse.
l 3 MR. ROSA:
4 MR. MICHELSON: Yes, that is right, they do, but the 5 response of the system is faster from an input than one mille-6 second. Much faster.
7 MR. ROSA: Now, there is one'other possibility in so O far as a scram system is concerned, and that is the solid state 9 systems. An EMP can result in nothing happening, in a delay of 10 a scram for a few aille-seconds at the most, or a scram and 11 none of these things --
/
12 MR. MICHELSON: I don't want to get into the details.
13 I want to get into the process.
O 14 Let's assume that a new plant comes along with a high 15 speed solid state response system, that was faster than the 16 systems that you might have looked at in the past. How does 17 each new plant get looked at from the review of the USI or i 18 generic issue t. hat is presumably already resolved?
I 19 I think thpt. there is a review process that says that 20 plant has to go bhak and show that it complies with the
..e ,
21 resolution of the previods issues. But those resolutions were 22 based on not this response system, but some other much slower i
23' . system and it said that there is a non-issue or here is what 2d you need to do.
25 As these newer faster syst. ems come in, sure they
- O x
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.q f, resolution because they :were a non-
.V 1 comp!,y with the .old n
2 problem, the old resolution was looking at system for, store 1 3 systems that were non-problems. ,
4 How does his get rehashed as a new fast response 5 system comes in, a3 an example?
6 MR. ROSA: I --
7 MR. MICHELSON: I mean clearly they comply with the 8 old resolution, that is not problem at all, but they never 9 detected the issue.
10 DR. SIESS: Let him answer the question, Carl, he is ;
i 11 trying to.
12 MR. ROSA: I don't see any need for a faster response 13 scram system. I O 14 MR. MICHELSON: I think that is immaterial. I am 15 giving you a hypothetical example.
16 DR. SICSS: The question is that you satisfied 17 yourself and documented that a system such as Nuclenet or the 18 Westinghouse system would not be affected by a 30, micro-second 19 pulse, would not respond to a 10 micro-second.pulte.
20 And now, suppose that somebody comes in, in a few 21 years, with af system that would respond to a 10 micro-second 22 pulse, is anybody going to look at it? Are they going to say,
.23 well, this iNsue-was settled 10 years ago, I don't know on what 24 basis, but it was settled. Are they going to look back and l 25 . find, in your enclosure three, that you satisfied yourself that O
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O 1 it - woeid eet reegoed to e 10 micre-eecond beceeee taev teeted 2 it at 1,000-micro-seconds, and now, they have got one that they 3 test at five micro-seconds?
l 4 MR. ROCA: I doubt that -- ]
5 DR. SIESS: How would they know what the basis was 6 for this resolution?
7 MR. ROSA: I doubt very much whether anyone would do i
8 anything more than perhaps read the Sandia Report, and draw a 9 conclusion.
10 DR. SIESS: This was not in the Sandia Report.
11 MR. ROSA: I know thet it was not.
12 DR. SIESS: This was a part of your resolution.
13 MR. ROSA: I am aware that it was not - -that this t
14 particular aspect is not addressed in the Sandia Report, but 15 the Sandia Report does address characteristics of the system, 16 with respect to EMP.
17 DR. SIESS: Well, you are missing the point.
18 You reacheo a certain conclusion, based on a certain 19 .line of reasoning and based on certain characteristics of 20 existing systems. And I think that I described them. Your 21 reasoning was that if they test this system, at 15 volts, 1,000 22 micro-seconds, and that does not make anything move, then a 10 23 micro-second pulse is not going to have any offect. Right?
24 MR. ROSA: Right.
i 25' DR. SIESS: Now, that conclusion was based on certain O
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70 O 1 caerecterietice or the eretem. And eew, merde there cen ee<er 2 be another system, but assuming that. there is, hypothetical 3 question now,- that has different characteristics, does a 4 reviewer, can he find, assuming that-he is told to look at the 5 previous USI's,.in approving this plant, can he find, in the 6 documentation, what your assumptions were?
7 MR. MICHELSON: Well, is there a requirement for him .
i 8 to do it?
9 MR. ROSA: There is one general requirement and that 10 is that any piece of equipment,. electrical or otherwise, has to 11 operate in the environment that exists in the plant. And one 12 of the environments is electrical noise. There is all kinds of '
13 electrical noise in the plant. But all of it of longer O 14 duration than an EMP. And that new system, then, will be 1
15 looked at from that standpoint.
16 DR. SIESS: But at some point, a few years ago, 17 somebody spent a $500,000 and one-and-a-half man years, 18 deciding that the plants were safe for EMP. And now that 19 decision does not say that the plants, all plants are safe for 20 all time. It was an issue that was looked at, money spent on, 21 in connection with the plants that existed at that time, and 22 were being licensed.
23 Why would not this issue be looked at, for future 24 plants? Or any other generic issue that was considered 25 important at that time? Don't these go in the books somewhere, O
n wamammwenetwemswpamawase m . 1 m .m m
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1 they become a part of the standard review plan?
2 MR. FRAHN: One thing that you have in this process, 3- you have to change the standard review plan so that every new 4 plant that comes in, would be reviewed against the standard I'
5 review plan.
6 DR. SIESS: Well, was there a change in the standard 7 review plan as a result of this?
8 MR. ROSA: Not as a result of this, as far as I know.
9 DR. SIESS: And the reason that it was not, because 10 you decided that it was not a problem for the plants that you 11 were looking at.
12 MR. ROSA: That is correct.
13 DR. SIESS: But now, Carl's question is, what if a b
d 14 plant comes in with a different design? Does it get built and 15 then five years later, Basdekas raised the issue about EMP for 16 that plant, or does.it get looked at, in the process of review, 17 to see if anything has changed?
18 This went away because of certain conditions, if 19 those conditions are changed, it needs a new look.
20 MR. EBERSOLE: But I think that Forester said that 21 the noise, and I take it that this is amplitude and 22 duration, --
23 DR. SIESS: But Jesse we are not worrying about the 24 technicalities --
but if that were true they would never have 25 had to do this in the first place.
(
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j 72 O 1 an. Wrt18: 1 w111 eex the question e 11ttie 2 differently. Is there any requirement at all, that the Staff, 3 on a new plant, revisit USI's resolution was that it was a 4 newer problem?
5 DR. SIESS: Yes, and the fact that noise covered, I
6 well, noise apparently did not cover this, or they would not 7 have spent all of the money.
8- MR. WYLIE: Well, regardless of what the technical l 9 innovation is, is there any reason that the Staff has to look l
10 at new plants --
11 DR. SIESS: Well, they know if the noise level --
12 MR. WYLIE: -- USI's where the resolution was, there 13 is no problem.
Of V 14 MR. EBERSOLE: Faust, can you define noise in terms 1
15 of amplitude, frequency that says that it blinds the plant for :
16 phenomena like this?
17 Is there a baseline for noise that you must consider 18 these little diodes to be --
19 MR. WYLIE: Well, maybe they have got --
20 MR. EDERSOLE: -- insensitive to? I understand that 21 these things will puncture if you rattle a little thin paper.
22 DR. SIESS: But the broader issue is the way that 23 Charlie stated it, a USI, a generic issue that is resolved by 24 saying, no problem, is it generically and forever no problem, 25 or is it only no problem for the plants that we have now and we O
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73 j O. 1 1ooxed et?
2 MR. ROSA: I would have to answer it in this fashion, 3 an engineering judgment is made, whenever a new design comes 4 'in. And as far as noise is concerned, we know that it has to 5 be designed for the noise environment in the plant. We know 6 that sensitive components, solid state components are embedded 7 in the circuitry with circuit designs that would tend to 8 protect them against the noise.
9 DR. SIESS: Then why do you have to spend all of this 10 money if you knew that?
11 MR. ROSA: Because this was a particular unique 12 threat for which there was no rigorous analysis demonstrating 13 what its offect would be on nuclear power plant systems.
O 14 MR. MICHELSON: I don't want to dwell on the 15 technical part, but your answer gives me a little difficulty 16 when people run walkie talkies whatever, and set things off, 17 certainly that problem is well understood and well known but it 18 is still a problem.
19 MR. WYLIE: Of course, he is right, they are supposed 20 to design against that.
21 MR. MICHELSON: But they don't.
22 MR. WYLIE: Well that is a deficiency in the design 23 and not in the requirements.
24 MR. MICHELSON: This does not everi cover, it was i
i 25 already decided earlier today that this only covers bombs and l l \
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74 1 nothing else.
2 MR. WYLIE: Well, he pointed out that there are j l
3 plants, last year, that got tripped of f by lightening strikes i 4 getting down into the control system. q l
5 DR. SIESS: Tom? /
6 MR. KING: Yes, my name is Tom King of the Research !
7 Staff, and the general question was, for future plants do they 8 go back and revisit the USI's, and the GSI's?
9 If you recall the Commission's severe --
10 DR. SIESS: It was more specific, do you revisit the 11 ones that came up with no problem.
12 MR. KING: The Commission's severe accident policy 13 statement featured a section that dealt with future plants and O 14 it had four items under it.
13 One of those items said that plants had to show how 16 they comply with USI's or GSI's. And we, in developing 17 implementing guidance for that policy statement, we have the 18 same precise question that you asked, do plants have to go back 19 and look at issues that are resolved with or without i 20 requirements?
21 Or do they just have to look at issues that are still 22 on the books as unresolved?
23 And our feeling, at this point, is, that yes, they 24 are going to have to go back and look at issues that have been 25 resolved, because maybe that resolution just dealt with plants O
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1 that were buil't or under construction at the time, and the 2 issue may still be applicable to a future p.l a n t , if a new 3 design or some feature are new or different than what was 4 looked at before.
5 But at this point in time, we are planning to write a 6 Reg Guide, several Reg Guides that talk about implementing the 7 severe accident policy statement, to address this question in 8 there, and give guidance on what they have to look at.
9 MR. MICHELSON: I think that sounds like that will 10 take care of it, except these Reg Guides will come out after we 11 have already certified these whole raft of designs, unless you 12 are going to get them out in the next few months. You are 13 reviewing now for certification, in a number of designs.
O' 14 DR. SIESS: The certification is a rule-making 15 process and --
16 MR. MICHELSON: They are reviewing to eventually 17 certify the ABWR and the rest of these, absolutely.
18 MR. KING: Yes, there are three designs, plus the 19 EPRI AWOR requirements.
20 MR. MICHELSON: Yes, and you are going to endorse the 21 EPRI documents, for instance, without the Reg Guide.
22 DR. SIESS: I know, but endorsing the EPRI document 23 is not certifying a plant.
24 MR. KING: Now, the EPRI document did go back and 25 look at all 700 issues.
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76 9j 1- MR. MICHELSON: Now, I wonder do they go back and 2 reopen each in terms of new anticipated technology for the.new 3 plants?
4 MR. KING: My understanding is that they do.
5 MR. MICHELSON: They should. And so far, I have not i
6 seen that, but I have not gotten into the later volumes, and I 7 don't find that promise yet in there, as specifically as you 8 and I think that they have to do it.
9 MR. KING: We don't need to have the Reg Guides on 10 the street to raise this issue as a part of the APWR, ABWR 11 reviews that are going on and we are working with NRR on this 12 issue.
13 MR. MICHELSON: But of course, this EMP issue never 14 was an issue, except relative to bomb sources, apparently.
15 MR. KING: We are not changing the scope of the j 16 issue.
17 MR. MICHELSON: No, and if there is an issue that had 18 never been raised like EMP generated internally to the plant, 19 cr maybe by lightening, or whatever, that has to be go through 20 the whole other process.
21 MR. KING: We would.
22 MR. MICHELSON: I think that I understand, thank you.
23 MR. KING: In the advance plans, the LMR's and the 24 HTDR's are doing the same thing, we are going back and looking 25 at all the resolved or unresolved USI's and GSI's and see how O
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77 f.A sy 1 they apply to these very different kinds of plants. )
2 MR. MICHELSON: And I expect to see more in there,
- 3. than the response to this issue, we did not have to consider 4 because it was determined a non-problem. I don't expect that 5' to be the answer in these new documents, because I don't know 6 if it is a non-problem for their new technology.
7 MR. KING: They would have to explain it is okay.
8 MR. MICHELSON: Right.
9 DR. SIESS: Let me extend the question. The severe 10 accident policy says that new plants have to show compliance 11 with all of the USI's and the generic issues. One obvious 12 question, is what about the mediums, there is a lot'of those 13 that are not even being resolved?
14 MR. KING: Well that would leave about six.
15 DR. SIESS: What about low or dropped generic issues, 16 for which it is possible that the reason that they were low or 17 ' dropped, related to some characteristic of the plant and that 18 it could no longer be low or dropped with the new designs?
19 MR. KING: We are not planning to look at low or 20 drops.
21 MR. MICHELSON: Well, EMP would not have been a 22 problem for relay logic but it certainly might be on a fast 23 response solid state logic, but if it is closed already and you 24 are not going to -- you just reversed what I thought you said 25 earlier, you are going to --
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78 h 1 MR. KING: EMP turned out to be a medium, I don't know 2 what the -- it was not a low or a drop.
3 MR. MICHELSON: Okay.
4 DR. SIESS: EMP was looked at for solid state, that 5 is what Faust has been telling us.
6 MR. ROSA: That is right.
7 DR. SIESS: Looking at solid state.
8 MR. ROSA: That is right. ;
9 DR. SIESS: But the low or dropped -- you understand 10 the point?
11 MR. KING: I understand the point.
i 12 DR. SIESS: It seems that something was dropped or 13 low because of the way that plants are built.
O 14 MR. KING: Yes, I may have mis-spoke, before about 15 EPRI going back and looking at the 730 issues, that includes 16 low or drops.
17 DR. SIESS: It does?
18 MR. KING: Yes.
19 MR. MICHELSON: So they are going to reopen those to 20 make sure that new technology has not changed the original 21 reason for dropping or making it low?
22 MR. KING: Yes, that is my understanding.
23 MR. MICllELSON: Well, that is the only way t.ha t 1 can do to bring in new l 24 thitik that you it, if you want l
25 technology.
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79 1 1 MR. KING: We have looked at all of them and we are 2 doing the same thing with the advanced.
3 MR. EBERSOLE: Mr. Chairman, I would like to ask 4 Faust a question. ,
i 1
5 Faust, EMP is a singular causative consideration for 1 6 damaging spikes inside the plant, it is a singular one, you 7 know, the weapons. In the course of looking at this, I presume 8 it is automatic, that you say, well, gee, that is maybe the 9 least likely cause of damaging spikes, so that I had better 10 look at all of the rest of them.
11 Have you?
12 MR. ROSA: Not specifically. You are talking about 13 the noise environment in a plant, right?
A U 14 MR. EBERSOLE: Yes, right.
15 MR. ROSA: In the environment that it finds itself in 16 the plant when --
now there have been tests performed, for.
17 instance, on a Westinghouse Solid State System where that i
18 system was subjected to electrical noise, and of course, it I 19 passed.
20 Now, whenever a question arises as to the sensitivity 21 of particular systems, new or old, such tests are performed 1 22 before these systems are qualified.
23 MR. EBERSOLE: Well, was that noise, what one could l I
24 say is the worst kind of noise that it would face --
25 DR. SIESS: Jesse, I am going to have to say that you O
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2 MR. EBERSOLE: All right, I am off center.
3 DR. SIESS: We have got to limit ourselves to looking
,4 at generic issues, the four that we have got, or we are never 5 going to get through with this.
6 MR. EBERSOLE: That is singular causation.
7 DR. SIESS: Faust, go ahead, and let's finish this 8 up.
9 MR. ROSA: Okay, the Staff Report extended the scope 10 .to include signal upsets and it addressed the pending petitions 11 for rule-making. The conclusion was the same safe shut-down 12 capability would not be disabled, or would not be adversely 13 affected by a signal upset.
O 14 MR. MICHELSON: Let me ask, are the signal upsets 15 that you looked at including potential arcings and this sort of 16 thing? No, not the day-to-day noise background. I am talking 17 about the faulting of a switch gear or something of this sort.
18 That kind of signal upset or a bus fault due to --
19 DR. SIESS: Due to EMP?
20 MR. MICHELSON: Does it generate EMP?
21 DR. SIESS: No, due to EMP. This generic issue dealt 22 with --
23 MR. MICHELSON: I think that he said here, he 24 extended, this is now looking at internal sources.
25 MR. EDERSOLE: No, this generic issue deals only with O
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..( 1 electro-magnetic processes for detonated nuclear weapons. We 2 are in a tiny crack here. It is a very small, narrow scope.
3 MR. MICHELSON: We are trying to determine what 4 signal upset affects and you are still looking at EMP from a 5 bomb then?
6 DR. SIESS: Yes.
7 MR. ROSA: There is one aspect of signal upset 8 effects that relates to what you -- i 9 DR. SIESS:' Let's don't get off the subject of this 10 generic issue.
11 MR. MICHELSON: I am trying to get the scope first.
12 DR. SIESS: The scope of this generic issue is 13 clearly defined.
14 MR. MICHELSON: The next time that somebody tells me 15 that the EMP was looked at when I ask about arcing, and you 16 know, then I am going to have to tell them, no, it was never 17 looked at, this is only bomb source EMP. But I keep getting 18 other answers.
19 DR. SIESS: Okay, I hope that you guys are kooping 20 track of all of the new generic issues that you want to raise.
21 MR. ROSA: We recomme ,ed to the Commission that no 22 further action need be taken on the EMP, and that also the 23 study be submitted to the National Security Council.
24 MR. EBERSOLE: Let me ask this question, is it proper j 1 l
25 that when one finds a singular cause, but you can say that i l
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82 O i there are 900 others, that you undertake the generic study 2 looking at the singular cause without broadening your view to ,
l 3 take in the more realistic causes?
4 DR. SIESS: Jesse, we have approved every generic 5 Issue that they have looked at. And the time to raise a j 6 question about the scope of a generic issue, is when it is 7 brought before the full Committee for approval. We do now have 8 a process where the prioritization is submitted to us and we 9 look at every one and we look at their definition of it, and 10 their priority.
11 We have not been looking at the resolution of every 12 generic issue, but we will be doing it in the future. And that 13 is the time for the ACRS to talk about what they are doing.
14 Now, we are trying to find out how they do it, and 15 how well they do it.
16 MR. ROSA: All right, the Commission gave its 17 approval unanimously on November 15, 1983, and nothing has been 18 done since, except the program that is ongoing yet, through the 19 sponsorship of the Department of Energy.
20 And Oak Ridge is a prime contractor for that one.
21 Getting back to our GSI-20, the Sandia National 22 Laboratory costs were $560,000, and that was about $30,000 23 under budget. And the Staff resources through issue of our 24 report to the Commission, was .33 staff years per year, or 4.25 25 years, or approximately 1.4 staff years total.
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l 83 O 1 nea eetere or reeeerca, eeeeetie117 eome. rue 2 subcontractors utilized data and methodology previously 3 developed in trial work for DOD. There was some testing done 4 at Watts Bar, to verify the transfer functions, that were used 5 in the study. That was the nearest we came to what might be 6 called research.
? Other factors involved were three petitions for rule-8 making, which requested that various parts of the regulations 9 be --
the applicable parts of the regulations be revised to 10 include protection against EMP, and on the basis of the Sandia 11 stats, that is we later denied these petitions.
12 And industry corroboration was excellent and Watts 13 Bar was the example plant and we had the study team visit three O 14 other plants, which was Catawba, Palo Verde, and Clinton, 15 plants of different manufacture.
16 We closely coordinated with the Defense Nuclear 17 Agency, and they supplied source term for the EMP pulse. And 18 there was complete documentation of all peer review and other 19 comments. And that is included in Appendix E of the Sandia 20 Report, because of the high visibility we thought that that was 21 necessary to document.
22 The coordination between the Staff and SNL was 23 excellent, and Dave Erickson was program manager for SNL and he 1
24 did an outstanding job.
25 There is that ongoing DOE program and which addresses O
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.q (g 1 the effects of EMP on the national grid. And I have about ten 2 reports issued thus far, I have not read much of them. I don't 3 know exactly what the results are.
4 And there have been two foreign studies. One by the 5 Federal Republic of Germany and'one by Sweden and they reached 6 the same conclusion regarding EMP vulnerability of nuclear 7 power plants as we did.
8 DR. SIESS: Let's hope that the Russians did, too.
9 MR. ROSA: They read ours.
10 DR. SIESS: Okay, Mr. Rosa, thank you very much.
11 Let's go on to the next item. What are we going to.
12 do, A-46?
~
13 MR. MICHELSON: Yes, A-46.
14 MR. CHANG: Hello, my name is Tawi Chang and I am 15 with the Research, Office of Research and I am the past manager 16 of USI-A-46. And I have presented the progress and the status 17 of A-46 almost yearly since 1983, to the ACRS. And so I presume 18 that ACRS is pretty familiar with the technical nature of the 19 resolution of this USI.
20 So, I am not going to dwell too long on the technical 21 issues, I just want to go through this quickly, to talk about 22 the nature of the resolution.
23 This issue is about seismic qualification of 24 equipment being operated in plants. And this issue was 25 identified as USI back in 1980, because of the recognition that Heritage Reporting Corporation (202) 628-4888
j 85 h 1 over the years,. the criteria and methodology for seismic
[ 2 qualification of equipment has been changing and there is a 3 concern that viewed by the current criteria and methodology, of 4 the seismic marking may not be adequate, and that is why this 5 ~- is identified as an issue to be looked at.
6 And from the outset, we tried to pinpoint the most 7 reasonable approach for the resolution of this issue. It is 8 obvious to us that it is not reasonable to require the 9 operating plants to comply to the current licensing criteria.
10 So we are looking for alternatives and there are five 11 alternatives we looked at, by our technical assistants 12 contracts.
13 At about two or three years of study, we concluded 14 that the use of the seismic and test experience approach is 15 the most reasonable and cost effective way to address this 16 concern.
17 And this conclusion is also confirmed by a utility 18 group study. The utility group, the name is called SQRG 19 Seismic Qualifications Utility Group, and that group was formed 20 around 1981, and they looked at the seismic experience. They {
l 21 collected from non-nuclear plants in the west coast, basically 22 it is the San Fernando Valley earthquake and the Peri Valley l 23 earthquake. And they are trying to establish the feasibility 24 of using the seismic experience approach to qualify operating 25 plants-(
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86 h 1 And from their study and from our study, that the 2 feasibility was established. Also, in around June of 1983, 3 SQRG proposed the formation of SSRAP, Senior Seismic Review and 4 Advisory Panel.
S And this approach was endorsed by the NRC Staff, so 6 that this independent review panel was formed in June 1983, and 7 it consists of five experts in this area.
8 They are from the private consulting firms, from l 9 national labs, from test labs and from -- one is from the 10 university.
11 So I want to emphasize that point, extensive industry 12 involvement. This is a special feature of the resolution of 13 this A-46. The resolution of A-46, from the NRC's point of 9 14 view, is trying to layout the guidelines and requirements. And 15 as far as the details of the implementation procedure, that is 16 left to the industry to work on.
17 So, they undertook the responsibility for development 18 of the implementation procedures.
19 MR. MICHELSON: I would like a clarification. Let's 20 assume that a plant has a particular device that was stated in 21 the FSAR to be seismically qualified and so forth, and then it 22 turns up that the device really was not seismically qualifled.
23 Is this generic issue resolution allowing him now, to go back 24 and seismically qualify it, by looking at it?
25 MR. CllANG: Well, let me mention what is the criteria O
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Q 1 for including plant in the A-46 review.
2 Our criteria is that if you viewed the seismic j
3 quality for the particular plant by the current requirement, l
4 that is, IEEE Standard 344 1975 version. And if viewed l 5 .according to that criteria, and we think the criteria 6 satisfies, then they are not required to perform the A-46 7' Review.
8 MR. MICHELSON: Well, how about if they did not meet 9 -- let's assume that they had promised an AVSR to meet that 10 criteria, the IEEE standard? And let's assume now that devices 11 slipped through and for whatever reason did not get qualified.
12 Are those in the scope of this resolution?
13 MR. CHANG: No. Well, that should be caught by the 14 so-called SQRT Scored Review.
15 MR. MICHELSON: Scored Review.
16 MR. CIIANG: For the current plants. Plants that are s 17 complying to the current requirements.
18 So this is a separate issue.
I 19 MR. MICHELSON: Which is a separate issue? l 1
20 MR. CHANG: SQRT --
21 MR. BAIRD: Well, let me try. This is Bob Baird of 22 the Staff.
23 A-46 only applies to the older plants that were not 24 reviewed with the current requirements. The scope is such that i
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88 1 MR. MICHELSON: I understand that but my question 2- was, if they had promised, at the time of construction, to meet ,
3 certain requirements, and then determined that they had not, is 4 this'-- is it allowed to go to the resolution of this issue to 5 satisfy those requirements?
1 l
6 MR. BAIRD: Not right now, but there is a new version j 7 that is out and published --
-8 MR. MICHELSON: I am just trying to determine, in 9 reading this, I could not tell for sure, what the scope would 10 be in a case like that. Can I use this resolution to come up 11 with the requirements to qualify that equipment?
12 MR. BAIRD: Right now, I think that the answer is no, 13 but I think that there is a new IEEE standard that has this N 14 experience base as an alternative.
15 MR. MICHELSON: I understand that the original scope 16 was.that this is the way that you fix the problem of having met 17 earlier requirements but could not meet later requirements.
18 So this was a patch.
19 Dut how about the case where you did not even meet i'
20 the earlier requirements that you even had stated that you were 21 going to meet? Is this also a patch?
22 MR. CHANG: Well, Mr. Michaelson, to answer your 23 question, there is a new version of the IEEE standard coming i 24 out in June of this year. It is IEEE 344-1987 version and 25 there is a relatively Reg Guide, 1.100 coming out also. It is l O Heritage Reporting Corporation (202) 628-4888 E- )
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2 Basically we endorse the approach in the new--
3 actually documented that is a section'that allows the people to 4 use the seismic experience approach to qualify equipment.
5 MR. MICHELSON: The reason that I am raising this is 6 that the next ratchet in this, and the industry ratchets as 7 well as the NRC ratchets and the industry ratchet is that this 8 is the way that we are going to seismically qualify future 9 nuclear plants.
10 DR. SIESS: That is not a bad idea.
11 MR. MICHELSON: Well, maybe or not, but I am just 12 trying to determine the scope. I 13 MR. BAIRD: That raises three different questions.
i 14 An old plant that has not promised to meet the 1975 criteria, i l
15 or promised to meet the 1971 criteria, it would be under the A- i 16 46 program.
17 And I think that the answer to the question, whether 18 or not they met even met the 1971 criteria, would be 19 established on an experience basis. Is that the intent?
20 You would not go back on each component and look at l 1
21 how it was qualified for 1971, you would look at it for the )
I 22 guidelines of A-46.
J
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23 MR. MICHELSON: Well, the reason that I raised that l 1
24 issue was that it purported that this is a seismic margin 25 problem and we have maybe not as big a margin as we thought.
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2 DR. SIESS: We have got another way of looking at 3 seismic margins, but --
4 MR. BAIRD: Yes, there are other ways.
S' DR. SIESS: But this is not seismic margins, this is 6 seismic qualification.
7 MR. MICHELSON: Well, I thought that I heard the 8 words earlier.
9 DR. SIESS: You did, he used the margin, but this is 10 not --
11 MR. CHANG: The safety --
12 MR. MICHELSON: The margin, whatever you want to call 13 it --
14 DR. SIESS: You can tell me what you want, but this 15 is not seismic margins. This has to do with seismic 16 qualification to the specified SSE, without regard to margins.
17 MR. CHANG: Only up to SSE, not beyond SSE.
18 MR. MICHELSON: In some cases, this equipment was not 19 qualified at all.
20 DR. SIESS: That is right.
21 MR. MICHELSON: And now, I think, that you have to 22 take a different look and not the look that was used in A-46 in 23 deciding whether or not that equipment is acceptable.
24 DR. SIESS: I am sorry, I don't understand. This 25 applies to equipment that was not qualified at all.
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.) MR '. MICHELS.ON: That is not clear.
2 DR. SIESS: Oh, I thought that it'was.
3 I thought that it was perfectly clear.
4 MR. CHANG: That the equipment is not qualified by 5 the current criteria.
6 MR. MICHELSON: I asked the question, what happens in 7 the case where they promised or made commitments es to what it 8 applied to? But whether it is whatever, and it did.not even 9 meet it.
10 MR. BAIRD: Can I try again on the three questions?
11 MR. MICHELSON: Sure.
12 MR. BAIRD: If it was not reviewed, not committed and 13 not reviewed to '75 criteria, then A-46 applies.
.14 MR. MICHELSON: Okay.
15 MR. BAIRD: If it is committed and reviewed to the 16- '75 criteria, then it would not be an A-46 plant and hopefully 17 the licensing process and the reviews including the on-site 18 reviews by the Staff, would catch it.
19 MR. MICHELSON: Now, if there were deficiencies (
20 found, though, in that review, can they use A-46?
21 DR. SIESS: Let me try something here, because I 22 think that we are getting two things confused. If they found a f 23 '
-eficiency, a piece of equipment that the FSAR said that it is 24 going to be qualified according to the IEEE requirements, but
)
25 it did not get qualified and it cannot be taken out of the i
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_U 1 plant.
2 'This is not an A-46 matter. This has nothing to do 3 with the resolution of A-46. What they might do, is then 4 decide to that they could use the techniques that were 5 developed from SQRT, of the criteria from SQRT to accept or
'6 reject that, but it would not come under A-46.
7 MR. MICHELSON: Well, that point is not clear, as I 8 say, in looking at the scope.
9 DR. SIESS: A-46 is a regulatory problem relating to 10 plants where the equipaient was not qualified and the rules did 11 not exist at that time.
12 Now, whether in the future, they might accept the 13 SQRT type of experience record, as a basis for qualification, O 14 in lieu of either analysis or shake table tests, is another 15 issue.
16 MR. CHANG: That is one of the options that they can 17 choose.
18 DR. SIESS: That is one of the things that people are i
19 talking about. But that is not a part of A-46 either. It is 20 taking A-46 data.
21 MR. MICHELSON: Now, if it is decided later that A-22 46 applies, do they write a regulatory guide?
23 DR. SIESS: It would not be A-46 applying, it would 24 be the use of experience data --
25 MR. MICHELSON: Well, to me, it is the techniques. Is j OV i 1
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2 DR. SIESS: We have not done it yet. He is saying 1
3 -that it would be -- l 4 MR.' CHANG: Yes, Reg Guide 14-100 basically endorses 5 it, the'new documents. l 6 MR. MICHELSON: Yes, but that is for electrical 7 equipment only.
8 MR. CHANG: In the regulatory analysis we say that it f
9 applies to mechanical equipment as well.
10 MR. MICHELSON: It will?
11 DR. SIESS: But it would be at whatever Reg Guide 12 endorsed the standards.
13 MR. CHANG: But when we reviewed on a case-by-case 14 basis, when they want to use the seismic experience approach.
15 DR. SIESS: We have to make a distinction between A-16 46 and the techniques developed out of A-46. It might have 17 other uses.
18 MR. MICHELSON: Yes, and there is danger in using 19 those techniques in some cases, and in other cases, it is fine.
20 MR. WYLIE: That particular Reg Guide that we passed 21 through the comment stage, I believe, and we have copies and--
22 MR. MICHELSON: Does that come up to the full 23 committee?
l 24 MR. WYLIE: It is coming up.
l 25 MR. MICHELSON: Okay, I will ask my questions later.
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(. 1- 'MR. WYLIE: I think that it has got our. proposing 2 comments. ,
4 3 DR. SIESS: .Oh, yes, it is back.
4 But A-46 proper is strictly a back-fit, it is the 5 older. plants, -- .,
6 MR. CHANG: Older plants, only.
7 DR. SIESS: .The techniques, as you say, may be used 8 in the future, but that is a separate issue.
9 MR. CHANG: That is right.
10 DR. SIESS: It is not an A-46 issue.
11 MR. MICHELSON: Okay.
12 MR. CHANG: And now, I would like to mention also ;
7 13 that the relationship of SQRT, SSRAP and NRC is kind of unique s 14 for,the USI 02jgeneric issue resolution. Another point that 1 15 want to mention is that on April 6, there will be a follow 16 through on the implementation with the resoludion task 17 managers, in order to have a continuation from the resolut,Jon 18 phase to the limitation phase. I think that this is the new 19 approach also.
20 In the past, once the resolution ic done, you change 21 the whole team to an implementation team.
22 DR. SIESS: Let me ask you a question about 23 implementation, since you brought it up. ]
24 A-46 must cover some of the same plants that are 25 likely to be involved in a seismic margin review on the east O
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1 2 p MR . CIIANG: Right.
R We.are.trying to combine the two walk-downs into one.
3 l l
4 And as far' as a coming scope is concerned, I think, that -
5 probe.bIy seismic margin will have more equipment in this scope
'6 ' because they are concentrating more than just within the sea
.7 Mvels, j 8 DR. SIESS: Well, the people that will be 9 implementing this are aware that there is more than one seismic 10 issue out there, with possibly common solutions.
[
11 MR. CIIANG: Right, so that during the walk-downs, 12 they may'want to collect more information, over and above the 13 electrical equipment for these things.
-O 14 Dry,, SIESS: You understand the issue. All right, x
15 thank you./] [
t 16 (MR. MICHELSON: .Are you going to explain later how 17 you are hbndling system interactions since it was excluded from 10 :much of the A-46 resolution? Only the physical interaction --
19 MR. CHANG: Well, I can mention now, I think that we 20 have had a discussion with you last year, about this time, and 21 our answer, at that time, is that issues like seismic induced 22 flood, seismic induced fire, or inadvertent actuation of 23 protection systems due to earthquakes, and so forth, is 24 presently, they are not presently in the scope of A-46.
l 25 And we are looking to those issues to A-46 and trying lO. licriteigo Reporting Corporation
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3 f 2 DR. SIESS: Now, somewhere in the resolution of A-46, 3 ~1t is going to specifically state that, so that the $eader 4 understands the scope of A-46?
5 MR. CHANG: Well, we define clearly, what the scope 6 of A-46 is.
7 DR. SIESS: How would systems interactions get into 8 equipment problem issues?
9 MR. MICHELSON: Well, they are not consigned, 10- starting when a tank falls down and the water comes out, then 11 it damages any equipment.
12 DR. SIESS: But this is seismic qualification.
13 MR. MICHELSON: Oh, yes, but they don't look at the p ,14 effects.of seismic failure, other than the physical effects and 15 if the physical effect does not prevent safe shut-down, then 16' they are saying, they are okay.
17 DR. SIESS: I thought that this dealt with the 18 seismic qualification -- ,
- 19. MR. MICHELSON: This is physical in'teraction.
20 MR. CHANG: Well, we do look at 'the physical j 21 interaction between the equipment and say, nearby structure of 22 piping.
23 DR. SIESS: By physical, you mean a valve that bangs 24- against the column? ,
?) 25 MR. CHANG: Against the wall or railing or th'ings W .
i Q ! !
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[ 1 like that, so that those kinds of things are in the A-46 scope.
2 DR. SIESS: That is a part of design, and that IEEE-3 ldoes not cover that sort of thing, does it? ,
4 MR. CHANG: No, but during walk-down we are on the 5 lookout for those things. As like a tank, if it topples on-6 it leaks due to earthquake and it floods the equipment, that is 7 not covered J n A-46.
8 MR. MICHELSON: Far away may be a few feet.
9 MR. CHANG
- Tanks required for a hot shut-down is 10 covered only up to the anchorage review, but tanks outside of 11 this scope are not covered.
12 -DR. SIESS: What I am getting is that Carl is talking 13 about seismic risk and not seismic equipment problem --
0 14 MR. MICHELSON: We were talking about, yes, it is a 15 part of the -- see that is a part of this walk-down process.
16 MR. CHANG: Anyway your concerns are covered by 17 another study. We have a national lab is looking into all of 18 those issues, peripheral issues, and trying to prioritize them.
19 MR. MICHELSON: But no, the question is very simple.
l 20 When you say that A-46 is resolved, do you somewhere state in 21 the resolution, the limitations on that resolution? It is 22 resolved relative to physical interaction only?
23 MR. CHANG: Yes, we mention specifically it is only 24 physically interaction is concerned.
25 MR. MICHELSON: I am not even sure that it is O
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Jg,)f 1 resolved for physical interactions. I thought that A-46 is --
2 MR. BAIRD: Hopefully it is.
3 DR. SIESS: I have got a pump over here that has not 4 been seismically qualified, how do I qualify it?
5 MR. MICHELSON: Yes, there is more to it than that.
6 To me --
7 MR. CHANG: While we go into the --
8 DR. SIESS: On a modern plant, that bulk would be put 9 on a shake table. I don't see how the shake table provides any 10 kind of interactions with anything. It just simply qualifies 11 that pump --
12 MR. MICHELSON: I think that the resolution is the 13 procedure that you use to verify the --
14 DR. SIESS: Oh, now, you are talking about the walk-15- down that they are going to do in support of this.
16 MR. MICHELSON: I am talking about the resolution of 17 A-46.
18 MR. CHANG: Yes, since walk-down it is quite adamant 19 in the resolution of A-46, which we think that during the walk-20 down, if you cannot identify a potenttal specific interaction 21 than that should be noted also.
22 DR. SIESS: And that is a part of A-46?
23 MR. CHANG: That is a part of A-46, 24 DR. SIESS: That is now just something that you have 25 added in? I
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l 2 DR. SIESS: Under seismic qualifications.
3 MR. CHANG: In A-46.
4 DR. S1ESS: Oh, in A-4 6, yes. That is what we are 5 talking about. That is something that you have added in to the 6 sel-mic qualifications?
7 MR. CHANG: That is correct.
8 DR. SIESS: Because if qualified by equipment in a 9 new plant, by IEEE --
10 MR. CHANG: Yes, strictly according to actually 13 document -- j 12 DR. SIESS: Well, the walk-down you would have to 13 invoke some other aspects to the rule to get a walk-down out of O
D 14 it.
- 15. MR. CHANG: Right.
16 DR. SIESS: What rule would that be incidentally?
17 MR. CHANG: But actually in the new licensing plants, i
18 the so-called SQRT review by the Staff, we did look at the 19 interaction.
20 DR. SIESS: But that is after it is built? j 21 MR. CHANG: Right.
22 MR. EBERSOLE: Let me ask you for an example, and I
23 this is a real life example, let's say that there is a l
l 24 humongous big domestic storage water tank on top of the roof. I 25 DR. SIESS: That does not have to be qualified. ,
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( 'l MR. EBERSOLE: Now wait a minute, I am not done yet.
2 Its moorings, its mountings, its pipes are non-3 seismic and --
4 DR. SIESS: Jesse, you are not talking about seismic 5 qualifications of equipment.
6 MR. EBERSOLE: I am too.
7 MR. WYLIE: I think that we are. A-46 --
8 MR. EBERSOLE: The only that will happen is that it 9 will tumble and start leaking and.--
10 DR. SIESS: Gentlemen, --
11 MR. EBERSOLE: You see, it is part of a seismic 12 problem.
13 MR. CHANG: Well, it is not included in the A-46 We have to limit our scope, Mr. Ebersole.
14 scope.
15 DR. SIESS: This problem relates to equipment that
! 16 has not been qualified according to the IEEE and how do you
! 17 accept that equipment for safe operation of the plant?
I 1 18 It does not deal with seismic interactions, with l
i 19 seismic safety, with seismic margins, or any other aspects of 20 it, because there is some of that in, in the walk-down.
21 Because when you do a walk-down you look for some of 22 these things.
23 MR. MICHELSON: It is a part of the A-46 resolution, 24 that is a requirement. It makes it hard, Chet.
25 MR. WYLIE: Well, I think that the scope as O
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2 DR. SIESS: If the ' scope is extended to seismic 3 safety from seismic qualification, I think that it is a 4 mistake. Because --
5 MR. WYLIE: But that is the way that it is written 6 though.
7 DR. SIESS: If I think that it is a mistake, I am 8 going to.say it, and shut up because I am not here today to 9 review A-46.
10 MR. WYLIE: Okay.
11 DR. SIESS: We have got other subcommittees --
12 MR. MICHELSON: We did comment on this problem at the 13 time that we wrote our letter.
O 14 DR. SIESS: If we did, let's forget about it.
15 MR. MICHELSON: We are trying now to determine how it 16 is finally factored in --
17 MR. CHANG: Yes, we did go through that in --
18 DR. SIESS: There are a 100-some odd of these issues, 19 and you pick four as an example of the process, we cannot re-20 review them in this committee meeting. If you want to 21 ~re-review A-46, you notify Mr. Kerr, who is the Chairman of the 22 Committee that you want.to re-review it, and 23 MR. MICHELSON: I don't think that we are trying to j l
24 re-review, we just want to find out how are these limitations l 25 conveyed to the reader of A-46? That was all.
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102 1 1 MR. CHANG: We just define clearly the scope of A-46, 2 in our resolution. Another point that I want to make is that 3 we have staff review groups formed early and they will be 4 active through implementation, that is, Anchorage Guideline 5 Review Group and the Reader Review Group and when we talk about 6 Anchorage Guideline Review Group, they review not only the 7 Anchorage Guidelines but other matters, other than relay.
8 (Slide) 9 Okay, this slide is about the time for resolution.
10 And as I mentioned earlier, it was designated as to USI in 11 December of' 1980, and the pilot program of the SQRT, was 12 finished towards about September of 1982, and in June of 1983, 13 the SSRAF was formed, and they started to look into the use of O 14 seismic experience approach to qualify equipment. And their 15 recommendations are labeled in their report issued as a draft 16 report issued in January of 1984.
17 And based on their recommendations, and the study 18 done by the Technical Assistance Contract, we formulated our 19 proposed preliminary resolution, early in 1984.
20 And the package was sent to the NRR Staff, and 21 Research Staf f for review and comment and have those were all 22 ironed out. The first CRGR meeting was held in December of 23 1984.
24 And during the meeting of CRGR, they recommended us 25 to do some changes on our resolution. And we went back and did O
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.Q 1 that and it was sent back to the staff for review, and their 2 concurrence again. And we meet with the CRGR again in July of 3 1985.
I 4 And after this meeting, the CRGR recommended the ;
i 5 package will be sent out for public comments. So the public l 6 comments started in September of 1985, and took 60 days to get 7 all of the comments back in and we tried to resolve those 8 comments and tried to incorporate the legitimate ones in our 9 resolution.
10 And this package is again, sent to the staff for ,
11 review and concurrence. And by October of 1986, we finally 12 meet with the CRGR for the last time and they recommended the 13 issuance of the package for the final resolution.
14 And the final resolution was issued in September of 15 this year, in a form of a generic letter, 87-02. And together 16 with two NUREG. NUREG 1211 is the regulatory analysis of A-46, 17 and it represents the acceptable ways for the resolution of 18 A-46 and NUREG 1030 documents the technical justification for 19 our resolution.
20 (Slide) 21 Well, about the resources used for the resolution of 22 A-46, first of all, we have the technical assistance from those 23 four national labs and this is the amounts spent.
24 Also SQRT committed extensive resources for the 25 development of, for collecting of the experience data and the O
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2 And . so far, today, it is approximately 200-K per 3 member of SQRT and we have about now, 38 members on SQRT.
4 Also EPRI developed the Anchorage Review Guidelines, 5 relaying evaluation procedures and GIRS, and that is Generic 6 Increment Relevant Spectra, this is the data collected from 7 test experience, and also, they are working on the seismic 8 demand.
9 So they spent quite a bit on the A-46 also.
10 (Slide) 11 As far as research programs used by A-46, one is the 12 Southwest Research Institute Contract, under Research. It was 13 an ongoing research program and the program was modified to 14 accommodate A-46 needs, and that means the schedule and tasks.
15 That study was not directly useful for A-46.
16 The second research program is one with Brookhaven 17 National Laboratory and Lawrence Livermore, and it is on 18 equipment fragility program. And that program is collecting 19 useful information for A-46, and they are sharing that 20 information with the SQRT group. ]
21 DR. SIESS: Thank you.
22 MR. MICHELSON: I have one clarification that I would 23 like, if you will? I l
24 DR. SIESS: Okay.
1 i
25 MR. MICHELSON: I have a new plant coming in, which I O .
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2 among them, of course, I assume is still the seismic l a
3 qualification of equipment. And I would expect that their 4 response to the applicability of A-46 to their plant is that A-5 46 only applies to old plants, it does not apply to new plants.
{
MR. CHANG: That is correct.
6 7 MR. MICHELSON: And I think that, because every bit 8 of A-46 has been written around old plants and the fact that
?
9 not all old plants meet the current seismic requirements. .
10 It has nothing to do with new plants. New plants 11 would always come in seismically qualified to current 12 regulatory requirements --
13 DR. SIESS: Not just new ones, an awful lot of O 14 existing ones.
15 MR. MICHELSON: Yes, I am saying -- new plants that 16 come in, they write off A-46 as non-applicable.
17 MR. CHANG: That is correct.
18 MR. MICHELSON: And they should not even talk about
-19 A-46 or its resolution. It has nothing to do with the new >
20 plants.
21 DR. SIESS: That is right.
22 MR. MICHELSON: Okay.
23 Now, you still have got to seismically qualify 24 equipment. Now, whether or not you can do it by experience is 25 something that will have to be resolved through a different O
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2 MR. WYLIE: How many members did you say that SORT 3~ has?
'4 MR. CHANG: Thirty-eight.
5 DR. SIESS: This question of walk-down, I think that 6 the document that I was looking at' defines, quite clearly, the l 7 scope of the interactions, to look for in the walk-down.
8 The walk-down, of course, is needed to identify the 9 equipment and'in the process, it says, that we will do some 10 interaction looks. Frankly, I think that it is a mistake. I 11 think that somebody decided that looking for interactions is a 12 good idea and this is a good way to get people to do it.
n 13 But what is proposed there is. a half-baked U 14 interaction study that I think is almost worse than nothing.
15 And the idea that you expressed earlier --
16 MR. CHANG: The reason for the interaction --
17 DR. SIESS: Just a minute, I am talking about your 18 resolution.
19 Now, if, in the process, of implementing this, 20 somebody coordinates walk-downs that are being required for 21 systems interactions, and walk-downs that are being required 22 for seismic margin studies, if we get to that point, after they 23 finish reanalyzing the east coast earthquake, and put all of 24 those together and get a really good seismic walk-down that 25 would take care of what you have got here.
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i l 107 j o But this sort of half-baked walk-down, I think, is
'() 1 a J 2 mistake because it only picks up a fraction of the things that 3 are --
4 MR. CHANG: Well, I -- l 1
5 DR. SIESS: I mean, I don't think that it was 6 essential to the issue.
7 MR. CHANG: The reason that physical interaction is 8 included in the scope, is because during the collection of 9 earthquake experience that kind of damage was observed.
10 DR. SIESS: Sure, we know that, but that has nothing 11 to do with_ equipment problems. I think that it is mixing up 12 two issues. If you want a seismic review of seismic 13 interactions, I think that it ought to be called for as a 14 seismic interaction review. And not as part of the equipment 15 qualification walk-down.
16 MR. MICilELSON: Well, this was not in A-46's 17 verification of seismic adequacy.
18 DR. SIESS: Well, that.is the fancy name for it.
19 MR. MICHELSON: But that does not mean of individual 20 components, but rather, of the plant, as I understood it.
21 DR. SIESS: Well, that it is not.
22 MR. MICHELSON: Well, that is what it was supposed to 23 be I thought.
24 DR. SIES?: Well, if you had sat in the meeting 25 yesterday and see what people are doing for seismic margins l O lleritage Reporting Corporation l
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(-) I review, you would see how inadequate this is as a verification 2 for seismic adequacy, of a plant.
3 MR. MICHELSON: Well, that is what I thought it was 4 supposed to be.
5 DR. SIESS: Well, I did not, I thought that it was a 6 verification --
7 MR. MICHELSON: Well, correct me if I am wrong, I 8 thought that is what it was.
9 MR. WYLIE: Wel), if you look at the scope as 10 written, the scope is more than equipment.
11 MR. MICHELSON: It sure is.
12 DR. SIESS: Very little more. Well, let's don't 13 argue about it, gentlemen. c For us to argue about something in O 14 .this Committee meeting, we can argue about it, when it comes l 15 into the full committee, but I think that it was a mistake.
16 MR. BAIRD: I would like to give you a better 17 explanation of why we are looking at the physical interaction.
18 My understanding is that we have seen from the experience base, 19 that that was a source of damage, and if things were mounted 20 on different foundations that -- i 21 DR. SIESS: But you pick this handful of them. That 22 is what Michaelson was trying to tell you, you are only looking 23 at certain ones. There is a whole complex of interactions out 24 there.
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b) 1- was that this was fundamental to saying that that ' piece of 2 equipment'was seismically qualified, was to make sure that if 3 it was mounted on a different foundation that it did not bang 4 into something. So is my understanding correct or --
5 MR. CHANG: Yes, basically when you are talking about 6 seismic qualifications, that is what it is.
7 DR. SIESS: You are dealing with a very narrow part 8 of the seismic interaction problem and if this were all that 9 you were going to be doing about it, it is better than nothing, 10 but it is by no means, complete. And I think it is very clear 11 in your documentation, as to what it is limited to. You leave 12 out block walls, you don't worry about tanks unless they are 13 required for the particular water, and.. you don't worry about t
14 this --
15 MR. CHANG: Because those are the things that we do 16 think that poses some interaction problems, though we only 17 mentioned the reasonable ones.
18 MR. EBERSOLE: The language then, is not consistent 19 with what you described as the issues here.
20 DR. SIESS: Because it is general, in character and l 21 it does not just say, included in the scope of review, to the 22 extent that equipmcat within the scope might be protected from 23 seismically induced physical interaction with all structures, 24 piping, that have been located nearby --
25 MR. EBERSOLE: That is impact damage from mechanical l
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3 DR. SIESS: That'is right, and I say that it is very 4 limited. I think that it is clearly limited.
5 MR. CHANG: Well, pipes are addressed by 7902 through 6 7914, IEEE bulletins, so that there is no point to repeat that 7 again.
O MR. MICHELSON: Chet, when this came before the full 9 Committee, what, a year ago now, we debated this point at great 10 length, on how the question of limiting it to just physical 11 interaction, not including the water that is running across the 12 floor.
13 DR. SIESS: Right, but there are other programs 14 talking about walk-down --
15 MR. MICHELSON: Yes, but we were talking about A-46 16 and its resolution.
17 DR. SIESS: And it is very limited.
10 MR. EDERSOLE: Well, it could be, if they would 19 eliminate some of that language.
20 DR. SIESS: I know but the language, Carl, is 21 concerned that the scope be well-defined, and I think that it 22 is clearly defined here, and it is half-baked, it does not 23 cover them all.
24 Now, if there are other programs that may cover it, 25 well, you can say look, these are old plants, I cannot make lO j Heritage Reporting Corporation (202) 620-4888
l q kJ 1- them do a seismic PRA, but I can make them qualify this 2 equipment. I am not sure, on what basis, we make them qualify ;
1 3 the equipment. It is a back-fit, but that has been agreed on, l . i 4 and at the same time, we will back-fit a seismic walk-down into !
l 5 it. )
i 6 Not bad, if that is all that you can get out of it. ]
)
7 MR. CHANG: Another reason why this physical l 8 interaction is included, is on the current plants, new 9 licensing plants, this has been looked also.
10 DR. SIESS: You back-fit the SQRT team 11 MR. CHANG: No, SQRT they look at those potential 12 physical interactions as well.
r . 13 DR. SIESS: I know, but what I am saying is that 14 along with back-fitting, the issue of back-fit, the SQRT people 15 that is what you are doing. You say this is an old plant and it 16 did not have a SQRT review, and so we will do with that 17 analysis.
18 MR. CIIANG: Yes, this is one of the reasons why.
19 DR. SIESS: You are doing nice things under the 20 rubrick of equipment qualifications.
21 MR. CHANG: You are commenting on the scope of A-46, 22 you think that probably it is a rubrick, too big, or if you 23 look at strictly from the seismic qualification point of view, 24 but there are others that think that this is not big enough.
25 So it is hard to satisfy everyone.
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% 1 DR. SIESS: Well, sure, if I look at this from the 2 point of view of equipment qualifications, the IEEE etc., this 3 is going farther than that. If I look at it from the point of 4 view of seismic safety and all of the things that we are doing 5 for newer plants, it does not go far enough.
6 MR. CHANG: What I am saying is that we are trying to 7 be consistent with the current requirements, and the current 8 requirement does look at the physical interaction to a degree, 9 we mentioned in A-46.
10 That is why it is also included in A-46.
11 DR. SIESS: Yes. But if you are talking, if what you 12 have goes beyond the seismic adequacy, the seismic 13 qualification of. equipment, and it does not go as far as what 14 was the wording somebody just read to me, as the seismic 15 adequacy of the plant, this does not say, seismic adequacy.
16 Seismic adequacy in mechanical electrical equipment, you see.
17 But you have gone a little bit beyond what the IEEE test would f i
18 recall. j 19 You have tried to combine that with the SQRT group, 20 right?
21 MR. CHANG: Yes.
22 DR. SIESS: Well, then somebody else is coming along 23 with other walk-downs, for -- l l
24 MR. MICHELSON: This is the integration problem that l I
25 I am talking about.
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113 L> 1 DR. SIESS: For non-seismic systems interactions, 2 what USI is that?
3 MR. CHANG: That is A-17.
4 DR. SIESS: A-17, and yesterday we were talking about 5 seismic margin reviews, which involved walk-downs, for seismic 6 interactions and somebody asked questions about some other 7 interactions, well those are not seismic. If the pipe breaks 8 or the tank fails due to any cause, it causes a problem not 9 just necessarily due to seismic.
10 And if those were all fixed, the seismic ones would 11 be left over, and the seismic themselves, doesn't take care of 12 all of them, you know, and we are looking like a committee with 13 a bunch of blind men looking at the elephant.
14 MR. MICHELSON: I would like to remind the Committee, 15 .of course, the Subcommittee, that when we talked about A-17, 16 the A-17 people told us that A-46 was going to cover the 17 seismically induced interaction. When we got over A-46, I admit 18 that we hounded them pretty hard on it and then perhaps the 19 physical interactions were in a little bit, but it did not 20 begin to address the A-17 problem so that now we have got to go 21 back to A-17, when they come and ask them all about seismically 22 induced interactions.
23 DR. SIESS: And the seismic margins people were 24 looking somewhat further, but they were not going three rooms 25 over to look at the tank that might fail seismically and affect O
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V 1 something over here.
2 MR. MICHELSON: And also the combination of seismic, 3 if more than one thing is likely to fail in a plant due to a 4 seismic event. There is just no feeling on my part, at least 5 that just one thing is going to happen as the result of an 6 earthquake. They don't look at multiple things, these analyses.
7 DR. SIESS: I don't know where you got that data. The 8 seismic margin study did not make that assumption, nor do the 9 seismic PRA.
10 MR. MICHELSON: You mean that all earthquake 11 experience indicates that only one thing broke in the plant?
12 DR. SIESS: No. Seismic PRA's look at the
- 13 fragilities of all of the systems in the plant.
14 MR. MICHELSON: No, but the systems interactions 15 effects have to be analyzed in terms of multiplicity of things 16 happening, not singular things, and they don't do that.
17 Now, the PRA people don't even deal with systems 18 interactions in the kind that we have talked about with water 19 running across the floor, and so forth. That is not a hard-20 wired interaction, so that it is hard to pick up on a PRA, 21 unless somebody tells them about it, and then they model it.
22 DR. SIESS: Yes, you are right there, you don't 23 assume just one failure.
24 MR. MICHELSON: No, you have got to deal with more 25 than one non-seismic failure.
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115 1 DR. SIESS: Okay, next item, is GSI-61, I guess, 2 Generic Safety Issue.
3 MR. SERKIZ: Good morning, my name is Al Serkiz, and 4 I am with the Reactor Plant Systems Safety Issue Branch and in 5 research. I was the project manager or the task manager, on 6 Generic Safety Issue 61, which deals with the safety relief 7 valve line break inside of a wet well air space of Mark I and 8 Mark II containments. I 9 And I would like to cover three areas with you in the 10 context of the purpose of this meeting. I will go over the 11 nature of the resolution and we will pick up some of the items 12 that Roy has noted on, how different issues are resolved?
g 13 I will also discuss with you resources expended, and
\
14 in a limited sense, because there was only a limited amount of 15 related resear.ch, the nature of the related research.
16 (Slide) 17 And an overview of the nature of the resolution, or 18 the resolution of Generic Issue Number 61, is depicted in this 19 slide.
20 The issue is identified as a potential Generic Safety 21 Issue, by the ACRS in 1982. And shortly thereafter, and by 22 this, I mean in a matter of two to three months, -- should I 23 hold?
24 The safety concerns were studied by Brookhaven 25 National Laboratory and were issued in a BNL NUREG 31940. That
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d 1 was a report that came out with limited distribution. I cannot l
2 give you the reason for the limited distribution. The staff l l
3 and some other people, within the NRC were on the distribution, 4 and it was a Brookhaven issue that came out in October of 1982.
5 The issue was prioritized through the prioritization i 6 methods that have been employed, I guess, in this NUREG 0933.
7 If you look at the prioritization that existed back in November 8 pf 1983, the issue was a low to medium and I selected to list {
9 here as a medium because it was maintained as an issue of 10 sufficient importance on a priority level to warrant 11 continuation and resolution.
12 And the time that intervened, and I will go back in a c 13 different fashion, chronologically here in a moment.
14 (Slide) 15 This particular Brookhaven Report was reviewed by the 16 NRC Staff and the PWR Owners Group. And the assumptions and 17 findings were questioned and it was a BWR Owner's Group letter 18 that came in, in March of 1985. I will try not to go into the 19 technical details, but just let it be sufficient for me to say 20 right now, that the questions that were raised were the 21 assumptions embedded in the analytical calculations, as being 22 overly conservative, as not being consistent with other types 23 of calculations and so on. And then an overlaying of 24 assumptions that one would have a line break and the line break 25 would over-pressurize the containment and over-pressurization l
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'bI 1 of the containment then it automatically led to core melt, etc.
I 2 These type of overlay conservatism.
l 3 (Slide) l 4 BNL re-evaluated this Generic Safety Issue based on 1 5 comments received both from the Staff and from the Staff 6 through the BWR Owner's Group. This was then reported out in 7 NUREG CR-4594, which came out in June of 1986. And the results l I
8 of that was a much lower assessment, our reassessment showed a )
9 much lower effect, on potential releases.
10 Core melt frequencies, for example, the NUREG CR45-11 94, indicated core melt frequencies associated with the 12 different types of pipe breaks and accident' scenarios, were in 13 the range of two times ten to the minus seven, to two times ten O 14 to the minus ten, of frequency per reactor year. And 15 associated estimated release of anywhere from between .1, .15 l 16 up to as high 5 person rem per reactor years.
1 17 (Slide) j 18 And so at this point, on a reassessment which came ,
I 19 about here, the issue then, you know, was focused on in terms l 1
l I
20 of what are the reassessed safety levels, and certainly much I
21 less than medium. J 22 We therefore, proceeded based on this report, as a l
23 principle report, to declare the issue resolved and a letter
, i 24 went out to the appropriate people and ACRS was included, that j 25 referenced this report, and the value impact analysis and so '
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2 And based on the type of results obtained here, the 3 issue was declared resolved, without a need for additional 4 expenditures.
5 MR. EBERSOLE: Can I ask a question at this point?
6 In the final assessment of the risk here, I have read 7 some of the report here, this is a carbon steel pipe?
8 MR. SERKIZ: Correct.
9 MR. EBERSOLE: And it is subject to rust from the 10 inside as well as the outside, and in some cases, like the Mark 11 II's, it is a long finulous pJpe that hangs down, you know, 12 like a telephone pole into the water.
p 13 And then the notion of selective. failure, the factor
(_) 14 of ten, which does not amount to a whole lot here, where they 15 talked about the coincidence of pipe failure being associated 16 with the coincidence of valves not seeding, is irrational 17 because the failure mechanism, I think is low cycle vibrations 18 and low cycle fatigue failure at the root of the pipe. This is 19 when you get into a low pressure resonant region and the damn 20 thing starts shaking all over the place. Are you with me?
21 MR. SERKIZ: I think so.
22 MR. EBERSOLE: flow , does the report cover these 23 aspects of the failure?
24 MR. SERKIZ: 110t exactly in that terminology, but the 25 pipe break of failure frequency was estimated on the high side, O
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V 1 by simply saying, okay, at this point in time, we have 2 something on the order of less than 400 reactor years 3 accumulated time --
4 MR. EDERSOLE: You are waiting for the first one.
5 MR. SERKIZ: -- and a one over that leaves you to an i 6 estimated --
J 7 MR. EBERSOLE: Just because I have not failed now, I g --
9 MR. SERKIZ: Well, it is a commonly accepted method 10 and then on top of this, other considerations which were, I 11 think, more important came into being, looking at related 12 effects. The containment certainly is not going to be 13 postulated to blow-up and in concert with this, you know, V 14 automatically go to core melt, etc.
15 MR. EBERSOLE: Yes.
16 MR. SERKIZ: The report, the Brookhaven Report was 17 discussed with you, Mr. Michaelson, other people and my reason 10 for including it here, coming back to the thrust of this 19 meeting.
20 This issue took four years to resolve and I would 21 like to comment for the benefit of this Committee, why.
22 And there are several reasons for it. There was an j l
23 identification, there was an initial study where people bound 24 off on studying and looking at it on a what if, the worst type
{ 25 of what ifs.
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'V 1 What really happened in this time frame, it really 2 went into a hold situation. And this is where different GSI's {
'3 or USI's encounter the nature of the organization. I think 4 t h a t a l l- of you are appreciative, we have had at least two 5 reorganizations in the Agency in that time. I.came on to pick 6 up this issue, and I guess it was what, November of 1985, was
-7 the last one prior to the April? -
8 And at that time, we reorganized, and there was what 9 I termed here, a dedicated -- and that does not apply to me, I 10- just am not trying to peddle my own wares -- but there is a 11 variety ways of doing this. l 12 And maybe sacrificial is a better term. I happened to fg 13 be travelling at the time I was told that I had GSI-61 with the N.) 14 incident response team on San Onofre Water Hammer, so that I l i
)
15 really got into looking at this thing, about January, okay, and l 16 I took a look at what was said and so on.
17 So, in terms of what I am saying here, the resolution 18 was really achieved by when you had a task manager assigned.
19 When we bore down on the issue and said, okay, what are we
.20 coming to grips with, what is the real safety issue, etc., and 21 the point that I would like to make to the members of this 22 Subcommittee, on this issue the laboratory was allowed to study 23 it. I am going to use that word, deliberately, study it, and l 24 study it, and study it. i 25 In fact, when I got into it, out of the resources '
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V 1 that I will go into,. dollar resources, 3/4 of them had been 2 expended principally on running contempt runs, and so on.
3 And the point that I would like to make is that the ,
i 4 resolution of any issue is very much dependent on the NRC Staff 5 and it has.to come through the Task Manager, identifying what 6 end product are we looking for? And now, I am not saying this
.7 to guide or coach, but we have to point it to a direction, 8 saying,:I have a safety. issue, and I have either a principle or 9 several principle underlying concerns.
10 Now, analyze these with the best tools that we have, 11 and let's look at the upper and lower bounds and let's come to 12' a conclusion on whether this should be maintained in a low
- 13 level, a medium or it requires some regulatory action.
14 And believe it or not, one of the most effective 15 methods is to go up and live with the contractor for several 16 weeks, which is what I did.
17 I went up to the lab and I stayed up there for a week
.18 and we sat down and we discussed, you know, what are you 19 finding and let's lay it up, in a logical fashion. I think that 20 they did a clear job of presentation in thejr NUREG CR-4594, 21 and the answer comes out of it. Okay?
22 Now, the four years to arrive at resolution is ,
23 attributable in this case, to the fact that the Agency l 24 reorganized and generally speaking, if you go back into that 25 time frame, safety issues which were not USI's were considered l
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122 C.) 1 safety issues and somebody'was assigned as a caretaker.
1 2 So, I think that the principal thing that comes out s
3 of this, and.I have been involved in several USI's also, is l
4 that you have to assign a task manager and that task manager 1
- y 5 has to realize that that is part and parcel of thdir 6 evaluation.
7 And otherwise, you get to it on a Friday afternoon.
8 (Slide) .t 9- And now, the reason that I added this and please 10 don't take this the wrong way, because, again, if we had 'to 11 follow this up, with a cycle of taking even a low to medium 12 . safety issue through the CRGR, and also interact with the ACRS, i
13 you can easily count on another year going by because there is O 14 two or three months to prepare that package and.get it to the 15 ACRS. -
16 You go to the CRGR and you have a two-month, and I'am 17 not saying this is unrealistic, or an overburden, you are up to 18 six months, and we come down and we brief you folks, and we
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19 then prepare another set of documents and you rapidly approach >
20 a year. .
21 Put yourself into a medium or a slightly higher, you .
22 make several passes through both of these organizations. So 23 from my point of view, that if you have a USI, you can count on
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24 a four-to-six-year cycle. If you have a low-level priority or 25 low-risk issue, such as this, was even being focused up barf O lieritage Reporting Corporation (202) 628-4888
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1 L 1 here, take away the ~ two years that I would estimate as an 2 impact, because the reorgeization and passing around. j q
3 I think that ypu are encountering a couple of years g 4 to resolve a low-level Isr.urs if you take it through the steps 5' of doing the necessary lehl of calculations and coming at a
, 6' point of saying, do I, or don'*t I have a significant issue?
- (
7 (Slide) , q l
8 In terms of resources, I have tried to focus on -- 4
- l. .
9 MR. MICHELSON: 3dfore we get to the resources, since .
L 1 10 this is the break point of'your discussion, does the resolution 11 of issue 61, pertain to new ABWF's?
12 In other words, a new ABWR, since this says that it 13 19 a 'non-problem, for what it looked at, does that O 14 autbeatically mean that a j new ABWR does not have to have a 15 guard pipe?
16 MR. KING: I think that a new ABWR say if they would l
17 follow the EPRI approach and they would go back and look at 18 this issue and see if it applies to them. ,
(
19 MR. MICHELSON: In other words, this is another one 20 where I think ,t. hat they have to say, 61 does not apply because ;
7 21 61 never looked at the cost benefits of doing this on a new 22 plant. It looked at the cost benefits on an old plant and said 23 that it cost too darned mir;h for the benefit.
24 ,
MR. SERKIZ: Well, they fix this on -- I
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25 MR. MICHFLSON: And that is why they dropped it, I l O
lieritage Reporting Corporat. ion (202) 628-4888
s "ic 124 V 1' believe, and correct me, if I am wrong. Did 3you drop it, no
'2 matter if it had cost nothing, would you have. dropped it?
& 3 MR. SERKIZ: No, the principle reason for dropping 4 it, was that we wanted to look and yub have the sach report 5 that I have had and we have discussed this before.
6 MR. MICIIELSON: Yes, I have looked at it very 7 carefully.
8 MR. SERKIZ: Did the core melt frequency, the impact l 9 on core melt frequency that came out of this Brookhaven Report, 10 June of 1986, okay, was in the range of two times ten to the 1
11 minur seven, to as low as two times ten to the minus ten for c
12 reac ton year .
,f- g 13 Without even getting into, okay, the costs,
.. V 14 associated with that particular level of estimated core melt !
I 15 frequency, and there were four different scerrarios that were 16 looked at --
the potential impact on a calculated release, and ,
)
17 they were embedded in there, certain considerations that the 18 containment would fall, it would not fall catastrophically and 19 embedded in that were the considerations that the Emergency 20 Procedure Guidelines dealt wi.th certala -of the considerations 21 that come into this type of accident scenario and so forth.
22 That the entimatred release on a per reactor year, o 23 person rem per reactor year, rarged from something less than .1 24 to in the order of 5. When'I put that relative to other safety 25 transience issues or what have you, it does not warrant fh.
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. U 1 maintaining this as a principle definitely not medium, probably l 2 not even. low levels safety priority without even getting into 3 the discussion on whether there is a benefit, now getting into l 4 the hardware impact, dollars, by back-fitting or any way you 5 care to phrase it.
6 And the value impact analysis that was done really 7 did not dwell on back-fit costs, but dwelt principally on what l
8 are the associated, estimated risks? Extremely low. And that 9 is why I have answered your question that way.
10 MR. MICHELSON: So, what you are saying really is 11 that'the resolution would have been the same, even if it had 12 cost nothing to have fixed the problem.
13 MR. SERKIZ: That equivalency applies.
O 14 MR. MICHELSON: You did not quito say that when you 15 wrote up the conclusions. You did talk about both cost and you 16 know, both value and impact, and I never derived the feeling 17 that you ignored cost because impact, alone, was such that, I 18 mean it was such a low probability event, you just plain 19 discounted it. That was never presented as the reason for 20 dropping it.
21 DR. SIESS: He probably could not justify more than 22 $10 or $15.
23 MR. SERKIZ: Well, I am coming back to answer your 24 question, in that fashion.
25 MR. MICHELSON: So I guess when GE comes in with the O Heritage Reporting Corporation l (202) 628-4888 1
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V 1 ABWR, they can take the guard pipes off the tail pipes, which 2 they now have on there.
3 MR. SERKIZ: If they wish.
4 MR. HERNON: I am Ron Hernon and I am with NRR and 5 the EPRI program looked at all 700 generic issues that have 6 been ever identified with the NRC, since day one, and made a 7 resolution whether or not they applied to PWR or BWR.
8 I would expect the EPRI to have made some resolution 9 on the applicability of this, and all of the items in the new 10 -designs, regardless of the resolution for the existing plants.
11 So it is really a combination of EPRI and the GE 12 advanced BWR when it comes in. We are going to have a meeting 13 with the EPRI folks on October 6th, 14 DR. SIESS: We had a little question earlier, if the 15 NRC dropped an issue, EPRI is going to go back and look at it 16 anyway.
17 MR. HERNON: When we say dropped, that means dropped 18 from the standpoint of pursuing them with our. manpower 19 resources and implementation. That does not mean that it 20 disappears from the face of the earth, in any form or manner, i 21 and I think that was stated as such. J 22 They have been resurrected as part of Effrey effort 23 which has been going on for five or six years.
24 MR. MICHELSON: In terms of current technology, that 25 would be applicable to new plants, which might give you a l
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13 O l' dif ferent answer then, than the reviews that were done for !
i 2 older plants. f 3 MR. HERNON: Certainly would.
4- MR. MICliELSON: So, you're saying, then, that the A40 5 -- what was this? 80-61, will be picked up and looked at and 6 justified by Effrey?
7 MR. HERNON: It would be, yes, it would be among the 8 generic issues for which a decision has been made regarding 9 applicability.
10 MR. MICHELLON: Well, how about A46 since A46 never 11 was intended to apply to new plants, apparently; it was only l
12 intended to apply to old plants.
13 DR. SIESS: It wouldn't have been disposed of on that O 14 basis.
15 MR. MICHELSON: Could it be just disposed of as it 16 never was intended --
17 MR. HERNON: Whatever the basis was, and there's sorne 18 rather detailed documentation that the staff has sent ACRS 19 recently --
20 MR. MICHELSON: I'll look carefully when I see that.
21 MR. HERNON: -- regarding A46.
22 MR. MICHELSON: Yes, we'll get to that eventually in 23 that Effrey report.
24 DR. SIESS: Has Effrey been through all of the 25 issues?
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!O U- 1 MR. IIERNON: It's my understanding, at least the ones 2 that have been resolved. 3 i
-3 DR. SIESS: And you said that's been sent to us?
4 MR. HERNON: That was put together in a three-ring 5 volume about three years ago. I can imagine your staff has got ;
6 it.
7 MR. EBERSOLE: In the course of looking at this, did 8 .you look at the German rationale for double-wallirg this pipe, 9 and discounted it as being unnecessary, worthless? ,
10 MR. SERKIZ: Did not look at that, sir.
11 DR. SIESS: Maybe they didn't either. They do a lot l
12 of things just because they look like a good idea.
'13 MR. MICHELSON: Yes, true. They use judgments 14 sometimes, where there certainly are uncertainties in this 15 business. And this tailpipe is one of those areas where it's 16 very difficult to really say what's happening.
17 DR. SIESS: We're not allowed to use judgments. J 18 MR. EBERSOLE: In the study of the chugging problem, 19 weren't these pipes subject to special bracing to cause them to 20 remain in tact?
21 I know there are qualifiers in the structural design 22 and aspect of bracing.
23 MR. SERKIZ: I seem to recall language of that type, 24 but I can't, you know, specifically say go to this document or l I
25 that document. ;
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129 U 1 To give you an idea of the level of resources 2 expended, the resources expended prior to or at the time I was 3 assigned to manage this particular generic safety issue, we had 4 a fin at Brookhaven -- this particular number.
5 The time frame was here; roughly a year and a half.
6 We expended $175,000. It was principally code work, running to 7 contend code and staff by an analyzing.
8 1 tried to track down hard evidence for this meeting 9 because we've gone through now at least two reorganizations, 10 and maybe as many as three in this four year time frame.
11 I've heard numbers from previous people that had been 12 assigned to follow this issue, technically ranging from 20 to 13 30 to 40 units -- today's dollars, and knowing how staff time O 14 was expended.
15 I feel fairly comfortable to say that the prior 16 costs were less than 80,000 -- may have been as low as 20,000.
17 But all in all, what we've expended here is somewhere in the 18 order of 200 to 225 thousand dollars to technically evaluate, 19 make judgments on the safety significant, and close on the 20 particular course of action on this generic issue 61.
21 The concluding phase, which is really when things, 22 you know, got done -- reanalyzed and done with -- was the 23 January of '85 to May of '86.
24 1 think the involvement of a person which is 25 currently a dedicated Project Manager is important.
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130 V(% 1 Caretakers, technical overseers -- these people will file it 2 for you.
3 I'll be very frank with you, when you want=to get 4 something done, there's got to be a simple point; one person at 5 'the Commission; one person at the contractor lab, or I
6 subcontractor.
7 And let's define what we want, get out and do it.
8 DR. SIESS: Well, is this unusual?
I 9 MB. SERKIZ: Well, it is from this point of view.
10 Until, let me say, the last two or three years, where we have >
11 gotten into the mode of assigning a singular task manager--
12 Project Manager.
13 This came about, I think, first on the U.S. side O 14 because of the unresolved safety issue --
15 DR. SIESS: Fine, but the question is, is a dedicated 16 Project Manager the current practice?
17 MR. SERKIZ: . In research, yes, definitely. And if 18 any species operation formally had hours which I worked in, 19 that was the nature of proceeding with getting an issue 20 resolved.
21 There was a central person; it says you're the guy, i j
22 you're the Project Manager. {
l 23 DR. SIESS: I hear you, but I still don't quite 24 understand why you're telling us -- are you trying to justify i I
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l 2 working'-- don't let it lapse to what it was, where people were 3 just Technical' Overseers.
4 DR SIESS: And what was the difference between a i
5 Technical Overseer and a dedicated. Project Manager?
6 MR. SERKIZ: Very simply, the . Technical overseer 7 would get a report. occasionally from the lab, look at it, and 8 have to make a judgement.
9 And generally speaking, the report was found 10 acceptable because there was another piece to the puzzle. A 11 dedicated Project Manager says we have a safety issue -- it has 12 this scope; we have a schedule; we have fiscal resources; and 13 runs it as a Project Manager, and is given the authority to run 14 it as a Project Manager.
15 DR. SIESS: I still don't understand, but since we 16 are using a dedicated Project Manager now I guess it'r not 17 important.
18 MR. SERKIZ: Well, I don't know. It could be due to 19 the NRR. People that are present, want to comment on NRR's 20 . current position?
21 DR. SIESS: 1 thought these were handled by research.
22 MR. KING: Well, I was in NRR. Right now, there are 23 68 issues under resolution; 17 are in NRR, the other 51 are in 24 research.
25 DR. SIESS: Now, does research have a d.edicated L O IIeritage Reporting Corporation (202) 628-4888
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(). 1 Project Manager?
2 MR. KING: Yes.
3 MR. SERKIZ: Yes.
4 DR. SIESS: Can anybody speak for NRR?
5 MR. HERNON: What's the question again, specifically?
6 DR. SIESS: Is there 3 dedicated Project Manager 7 assigned to those generic issues of being resolved in NRR?
8 MR. HERNON: For the most part, yes. That person is-9 called a Lead Project Manager. That person has other duties, 10 normally.
11 But that person is responsible for following 12 implementation of the generic issue until the last plan is 13 completed.
14 DR. SIESS: We're talking about resolution, aren't 15 we?
16 MR. HERNON: I'm sorry?
17 DR. SIESS: Aren't we talking about resolution?
18 MR. HERNON: Talking about implementation.
19 DR. SIESS: No, 're talking about resolution. I'm 20 sorry, Ron.
21 MR. HERNON: I can't speak to the resolution part. I 22 think you have to get down to a specific issue because the ones 23 that remained with NRR remained with NRR for a specific reason 24 in the case of, for example, control room habitability.
25 The reason that one utayed with the NRR is because l
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2 DR. SIESS: I'm getting everything but an answer.
3 Carl King says that there were 17 generic issues, the 4 resolution of which were being handled by NRR; the remaining 5 ge eric issues the resolution of which is being handled by 6 research.
7 He said those that are being handled by research have 1 8 a dedicated Project Manager. The question is, does NRR have a 9 dedicated Project Manager for each of those 17 items?
10 MR. HERNON: NRR, organizationally, is not set up to 11 have generic issue Project Managers. I would have to say some 12 do; some don't.
13 DR. SIESS: Some do; some don't.
O 14 MR. HERNON: I know of some that do; I know of some 15 that probably don't.
16 DR. SIESS: And those that don't, who's responsible 17 for seeing that they get resolved?
18 MR. HERNON: I don't know what they are so I can't.
19 comment on that. It depends on what they are. They're 20 assigned to specific provisions.
21 There's not one central generic issue portion of the 22 NRR organization. They're fairly well scattered out throughout 23 the organization, depending on what they are.
24 MR. MICHELSON: Dut there's somebody, at least, 25 assigned responsibility.
O lleritage Reporting Corporation (202) 620-4808
i .: 134 1- MR. HERHON: Yes. There's at least a Division 2 Director that has within it's division the _ responsibility for 3 resolution of that item.
4 DR. SIESS: I'm confused now because somewhere in the 5 course of two Subcommittee meetings, and two meetings with the 6_ staff, I'm learning for the first time that resolution is not 7- always the responsibility of research.
8 Now maybe somebody told me that and it slipped by me.
9 MR. HERNON: That's a true fact. And we can get into 10 that when we.get into the NRR portion of the meeting. For 11 example, there have been a number of issues --
12 DR. SIESS: I know all about that. I want to talk 13 about -- we've had a meeting of this thing with the staff to 14 talk about the resolution --
that's one phase, and 15 implementation is another.
16 And I now find that we only have part of the 17 resolution. Now this is the kind of information I think is 18 important if we're going to report to the Commission on the 19 effectiveness of the program.
20 If the program is more or less effective in one 21 organization than in the other, or to be carried out 22 differently, that's a question the Commission has asked us to 23 look at.
24 And I'm not complaining. It's just that I didn't !
25 realize it till now that we overlooked 20 percent of the l
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1 program that's being carried out in NRR for resolution.
2 MR. HERNON: It's important for the Subcommittee to.
3 understand there is not a single way in which the Commission or 4 the staff deals with generic issues.
1 5 There is a very well organized system that you've 6 heard plenty about from research. There is a number of other 7 ways, going back to the TMI action plan which accounts for a 8 large number of the issues that are still being implemented.
9 There have been a number of major events such as the 10- Davis-Bessy event; the Ganae event; the Stadum Hadles event--
11 that never did go to a generic issue portion of the 12- organization.
13 It was important enough; it was resolved and O 14 corrective action was specified by the operational --
15 DR. SIESS: And I assum9 that those were not the 16 generic issues the Commission asked us to look at.
17 MR. HERNON: Those are generic issues, though.
18 DR. SIESS: I don't have exact proof. The Commission 19 asked us to look at the effectiveness of the resolution of 20 generic issues.
21 And I assume, as USI does, generic issues -- and I 22 think by that they meant generic issues with a capital G and a 23 capital I.
24 MR. IlERNON : The staff doesn't look at it -- at least 25 my personal opinion, you can't disregard the other items O
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\ 1 MR. MICHELSON: It was all in NRR then, and now what 2 you're saying is that you relinquished all but 17.
3 DR. SIESS: Okay. I think we were told that some of 4 the issues were still open to have a resolution because the 5 Task Manager or somebody was over there. Is that right?
6 MR. KING: True.
7 MR. SWINK: Something might help. We're in the 8 process of assigning --
9 DR. SIESS: Who is "we?"
10 MR. SWINK: We, NRR. My name is Walt Swink from NRR.
11 We are in the process of assigning a lead technical person and 12 a lead Project Manager for every generic issue, whether it's in 13 NRR or it's in research.
14 We have already done that for the rules and 15 regulations. And we should have all the generic issues ;
16 assigned by the week or the first of next week.
17 DR. SIESS: Thank you.
18 MR. MICHELSON: By " lead" do you mean he's supposed 19 to remain cognizant of the status of it and so forth?
20 MR. SWINK: Yes. He would be involved early in the 21 process for issues that are in the early resolution, like the 22 medium issues. I 23 Ile would remain with through the last plant-making 24 modification. And of course, the lead P.M. would be involved 25 from the generic imposition all the way through the last O ;
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() 1 because the other items are fact; account for most of the 2 licensing actions that NRR processes.
3 DR. SIESS: Sorry, Ron, you just don't get the point.
4 I will put in writing what I want from NRR and send it to Mr.
5 Merrick -- or to the Commissioner's. 'I'm not sure which.
6 MR. FRAHN: I'm not sure there's a misunderstanding.
7 If you look at the gimmicks out-put, there is a Task Manager in 8 NRR, our division assigned the 17 issues that are NRR.
9 Now I think what Ron is saying, he doesn't know 10 whether they are working full-time on those issues.
1 11 DR. SIESS: We've spent a lot of time talking to i 12 research about the process of firization and resolution.
13 And now I find that we haven't got the whole picture.
'd 14 And the thought of a particular leverage act may be important; 15 I don't know.
l 16 Did firization spread between the two of you?
17 MR. FRAHN: No. We do that.
18 DR. SIESS: The resolution was always a joint effort, 19 I though, it involved both people. But I thought it was under 20 the responsibility, too.
21 And some of this responsibility goes to NRR.
22 MR. KING: Just in this last three organization. l 23 MR. FRAHH: Reorganization, 17 issues remain with 24 NRR.
l 25 DR. SIESS: How was it before that? !
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2 MR. MICHELSON: Is this to assure equalized treatment 3 or something?
4 MR. SWINK: Well, it's equalized treatment; it's also 5 to make sure that the language of licensing is taken into-6 account in the resolution itself.
7 And also from a technical point of view that specific 0 key elements that we're looking for in the resolution in fact 9 wind up in the last plant as being addressed.
10 MR. MICHELSON: Once this list is issued is the 11 future, if I have a question on a particular generic issue :
12 where I wonder where it is or, you know, how it's being -- he's 13 the fellow I call?
- O 14 MR. YU: Yes, sir.
15 MR. BAIRD: No, sir. If it's in the resolution base, 16 call the Task Manager, I would say.
17 MR. MICHELSON: Which task are we talking about? I'm 10 talking about a particular generic issue -- generic issue 61.
19 I might be interested in it for some reason.
20 And I want to find out, well how are you doing on 21 that implemented somewhere?
22 MR. BAIRD: During the implementation phase is 23 correct, but if you begin the resolution phase --
24 MR. MICHELSON: Wait a minute, I'm not talking about 25 resolution. I'm talking about those that are resolved, and I'm j O .
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l 2 DR. SIESS: Okay. IIold it until the next part of the ]
3 meeting. ,
l 4- MR. MICIIELSON : Then they're going to tell me. l 5 DR. SIESS: Cause we're going to devote that to 6 implementation. I know they're going to tell you. Somebody'll I
7 probably tell you to look it up yourself. I'm sure Walt will l l
8 tell you that, right? l 1
9 MR. IIERNON: Dr. Siest, I would like to point out the 10 NRR was not requested to come down here and talk about l 11 resolutions --
i 12 DR. SIESS: We didn't think they had any involvement. )
13 MR. HERNON: We would havo lectured to the 17 that O 14 you 're ' talking about. We didn't come down to talk about the 1 l
15 resolution of this process. J l
16 DR. SIESS: Well, the reason you weren't asked to q 1
17 come down is because we -didn' t realize that there was 17 that l I'
lu you had. But I have some recollection now that they were so 19 far along -- I remember that impression.
20 And that's probably why we ignored it. Anyway --
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21 MR. SERKIZ: Anyway, just brief1y in conclusion, ;
22 since the topic of related research was on your agenda, there I 23 was no special research required for GSI-61.
24 The resolution was based on a reassessment, which was 25 based on -- and my own typing is showing the use of actual Heritage Reporting Corporation (202) 628-4888
140 1 plant data. )
2 If we take a look at things more closely, I think l 3 some of the gentlemen will realize we got into how many check 4- valves do you have located, and so on.
5 For example, the prior organization assumed one. You 6 go back and look at plant data you have to check valves series 7 predominantly.
L 8 The pipe rate probability is based on more current-l 9 theories. So, I guess from that viewpoint, Mr. Chairman, we 10 did take advantage of research because the pipe rate analysis, 3 11 the theories, the back-up research was folded into the l-12 calculation; they were revised to content code calculations.
'13 And some of the internal models of the contempt code 14 had benefited them several years of code related research.
1 l
l l 15 DR. SIESS: But contempt is all based on research, l
l 16 isn't it?
l l 17 MR. SERKIZ: Yes, but in terms of special research we 18 did not need a facility; we did not go out for experiments. It 19 was analytic.
l 20 MR. MICI!ELSON: Just in a matter of procedure again.
21 I think you answered this earlier, but this is another good 22 example.
l l 23 Let's assume that some time in the future we find 24 that the air return valves between the torric and the drywell 25 sayer are sticking open frequently.
f~\
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,q V' 1 And the probability of - them being open'is going way 2 up. How do we -- of course this is a simple one, so I guess 3 we're smart enough to realize that this resolution becomes 4 invalid because of that, because it was tied up very much in _k 5 this probability of the event.
6 But on a more complicated generic issue, we somehow 7 have to realize that that issue 'might be affected, and go back 8 to see if the new information really invalidated it.
9 Assuming that we did, and assuming that it was found 10 invalid, then I guess we decide whether to open the issue or to 11- create a new issue.
12 MR. SERKIZ: Well, I think the way I would answer
. 13 that is, you're raising a concern; you may not even know that 14 work went on before.
15 I would assume that the procedure from the other 16 place would allow you to raise the generic issue. You identify ;
i 17 an issue -- remember, we prioritize it; we'll go back and look 18 at all the related issues.
19 MR. MICHELSON: Yes, but I'm wondering though that 20 before I get far enough to realize that I do have a generic 21 issue that somebody will convince me, "Oh that thing was put in .
l 1
22 bed years ago; that issue was resolved." l i
23 And I might not be smart enough to realize it was !
l l 24 resolved on a basis which is no longer valid.
l 25 DR. SIESS: You would. I doubt about somebody else.
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-2 because it will be formally resolved for you then.
3 MR. MICHELSON: Yes, but you know you like to talk i 4 people out of creating generic issue and things.
5 DR. SIESS: Yes. I mean, if a fellow came up with 6 this as an issue, and'somebody said, "Oh, well that was looked 7 at a long time ago."
8 And he took a quick look at it and didn't dig into 9 it, he mighty just assume it was. And the trouble is that 10 there are lots of things that have never been generic issues 11 that could become an issue because something changed.
12 MR. MICHELSON: Yes, that's also a possibility. !
13 DR. SIESS: And what they're saying is, if you just 14 weren't cowered by some previous action, they'd have to go back i 15 and look at it. l 16 MR. MICHELSON: Yes. What I would like to do is have 17 a computer bank that has a few of the key contractors that were 18 decided in such a way, so I can go back and test real quick to 19 see if those key parameters might have affected any of the 20 generic resolutions.
21 MR. SERKI'Z: I'd like to comment on that question or 22 point that was brought up in the context of generic safety 23 issues, 61.
24 I think the type of NUREG CR that Brookhaven laid up l
25 with a detail of the assumptions on it, convey the equivalency O
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~1 'of a computer bank information source. And you have. That's 2 why I want to answer your question directly.
3 If we have a technical findings report that is fairly 4 thorough, has marched through things systematically, has 5 contained in there assumptions and probabilities, et cetera.
6 And if a concern related to some part of that 7 analysis, either top bonus or the type of accident treatment, 8 one contests the previous premise by saying I'll raise that 9 probability to one and see how much my results change.
10 If we have a technical f1.ndings report which is based 11 principally on hypothesis, and otfher hypothesis, and all that 12 we can to drive.us immediately tu looking at a situation that 13 is not supported by the level of calculations that can be made,
%)
14 then we're going to have the sit l1ation ae gone up here, having 15 to go back and make a reassessment. 1 16 But generic issue 61, I would suppose that if they're 17 not questions related to some of these, then one can make a 18 determination saying how mucr. does my answer change prior to 19 going off somewhere?
20 So, I think the technical findings report in any 21 safety issue for USI is imp;>rtant, very important.
22 DR. SIESS: I think the point Carl made is, some 23 point many years from now what was it, the vacuum breakers, is l 24 that what you referred tc?
25 MR. MICHELSON: Yes. Yes.
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.g i DR. SIESS: Became unreliable. He would like to be 2 able to go into the data bank and look up vacuum breakers and 3 find every question that's ever been raised about vacuum 4 breakers.
5 MR. MICHELSON: Every generic issue that involves 6 vacuum breakers in their resolution --
7 DR. SIESS: Better to address vacuum breakers, and i
8 involve them to see if that now had changed.
9 MR. KING: You can do that for the generic issues.
10 That's all on overline 3-3. You can take generic issue on 11 vacuum bracers, you can find out what was assumed in that issue 12 that turned out to be -- )
13 DR. SIESS: But suppose vacuum breaker wasn't the O
b 14 issue. See, something else was the issue, but vacuum breaker 15 was one of the factors that was considered in the issue.
l 16 It wouldn't be a depart.
17 MR. KING: It's a tougher job.
18 DR. SIESS: You see your key words. If they gave you l 19 a set of key words and key components you could do that. Of I 20 course that's easy to do after the fact, you do it at the time 21 --
22 MR. MICHELSON: This is when corporate memory is I
23 nico; there'll be people around who remember. But eventually I i
24 there won't be people around who worked on this; it's a whole 25 new crew. !
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/7 U 1 And they don't have the corporate memory to realize 2 how much tied in --
3 MR. SERKIZ: Sounds like building a general corporate I
4 data network. l 5 DR. SIESS: Gentlemen, it's now 12'o' clock. It's my 6 proposal that we go through the ' lunch hour. We've got i
7 something down here for about an hour and 15 minutes of 8 presentation time.
9 There was something on here for Subcommittee remarks 10 that I think we can easily defer. Van, are you and Walt the 11 only ones here now? Pamela didn't come in? So, we have no l
'12 representative of the project man? You're not a project man.
.13 Okay, give us what you can. You can pick a couple of 14 items to discuss.
15 ~ MR. SWINK: My name is Walt Swink, and I'm Chief of 1
16 the Generic Activities Integration Section in NRR. And I want 17 to context what Ron and I are going to say in terms of the NRR .
~
18 portion of the end of it to say we had really focused on trying 19 to get good power to address those issues that were identified 20 in the agenda, and then responding to our views about how they I 21 were addressed by Duke lloward.
22 So, we're kind of winging it in terms of these last 23 items on the agenda, although it is somewhat of an opportune 24 time since we have been working with research to identify 25 weaknesses in a generic issue resolution process.
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146 1 And also articulate how to fix those weaknesses, and 2 put that into some kind of single focused management attention 3 to improve the process.
i 4 DR. SIESS: Now you said resolution.
5 MR. SWINK: Yes.
6 DR. SIESS: Is that what.you're talking _about?
7 MR. SWINK: Well, it's more than resolution, it's the 8 whole process of identifying the issue, .priortizing the issue, 9 resolving the issue, imposing the resolution, generically 10 imposing the resolution plan specifically, making sure that the 11 plant implements it as we intended the resolution to be 12 implemented. ;
l 13 DR. SIESS: Now we thought we had looked at 14 resolutions in our previous meetings. You have something new 15 to tell us about resolutions?
1.6 MR. SWINK: Really, the context only of what we 17 identified at this meeting we had with research where we ,
i 18 focused on how to improve the resolution process as part of 19 addressing this whole generic issue process, weaknesses and so 20 forth.
21 DR. SIESS: I think we'd like to hear what you have 22 to say about improving it.
1 23 MR. SWINK: Okay. Again, I'm addressing the whole l 24 thing from cradle to grave. One of the weaknesses that was
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L 25 identiflod, and again, in answering the general question of how l
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(,) 1 effective is the process, in general we think it's effective.
I 2 In specific, we know there are some weaknesses based 3 on our past experience; our current experience in trying to go 4 back and validate what we did on generic issues at what plants.
5 In~the improvement area, we think that there ought to l 6 be a global approach to generic issues rather than quote the 7 big G, big I generic issues.
8 For example, the agency works on a lot of things, 9 There are rules; there are reg guides; there are bulletins; 10 there are policies; there are generic letters; there are 11 Industry actions that are endorsed by NRC -- they're all 12 generic.
13 We think that the scope of the generic issue should 14 be expanded to be what the agency does about generic things so 15 that number one, they're consolidated; they're integrated; 16 they're phased such that one organization's not working on 17 something as a high-priority, versus another organization 18 working on something as a low-priority, both in terms of i
19 resourcement and schedule. i 1
20 The generic issue has typically been focused on, 21 quote, "USIs and GIs." In fact, the agency does things in a 22 broader context with generic things than those two identifiers.
23 So, our recommendation was, in this research 24 discussion, that there be a broadening of this generic issue 25 concept.
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-V 1 And these things were being considered as part of 2 researcher's effort to deal with the front end-of the process.
3 We think that there ought to be a better articulation of the 4 issue in terms of both its scope and its key points. i
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5 What's broke that we're trying to fix? We do a
]
6 rather elaborate write-up that one can criticize in terms of 7 what it says and how it says it and so forth.
8 But eat we're really looking for is, what are the
{
9 key points of this thing that's broke so that we can focus on .
10 those to fix it and not get caught up in some of the trivial 11' stuff that's on the outside of the issue?
12 And if we do that well, then we ought to be able to o 13 14 articulate its relationship with other issues in another way.
We think this consolidation and integration, with 1j 1
l 15 existing generic activities is important so that the left hand j 16 knows what the right hand's doing, and the whole agency is 17 focused on what it thinks is important versus what it thinks is l
18 unimportant.
i 19 We're talking, in this context, of the rules, reg !
20 guides, generic letters, bulletins, generic issues, USIs, I
21 industry -- ]
1 22 DR. SIESS: Those are generic actions. )
23 MR. SWINK: That's a better word.
24 DR. SIESS: Not generic issues.
25 MR. SWINK: Well, except there are generic actions
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1/ 1 that are addressing generic issues; a bulletin that goes out 2 addresses a' generic issue.
1 3 A generic letter that goes out addresses a generic 1
4 issue. l 5 DR. SIESS: I'm trying to get what you're getting at 6 here because what you would be doing is dividing everything the i 7 NRC aoes into two categories, generic and plant specific. l 8 MR. SWINK: No. I'm suggesting that everything NRC 9 does is a generic issue that's being addressed in some form-- ,
j 10 be it a rule, a reg guide, a generic issue resolution that has 11 been typically -- .
12 DR. SIESS: That everything NRC does is a generic ;
13 issue? A tremendous amount NRC does is plant specific
~
14 MR. SWINK: No. I understand that.but in terms of 15 the generic things, like bulletins, letters, reg guides, rules, 16 the generic issues that have been --
17 DR. SIESS: Well then why did you.say no when I said 18 you were trying to divide what NRC does into plant specific and 19 generic issues? )
20 MR. SWINK: Because I'm suggesting that all of the l l
21 generic actions that we take now are divided into separate ]
i 22 categories. 1 23 And I'm saying that those generic categories are ,
24 really generic period.
25 DR. SIESS: Yes.
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O 1 MR. SWINK And we shouldn't try to break them into 2 .those separate categories.
3 DR. SIESS: Why not?
4 MR. SWINK: Because they get fragmented and lose 5 their. association. We're dealing with the same topic, and we 6 sometimes fix the 'same ' thing twice; and we sometimes lose the ]
7 integration and the consolidation, 8 DR. SIESS: Could you give me an example? I can't a
9 see that an organization has to be homogenous simply because it 10 has a general function. Most things get divided up; electrical 11 people work on these problems; mechanical people wo.rk on these 12 problems; constructual people on these problems.
13 You have divisions'of respons ibi.' i ty . You trentioned '
O 14. reg guides -- an awful lot of reg guides come out as a generic 15 issue resolution.
16 MR. SWINK: That's correct.
17 DR. SIESS: A lot of them don't come out as a grnori,3
.18 issue resolution.
19 MR. SWINK: There are also a lot of reg guides that 20 are not tied to a generic iscue resolution.
21 DR. SIESS: But they are. generic actions.
22 MR. SWINK: That's correct. But they're dealing with 23 a generic problem.
24 DR. SIESS: And would you treat a reg guide that's 25 dealing with a generic problem that isn't a generic issue O
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3/ MR. SWINK:- Okay, I would prefpr to call it a generic 4 topic, and all the things that are associatad with that topic
\
5' are dealt with in a problematic area of discussion of that I s
6 topic that says -
v 7 DR. SlESS: How would you ddine a topic? i i ni I 8 MR. ' SWINK: A topic wauld be is someone raised a 9 question of station blackout -- I.would expect to see in that
./ e 10 station blackout topib all of the things having to do with 11 dealing with station blackout.
12 For example, the. tie to diesel genecutor reliability, 13 which includes a generit- letter that was issued -- several
,. /
i 14 generic letters that were issued; pump seals --
l , i 15 Of SIESS: Systems interaction. ,
16 MR. SWINK: DC , batteries ; diesel generator l
1 l 17 reliability, f66. !
18 DR. SIESS: Now these are all either generic 19 issues,or something else that's going on.
l 20 MR, SWINK: That's correct.
21 DR. SIESS: Let me suggest a topic, and tell me what '
22 you'd do, Seismic safety.
/ 23 MR. SWINK: Seismic I see as a qualification issue, l
,j. 24 and I would deal with it as part of -- I want to make sure that 25 the plant -- both in terms of structure and equipment -- can l
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'l survive seismic events.
2 DR. SIESS: That's only a small fraction of the 3 issue. You left out the seicmic hazard, the seismic analysis, 4 you see? .;
5- MR. SWIHK: But that's all a part of how I would be 6 ' able to come forth and say.that a structure can survive this )
7 seicmic event.
8 DR. SIESS: All right, but dentatade would come under 9 this. Wholly geological, seismological research would come 10 under this.
l l 11 MR. SWINK: That's the chemical of it; that's 12 correct.
13 DR. SIESS: So, how would we now bring those O 14 disparate portions of the activity together in some l
15 consolidation integration.
16 MR. SWINK: Well, I would look for a program area 17 description that says here's all the tentacles that go along 18 with seismic.
19 And then I would still keep all the pieces that we're 20 talking about in terms of it may be necessary to short term the 21 issue or bulletin; it may be necessary to do some short term 22 research, some long term research; it may be necessary to 23 fragment it into sorne pieces that are doable, rather than try 24 to take on the whole topic as one thing.
25 DR. SIESS: The consolidation would be what, in a O '
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153 1 . branch? I mean, right now in research you've got a structural 2 and geotactical plan; and all the seismic research is in there.
3 MR. SWINK: But I'm not suggesting there be an 4 organizational consolidation; I'm suggesting a topical 5 consolidation under one description area called, "Here's what 6 we're doing for Seismic.
7 DR. SIESS: Some other kind of cross-cut.
8 MR. SWINK: Right. And then under that topic, we may 9 decide to pursue five separate generic issues that are part of 10 that topic; you may decide to pursue some long term research 11 that's not part of any of those generic issues -- it's just a 12 problematic area in research, 13 And you may decide to issue a bulletin immediately--
, 14 maybe even an order in a necessary case.
l l 15 DR. SIESS: Now, you've got a bunch of different l
16 organizations, and each one has something outside going on.
17 Now what do you put in across there to do it?
18 MR. SWINK: Well, by having this topical approach, i 19 one could define all of the pieces or chemicals of that topic, 20 and then cross-cut across the organization identifying who is 21 responsible for each of those pieces, both in terms of the 22 resolution, and in terms of the actual imposition-l 23 implementation of the plant.
l 24 So, you have this cradle to grave approach for every 25 piece, for every tentacle of this topic outside.
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\ l DR. SIESS: That just says, you know who's doing 2 what, now what do you do about what they're doing?
3 MR. SWINK: Okay. By having this program area look 4 at it, this would be a program area level topical review to say 5 here's a topic called seismic; here's all the concerns that go 6 with that' topic; here's how those concerns are being dealt 7 with; here's who's doing it.
8 DR. SIESS: Who? I mean, you haven't got a computer 9 that can do this -- who does this? One person, or a committee?
10 MR. SWINK: This would be the global expansion of 11 what the generic l'ssue people do right now in research. When I 12 they look at a generic issue in the context of generic issues, 13 it would be a broader look at what's going on in these -- l
'O 14 DR. SIESS: But they do that by having a task manager 1
15 in a task group.
16 MR. SWINK: Well, once they've identified a generic 17 issue, that's correct.
18 DR. SIESS: Yes, but now somebody's got to look at 19 all of this station blackout activity. Is there going to be a 20 person designated to do this, or a committee?
21 MR. SWINK: That's what we would suggest, yes. And 22 that person would, depending on the size of the issue, may be a 23 committee.
24 DR. SIESS: And he could be one of the people in the 25 vertical organization, but he now has to look crosswise, too.
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V. 1 MR. SWINK: That's correct.
2 DR. SIESS: He just looks. And he finds something 3- that's wrong and needs to be fixed, now how does he get it
- 4. done?
5 MR. SWINK: Okay, two things. One is, he would have 6 to identify there's a piece of pie that's missing. Then he 7 would have to articulate what that piece is.
8 And then from there, there would be a decision of.
9 Ilere's how we would propose is the best way to handle this, be 10 it a generic letter, a bulletin, a reg guide, an industry 11 initiative that we can enforce by some policy need.
12 However, it would be appropriate for that piece of 13 pie once it's articulated.
O 14 DR. SIESS: Soundo like it could be useful.
15 MR. MICHELSON: Got a couple of questions. Is this 16 proposed as an NRR function?
17 MR. SWINK: No, we're proposing this as a joint 18 research NRR improvement of the whole generic issue process.
19 MR. MICHELSON: Would that mean the lead person might 20 be from one or the other organization?
21 MR. SWINK: Well --
22 MR. MICHELSON: I assume there's kind of a lead 23 person involved in this topic.
l 24 MR. SWINK: What I'm suggesting is that for example, 25 if you raised the question about --
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V 1 MR. WYLIE: Let's take the -- because it affects ~ a 2 lot of issues. Is it the intent to integrate these in some 3 way?
4 MR. SWINK: Yes. Consolidate and integrate.
5' Perhaps we're working two or three topics in the same area that G are very close, that would be better resolved if you 7 consolidate them as one topic.
8 And by doing that one topic, you would deal with that 9 issue. I think all of our issues fall into three categories.
10 MR. MICHELSON: Or, is the thought, though, that you
' 11 have a project manager for that topic? Or lead engineer; 12 whatever you want to call him?
13 MR. SWINK: Let me give you what I think the process O9 14 should be. I think for station blackout, we've just gone 15 through this exercise somewhat in identifying the tentacles of 16 station blackout for a rule that theoretically is already 17 finished and so forth.
18 And what that is pulling into it is, how are we going 19 to deal with the station blackout from the standpoint of diesel 20 generator reliability A30; the DC power; the pump seals -- and 21 pull those all together to understand that when you get this 22 package on station blackout as rule, understand you've
. 2.3 addressed a big piece of it, but there are still some other l
( '24 pieces that are yet to be addressed, and here's our current 25 plans for addressing those.
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.Q 1 MR. MICHELSON: I thought we were kind of talking 1
2 _ implementation here, though.
3 DR. SIESS: No, he's talking the whole --
4 MR. MICHELSON: You're still back looking for the 5 pieces that dropped in the cracks.
6 MR. SWINK: That's right. Well, I'm recounting this 7 meeting that we had recently --
8 MR. MICHELSON: But is this topical set up only to 9 find the pieces that dropped in the cracks, or is it to guide 10 through the implementation of the topic area?
11 MR. SWINK: It would do, first, the topical look.
12 And once you've got all these pieces articulated, it would 13 follow those pieces and the topic so you didn t lose sight of O 14 what you were trying to accomplish as an end result.
15 All the way from the resolution process, all the way 16 through the last plan's implementation, and the continuing 17 inspection to make sure that that still was maintained in that 18 plan.
19 MR. MICHELSON: This is sort of an overseeing 20 function you're articulating, then, is that right? It doesn't 21 do anything, it just oversees and makes sure that these things 22 are done.
23 MR. SWINK: The way we recommended it to research was 24 an expansion of what they're already doing to sweep in not only 25 the generic issues, but all of the other things that are going O \
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158 1 on separate from the generic issues that are generic so that we 2 take a programmatic approach to a topical area.
3 Topical area could be just station blackout for 4 example.
5 MR. MICHELSON: Let's take one little more 6 complicated topical area system interaction --
is that 7 considered a topical area, or is that considered a problem 8 relating to a whole lot of other topical areas.
9 MR. SWINK: I think it's both.
10 MR. MICHELSON: I think it's both. And since it is l 11 both, how are you going to handle it?
12 MR. SWINK: I don't have an answer for that because I-13 don't have an answer for the system --
O- 14 MR. MICHELSON: You haven't predetermined that yet.
15 DR. SIESS: And you were going to say a few minutes 16 ago that everything falls into three something.
17 MR. SWINK: Yes, personal opinion. Everything falls 18 into three categories. One is, shut it down; koop it shut 19 down.
l 20 Two, maintain the integrity of the systems. And 21 third thing is course remove heat. If you do that you have a 22 safe plant.
23 DR. SIESS: What was the third one?
24 MR. SWINK: Decay heat -- remove decay heat.
25 DR. SIESS: Okay.
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2 generation; keep it shut down. Maintain the integrity of the -q s
3 systems, and then the third thing is remove decay heat.
4 If you do that you have a safe plant -- my personal 5 feel. The~ issues, the rules, the reg guides, the generic 6 letters, the bulletins, the inspection activity, the licensing 7 activity -- everything seems to focus around those three things 1 l 8 in my personal opinion. 1 1
9 DR. SIESS: And seismic cuts across all three.
i 10 MR. SWIHK: That's correct. What we have suggested 11 to research is, we would like to see a more global approach to 12 the generic issue prioritization process; resolution process, q g- 13 so that when we deal with a topic we know what all the pieces
.]. 14 of the topic are and we're sure that there's nothing that's 1
l 15 been missed.
16 And we're sure that one generic issue person working 17 on a _ generic issue knows that he relates to another generic 18 issue person.
19 And those two, rather than wait till you see what 20 I've finished, work together interaction-wise to make sure that 21 that comes about, that when all of these pieces are finished, 22 it goes together in a whole piece of pie.
l 23 And we have a sense of how we're dealing with that 24 topical area both from the initial part of what we thought was 25 broke, to the end, when the last plant makes the modification, Heritage Reporting Corporation (202) 628-4888 l
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160 0 1 and the judgement about how to keep that modification current.
2 DR. SIESS Well, this clearly addresses a concern 3 that has been raised, that there's been narrowing of generic .,
4 issues to make them tractable, but losing the broader 5 viewpoint.
l l 6 Now what you're really saying is, keep them narrow 7 and tractable as necessary, but aggregate them -- it may be a 8 better word to consolidate, I don't know.
9 Integrate, aggregate, they're still discreet pieces 10 but they're brought together. I'm a concrete man.
11 MR. SWINK: Your word's fine.
12 DR. SIESS: Aggregate them so that there's an s 13 interchange among the people managing the various ones and 14 somebody that takes a larger viewpoint.
15 Somebody like the ACRS starts raising questions about 16 how they relate to each other, those that do that. I think 17 this has potential; I think the difficulty is in finding the 18 collections to make.
19 MR. SWINK: I agree. .
s 20 MR. WYLIE: Well now, let me ask -- I heard the word 21 " integrate." Is it the intent to integrate these things?
22 MR. SWINK: Yes.
23 MR. WYLIE: That's a little different issue.
24 MR. SWINK: Let me answer the way I mean integrate.
25 When I say integrate -- I think Carl raised a question about -
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(,/- 1 well, in systems interaction, they told us they were going to 1
l 2 fix an'A46. They told us they were going to fix it, systems 3 interaction. 4 4 Presuming he's right, I would expect integration to 5 have stopped that inconsistency.
6 MR. MICHELSON: Well, I do.n't think what you propose 7 is going to stop it either because that topic -- the topical 8 area as you're setting up all may involve system interaction. !
9 And it can all be necessary to the leaders of system 10 interaction; it can be the leaders of a topical area. In other 11 words, that area, and how system interaction may relate to it-12 - you've still got the problem if integrating some of these 13 high level things.
O 14 DR. SIESS: Systems interactions is a state of mind.
15 MR. MICHELSON: It's a real problem; it's not just a 16 state of mind.
17 DR. SIESS: Integration -- and I guess to use words 18 without defining them doesn't help, but I'll try. You can 19 integrate at various levels.
20 Some of them you may have these strands coming down 21 here, and it'll turn out that you can pull these two together; 22 these two together --
or you may continue on down to a 23 resolution as separate areas.
24 But the implementation can be integrated.
25 MR. SWINK: Yes.
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1 DR. SIESS: One may affect the other; may have to be 2 integrated.
3 MR. SWINK: For example, it might have five required 4 modifications to one system, and they're spread out at three or 5 four different times.
6 It may be safer, and it may be less occupational 7 exposure intensive, and it may be less costly to.make all those 8 modifications at one time, and you're done with it.
9 So, the way to approach that is making sure that the 10 schedule is for implementation -- resolution, whatever what you 11 want to call it.
12 Look at it in terms of doing an integrated 13 modification to that particular system.
14 DR. SIESS: And it may be that all five modifications 15 aren't necessary when you look at what you're trying to 16 accomplish.
17 MR. WYLIE: Well, let me ask you the question this 10 way, that the resolution to, say, decay heat removal--
19 depending on what the resolution is -- could make void the 20 resolution to A44, for example.\?
21 MR, SWINK: Possibly.
22 MR. WYLIE: Is that going to be considered?
23 MR. SWINK: We're asking that question right now; the 24 answer seems to be no, we want to go forward with station !
I 25 blackout.
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V 1 MR. WYLIE: That weakened to a position on A45.
2- DR. SIESS: But you see, that's taking the thing that i
3 is already operating and trying to fit.it. )
l 4 MR. SWINK: That's right. 1 5 DR. SIESS: Suppose these things had been aggregated ;
6 or coordinated earlier? ;
)
7 MR. WYLIE: That's what I'm getting at. The )
8 resolution --
9 DR. SIESS: Way back in the beginning, suppose 10 station blackout and decay heat removal or whatever had been 11 looked at; seen that these relate to the same thing, and been 12 handled together from the beginning. l i
13 You might not get to that point where --
0 14 MR. SWINK: Well, for example, we just had a meeting i 15 on severe accident; we raised the question, should the severe 16 accident policy take into account severe accident management?
l 1
17 In other words, would you want to have plants '
10 designed with the capability of maybe additional structures and 19 components that would allow you to manage the problem of having q l
20 the core on the floor. j i
21 I don't know if that's viable but I'm saying that i 22 that's a consideration.
l 23 DR. SIESS: I think you'll find that that's the
- i. 24 approach that the Germans are taking. They look at the l
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164 0 1 it 9ete to taet ete9e to mexe it e 11tt1e eeeier2 2 MR. SWINK: The point I'm making is, we're asking 3 that question in terms of contexting it as what should the 4 agency be doing for severe accident.
5 A piece of it is equipment design. A piece of it may )
6 be procedures. And another piece of it may be emergency 7 response.
8 We're asking the question now, how do these pieces 9 interrelate, rather than letting them go down separate paths?
10 I don't know what the answer's going to be, but we're asking 11 that question as a topic. -
12 How should we deal with a severe accident as an 13 agency for both the existing plants and the new plants? And 14 we're now forcing the people who had focused on the equipment 15 part of a severe accident to talk with the management 16 procedures part of severe accident -- those people to talk j 1
17 together to see if there's something you can do that's common l l
18 to both that helps both out.
19 That would be the topical approach to severe 1
20 accident. I don't know what all the pieces are yet. I 21 DR. SIESS: I'm surprised you didn't use the words ,
1' 22 prevention and litigation.
23 MR. SWINK: Well, he people in the equipment area are 24 focused on prevention. The management procedures part are 25 focused on -- you've done all you can in provention; now the 1 l
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(h 1 question is, you've got the core on the floor, what do you do 2 now?
3 DR. SIESS: If you look through the list of USIs or 4 generic issues, 'how many of those are not focused on 5 prevention?
6 MR. SWINK: Not focused on prevention?
7 DR. SIESS: Yes.
8 MR. SWINK: Clearly they're focused on prevention.
9 DR. SIESS: I mean, off hand, I can't think of one; I 10 thought maybe somebody else could.
11 MR. SWINK: The only one I could point out would be 12 the TMI action items dealing with emergency preparedness.
13 DR. SIESS: Must be something to do with emergency 14 preparedness in there, yes.
15 MR. MICHELSON: In your thinking on topical areas, 16 how do you treat the topical subjects of external events like 17 fire, like blood, like tornado, and so forth.
18 These are items that will interact with all of your 19 other topical areas to varying degrees; yet many of themselves 20 require a topical solution.
21 Unfortunately, I think, in the case of fire 22 protection, maybe we didn't really look at ta topical solution, 23 but rather a solution to how you put fires out without looking, 24 necessarily, at the effect on systems.
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(,)\ I we're covered. So, in the future, if you divide it topically, 2 how do you treat these high-level topics?
3 System interaction's one of them, and external events 4 is another one -- and I can give you several more if you wish, 5 but you've got the idea, j 6 These go across the board. j j
7 DR. SIESS: See, actually, you're talking about i 8 interactions among the topics just like systems interactions. j 9 It's the same thing as that.
10 MR. MICHELSON: Yes. Right. That's it precisely.
11 MR. SWINK: For example, we're dealing with the plant 12 aging issue as a topic.
13 MR. MICHELSON: That, in a way, is a topic, too. It
()
4 14 can go across many. There's a number of these over the line 15 ones that are awfully tough to deal with, but I just wonder how 1 1
1 16 you planned on approaching it?
l 17 MR. SWINK: I don't know that we've really planned it !
18 yet. We've raised this in the discussions with research on how 19 do we go about improving this process.
20 And we've only had one meeting on the topic.
21 MR. MICHELSON: Well, you might add that to your list 22 of thinking then.
23- DR. SIESS: Well, certainly what they are proposing 24 could address one of our concerns about the departmentalization 25 that exists.
(O>
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L 167 h 1 M R .. SWINK: And-please understand, I'm not trying to 2 caveat this as being a finny -- everybody agrees. We've had 3 this one meeting, and it lasted for, I think it was 3 or 4 l 4 hours if I'm not mistaken.
l' 5 DR. SIESS: You know, you'll never come up with any 6 neat . set of arrangements. It's more an approach or a 7 philosophy.
8 You can never get these things organized into boxes,,
9 cross-cut any way you want. It just won't work. And as soon 10 as you do you'll end up with something else that's getting 11 ignored.
12 MR. MICHELSON: This is why people wonder whether to 13 divide by mechanical or by function.
14 >
DR. SIESS: But the idea of looking at things that 15 are related, on some basis of the relation, probably down to 16 what the ultimate objective is, whether it's to do things you 17 mentioned, or whether it's parts of the plant that are effected 18 or something like that.
19 It does make some sense. It's a way of letting you 20 handle problems that are manageable, maybe, with inner 21 discipline. And yet to keep an overview on getting an answer 22 to the real problem which may involve multiple disciplines.
23 MR. SWINK: I've coined it as systems approach.
24 MR. MICHELSON: Human factors is another .+ of these 25 overlying topics.
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V 1 MR. SWINK: Yes. l 2 MR. MICHELSON: It certainly interacts with most 3 every topic you'll probably dream up.
4 MR. SWINK: In fact, one of the things that I'm 5 setting up is review criteria for research items to come over, 6 is that as a minimum, technical people in terms of hardware 7 technical would look at a package.
8 The human factors people would look at a package to 9 see if it's humanly possible to operate and maintain. And 10 t Nrd, the risk people look at it in terms of what's this mean l
11 in risk space and in occupational exposure space? !
i 12 So that when you get a package back with review j 13 comments, it has considered the human factors element, the risk :
14 and occupational exposure element, and the technical element. !
i 15 DR. SIESS: Now I'm taking seven years to get one.
t l 16 MR. SWINK: Well, no. We're saying 3 weeks. Three 17 weeks for NRR review. That's what we put forth in the 18 Memorandum of Understanding between NRR and research in draft.
19 DR. SIESS: No. You could have it all in one place; 20 .it would still take time.
21 MR. SWINK: I understand.
22 DR. SIESS: As somebody pointed out, there are a lot 23 of people that have a legitimate reason to combat on it.
24 MR. SWINK: Yes. And these topics aren't easy. The !
l l 25 more I work with each of these topics, the more I realize that 1
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(]. 1 it's just not black and white.
2 And everybody has a wheel; that's the other thing.
3 Moving on to some other recommendations that we discussed is 4 early involvement in issue identification, prioritization, and 5 resolution by the licensing people and NRR, and the technical 6 people and NRR.
l 7 The purpose of that is, number one, to make sure l 8 we're not goin" on a wild goose chase. Two, to make sure that 9 we . focus on what's broke; the key elements of what's broke--
10 and try to keep it focused both in terms of what the resolution !
11 is and in terms of what the imposition is both generically and 12 plant specifIcally.
13 And ultimately and most importantly, what gets fixed 14 'in the plant? What piece of hardware goes to the plant to 15 correct the problem?
16 And we think that by getting the technical viewer 17 involved early rather than waiting for it to show up on his 10 doorstep for review, and also getting the PM involved -- the 19 lead Project Manager for the plant -- involved early, we will 20 get the right licensing considerations.
21 DR. SIESS: You say "the plant," but now these are 22 generic --
Ii MR. SWINK: Yes. I didn't mean to say the plant but
( 24 the lead Project Manager. We're assigning lead Project 25 Managers from the PMs for each plant --
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U 1 DR. SIESS: Oh, okay.
2 MR. SWINK: To be the lead guide for each rule, reg 3 guide,. generic issue, bulletin, letter --
4 DR. SIESS: And that person is simply supposed to S represent the. Project Manager's viewpoint?
6 MR. SWINK: The licensing side, that is correct.
7 That's so that when it comes to fruition as a resolution that 8 we don't. wind up in a situation where we said to do this thing 9 within a year, and most of the plants that are affected have 10 just finished an allege, and won't be down for an allege for 11 another 18 months or 24 months.
12 DR. SIESS: And wouldn't that suggest that you ought 13 to bring the licensees into the picture at some stage?
14 MR. SWINK: Well, they are involved to some extent.
15 In fact, the public is. The 0933 Publication, I think, is an 16 excellent vehicle for communicating what the agency's thinking 17 about; what they're doing early in terms of, here's an issue 18 that's been identified, prioritized, or is in resolution.
19 It also gives a reasonable description of the issue-I 20- - not enough that someone could take some technical action, but )
)
21 you certainly could call to the person that's identified and 22 ask him questions, and get more information about it. ,
1 23 DR. SIESS: Okay. Sam, make a note. That's a 24 question you'll ask the utility, if we every get one in here.
25 Read 0933.
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, 171 1 MR. MICHELSON: Have they got a copy of it?
2 MR. SWINK: I think that NUREG sent over to utility 3 routinely was published. )
i 4 MR. MICHELSON: I think it is. j 5 MR. FRAHN: Yes, but that doesn't mean that they're 6 .used. Do they read it? Yes.
7 DR. SIESS: They all don't have to read it; a couple 8 of good ones read it and come in with some comments. That's !
i 9 good enough.
10 MR. FRAHN: There's a chorally, I know. They are 11 always on our doorstep to find out where we are in the 12 resolution process for these issues, and request the updates 13 for gimmicks.
O 14 DR. SIESS: Okay.
15 MR. SWINK: And the key point is, I think everybody 16 gets served notice, not just the utilities. I think 17 interveners get served notice; I think if there's an interest 18 on the behalf of a specific person in the public domain, it's 19 available to them.
20 I thin?c there's good notice served that we're 21 thinking about this; here's what we think it is in very summary 22 form. And if you've got a question about it, here's the guy to 23 contact.
24 I think we do that well as far as 0933 is concerned.
25 The technical resolution now in station blackout is i
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172 0 1 en evo1 vie 9 exeme1e of thie. we re feceeius e 1ot of effort on 2 -- what do you expect the plants to do? When do you expect 3 them to do it? And by what means do you expect them to do it?
4 And what are the key factors that you're trying to 5 get them to focus on. If you're worried about water level, 6 stay focused in the generic issue resolution on water level.
7 Don't get so hung up in the technology for how you 8 look at water level that you forget what you're really 9 interested in is water level.
10 And then the other part of it is making sure it 11 physically gets done at the plant. Issuing a piece of paper 12 doesn't make the plant any safer.
13 So, we're focusing now on when did you physically do O 14 it? And what did you do?
15 And the last thing is our confidence in his ability 16 to do it; to make the modification. We have a whole bunch of 17 indicators of performance.
18 You can argue the validity; you can argue that 19 they're not a good indicator, but they're there. They're 20 pieces of information.
21 Salt is one. Inspection results is another. The 22 collective views at the management meetings about how well a 23 plant performs.
24 If a plant is weak on procedures, and you're putting 25 a requirement out that very heavily focuses on procedures, you O lleritage Reporting Corporation (202) 628-4888
173 1 may want to have a verification that it really did put the 2 procedure in place, and it really is a good procedure. >
3 We're focusing on that now. We're asking that 4 question up in the resolution process instead of waiting till a 5 plant does something and then leaving it up to the PM's G discretion of whether or not that plant did a good job, or-7 didn't do a good job; and leaving it up to the inspector's i 8 discretion of whether or not to go check it. !
9 We're trying to make those decisions up front. So, 10 we're focused very, very heavily now on the imposition both 11 generically and plant specifically, and the actual 12 implementation, and whether or not to mako an initial 13 verification.
14 And then the last thing that we're focused on is, we 15 put a lot of emphasis on sometning -- on the front in; a lot of 16 FTs; a lot of dollars; a lot of technical peer review.
17 Hopefully, we're going to be focused more heavily now 18 in the future on this implementation part. The question is, 19 what about five years down the pike?
20 Do you care enough about this thing? Do you think 21 it's important enough that you want to have a specific 22 inspection as part of the routine inspection program that looks 23 at that item year, after year, after year to make sure that 24 it's still there, and it still operates the way we think it 25 should, and it's still maintaining the way we think it should O lieritage Reporting Corporation j (202) 628-4888 '
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2 We're asking those questions now, up front.
3' DR. SIESS: You could ask those questions about f 4 things that are already in the plant, couldn't you?
5 MR. SWINK: Yes. We've got an effort going on right 6 now in NRR to validate, in essence, all of the previous generic 7 issue resolution implementations at the plant.
8 . DR . SIESS: I know. But generic issue resolutions in 9 Texas, where something went wrong, I found out later -- there 10 are a lot of things designed in the plant, you know, that got 11 fixed before they happened.
12 MR. SWINK: Yes.
_ 13 DR. SIESS: Now do you inspect those every five years
\# 14 to see that they're still there?
15 MR. SWINK: We have an inspection program --
16 DR. SIESS: I wouldn't raise an example like the 17- scram system, but you know.
18 MR. SWINK: We have an inspection program that is, by 19 its nature, an audit program; we cannot inspect every single 20 thing in the plant.
21 DR. SIESS: I mean, I'm trying to figure out what's 22 so different about something that's added in there because of a 23 generic issue. l 24 MR. SWINK: Okay. Our instruction program right now 25 is topical, and it is an audit program which means that a Heritage Reporting Corporation (202) 628-4888
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.g V 1 specific pump may not be looked at but that topical area--
2 that system that that pump is in may be looked at.
3 And that audit of that topical area may involve i
4 looking to see if he has a program to maintain it. If we :
5 identify something that we think is critically important -- we 6 think station blackout is a very, very important safety issue.
7 And let's say that diesel generators are something 8 that we think is the key to station blackout. Then it may be 9 important enough that we want to have part of the routine 10 ~ inspection program, part of the audit of that topical area, a 11 specific action that calls for -- go witness a diesel generator 12 reliability test because we think it's that important.
13 Whereas if you just left the routine inspection
- i. 14 program alone, it may only look to see if he has a procedure to l
l 15 go check the reliability of the diesel generator.
L 16 DR. SIESS: I understand that now in the context of a l
17 broad issue like station blackout. I didn't understand it in 18 the context of some narrow issue that says go in and fix this 19 valve.
20 Put in a first aux feedwater pump, and tell the 21 inspectors to go count the pumps every week.
22 MR. SWINK: No. Our whole inspection program's 23 moving more toward the equipment and less toward paper. It's 24 typically been focused on, does he have a program; does he have 1
1 25 a procedure?
f L.-)
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176 1 Now the' inspection program's moving more toward -- is 2 the pump there; does it work?
3 DR. SIESS: I assume that's partly because they found -l 4 out that looking at the paper didn't prove anything. l l
5 MR. SWINK: That's correct.
6 DR. SIESS: But they're still going to require all of 7 the paper to be there. l 8 MR. SWINK: The paper _would have to be there because 9 that's the only institutional way that you have to assure that 10 there's some program that institutionally is there to cause 11 things to happen.
12 But the test of the paper is, can you physically go g 13 there and see the pump, and is the pump working?
(J 14 DR. SIESS: You have a program to ensure that the l
15 paper's there, but looking at the paper's not going to help you 16 any, so you got to go out and look at the equipment. But still 17 you want the program to have the paper there.
10 It's an interesting line of reasoning.
19 MR. SWINK: Well, to me the test of the program that l \
l 20- they have in place is, is it working? And the only way to test 21 that is --
22 DR. SIESS: The test of the program ought to be 23 whether the plant is in good shape, and not whether they have l 24 the paper there.
25 MR. SWINK: That's correct.
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I V 1 DR. SIESS:. But there's been so much emphasis on ,
l 2 having the paper there that people have been more concerned {
3 about having the paper there than having the plant working 4 right.
5 MR. SWIf1K: But that emphasis is shifting. The new 6 management NRR is focusing on, is the plant working?
7 DR. SIESS: tiot to reduce the paper?
8 MR. SWINK: Well, I shouldn't say that. We've had a 9 tremendous paper reduction effort over the past five years. In 10 fact, we had a congressional citation for that, I think.
11 The next Item is the improved tracking and record 12 keeping: cradle to grave. The previous briefing 1 talked about 13 Simms. It's the tracking part of the thing I think is in 14 place; now it's a question of its validity.
15 And we have an effort to validate what's in the data 16 base. And then too, using that as a management tool which is 17 being done to some extent, and will be done once it's verified 18 as reasonably accurate, to hold the PM accountable for what's 19 been done at the plant and what hasn't been done at the plant, 20 and to a different topic, hold the management in each 21 organization, be it research or IJRR to the resolution of issues 22 -- of when we say things will be resolved.
23 The record keeping part of the thing is another issue 24 that's molding to the surface based on our experience with 25 having the PMs validate which is Simms.
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[') 1 Part of - the problem is , does the licensee have a sf 2 legal requirement requiring him to make a modification. And in 3 some cases we're'having trouble finding that out.
4 And the 'llcensee doesn't recall it. And the PM, for 5 whatever reason, doesn't recell it --
maybe because he 's the-6 new PM on the plant with the reorganization. Or he just can't 7 recall it.
8_ We need to better conso3idate and organize our record 9 keeping systen so there is one authoritative flie.
10 DR. SIESS: Doesn't that go into Simms?
11 MR. SWINK: It is in Simms now, but we're trying to 12 validate it.
13 DR. SIESS: Oh, you're trying to check back on --
D d 14 MR. SWINK: That's correct.
15 DR. SIESS: You mean, there are actually some plants 16 that, as far as NRC was concerned, they should have done 17 something but they were never told they should have done it?
10 MR. SWINK: That's correct.
19 DR. SIESS: Other than four cent raise?
20 MR, SWINK: That's correct. Understand that the way 21 we -- 'l I
22- DR. SIESS: It's a year after TMI got the questions, 23 or something.
24 MR. SWINK: Understand that the way we do things, we 25 issue a generic imposition that says, submit a proposal to your O Heritage Reporting Corporation (202) 628-4888 1
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a a 179 1 PM w.'ithin 90 days , and then negotiate a schedule for what will 2 be done, and when it will be done.
3 If that plant submits something, as far as he's 4 concerned, he's met the generic requirement. Until NRC goes 5 back and tells him, we agree with your proposal and we agree '
6 with your schedule, he is not committed to do anything.
7 That's the way we do business. So, unless there is 8 something that goes back that says, we agree with your 9 proposal, and we agree with that schedule, you should not 10 expect anything to change in the plant, as far as a regulatory 11 requirement causing it to change.
12 DR. SIESS: That's just a matter of following up 13 what 's going on in your own shop. i 14 MR. SWINK: That is correct. But the tracking 15 system, the Simms, will do that, What I'm also suggesting, and 16 what we're trying to improve is our records to show, here is j 17 the letter that imposed that specific requirement on you 18 licensee.
19 The SER is a tt ac hed _. Here's the schedule; that's 20 attached. Here's the letter. You are committed. We're also 21 thinking about a generic rule-making that would require the 22 licensee to come back and tell NRC under oath that he has 23 physically installed that piece of equipment or that.
24 modification procedure, or whatever it called for.
25 And that completion would be the trigger to have, if O
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]
I 3- We're having great dif ficulty in terms of records of 4 articulating what was done; what was approved; and what the 5 specific licensee was asked to do.
6 MR. MICHELSON: Isn't that problem extending back 7 into the FSAR?
8 MR. SWINK: Yes.
9 MR. MICHELSON: Unless you read it you don't really 10 know all the promises that are in there.
11 MR. SWINK: Yes.
12 MR. MICl!ELSON: The licensee doesn't even know all 13 tne promises he made.
14 DR. SIESS: Some of them are putting that on the 15 computer now so they can track that. .
16 MR. MICHELSON: Is Simms going to computerize FSAR 17 entries?
10 MR. SWINK: It won't computerize the entry; it'll 19 articulate that there was a modification.
20 MR. MICHELSON: But if it says in the FSAR you're 21 going to design something to -- >
22 DR. SIESS: No, no. Simms is only trackJng generic-l' 23 -
I 24 MR. SWINK: That's correct.
25 DR. SIESS: -- and plant specific issues.
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MR. MICHELSON: Okay. That's right.
2 MR. .SWINK: But typically, we send an SER out to 3 identify that we agree with a licensee's proposed modification 4 in. response to a generic --
5 MR. MICHELSON: This is a side piece of information, 6- though. Is there any effort underway to try to computerize the 7 regulatory promises made in the FSAR, and other licensee pay 8 documents?
9 DR. SIESS: I think some utilities were doing it.
10 MR. SWINK: Yes, Phil Mcdonald's got a project 11 underway to try to do that. It's not as clean as going into 12 every FSAR and articulating every commitment.
13 At this point it's just, let's get the FSAR on some l
N -
14 automated means and decide on a format.
I 15 DR. SIESS: It ought to be the licensee's l
16 responsibility to do that.
l l
l- 17 MR. MICHELSON: That would be for future FSARs.
18 DR. SIESS: You can't monitor 120 plants that way.
19 MR. MICHELSON: But ior present day FSARs, then you 20 really don't intend to go back and try to perform some kind of 21 a data logging of the regulatory process and so forth.
22 MR. SWINK: Not at this time.
l 23 MR. MICl!ELSON: Thank you.
24 MR. SWINK: But understand that one of the reasons we 25 want to have these key points articulated in the resolution l
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182 l 1 process so the< it's very clear to the licensee, and to the PM, 2 and to the Technical Reviewer, and the Inspector what it is 3 that we're trying to focus on -- what we're trying to fix, so 4 that it.will be very easy to focus on those things at the tjne 5- of licensing; at the time of inspection; at the time of 6 technical review of the licensee's proposals.
7 The other thing that we have underway is improving 8 the generic issue procedures. We're trying to articulate how 9 the agency will deal with generic issues, rather than haver an 10 office articulation of how to deal with generic issues.
11 There would be some kind of document that says, 12 "llere's how HRC deals with the generic issues." That doesn't 13 mean that there won't be office procedures that articulates 14 specific organizations. You could still have that.
15 But there should be some very, very --
' 16 DR. SIESS: Is this just an administrative type 17 thing?
18 MR. SWINK: Well, I don't want to say it's purely 19 administrative because --
20 DR. SIESS: You talk about the agency -- to me, the 21 parts of the agency, I think, that have much significant effect 22 on safety would be NRR, and perhaps research.
23 But you talk about the agency now. I'm looking at 24 legal people, and all of the others. And I don't know what l l
25 wrong with an office position compared to an agency position. j
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/~n U 1 MR. SWINK: I'm thinking a little bigger than that.
2 For example, a question of the waste program affecting.
3 reactors. There are deals being cut with the states that if we 4 will change the red specks and reactors, they'll accept the 5 form and classification coming out of the end of the affluent 6 process without them having to follow the form and 7 classification reg guides on waste.
.8 So, there are impacts in other than research and NRR.
9 DR. SIESS: Yes, but does this require a policy? I 10 MR. SWINK: Well, I think it does. If the agency's 11 going to adopt that, from the state's point of view that had 12 the waste disposal facilities, then I think that ought to be a 13 clearly articulated policy.
O 14 And to an extent it's a back fail cause you're going 15 to go ask the reactors to change their tech space.
16 DR. SIESS: Yes. I can't get that tied up with 17 safety right now very much.
18 MR. SWINK: The idea being that we have an improved 19 set of generic issue procedures, and this is the context that 20 we had the meeting with research to talk about improving the 21 process, because we want to come out with a set of procedures 22 that institutionally cause things to happen because l 23 historically, we seem to keep shifting people around. j l
l 24 And if you shift people, you have a person who has '
25 worked in a tunnel vision environment in a particular piece, 1
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l 104 1 and all of a sudden he's in a different piece, and he doesn't 2 know what to do; he's floundering.
3 The procedures vould give you the -institutional l- 4 memory that would cause a person to be able to understand that 5 I'm now in this position, and I now have to interface with 6 these people on a regular basis.
7 We think that if we can improve those procedures, 8 cause things to happen institutionally, and not be so dependent 9 upon the initiative of individuals.
10 DR. SIESS: Well, that's an interesting thought, but 11 'I don't think.you're gring to accomplish much in this agency to l 12 really increase safety without depending upon the initiative.
13 The intelligence, the integrity, and the experience 14 and the knowledge of individuals -- you aren't going to replace l 15 that bv procedures.
16 MR. SWINK: Yes, but my experience has been that we
[ 17 have --
l l 18 DR, SIESS: Where you sit, you know, you're managing.
19 MR. SWIHK: We have very, very competent people, and 20 we articulate generic issues. And they put a lot of etfort, a 21 lot of dollars, and a lot of the right kind of people in it.
l- 22 Trouble is, sometimes we do it in tunnel . vision 23 environment. There's an institutional need --
24 DR. SIESS: No, that's a management problem.
25 MR. SWINK: That's right, but there's an O
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185 1 institutional need to deal with that issue. And I think the 2 first step in doing that is having an institutional corporate
.3 memory, called procedures, that force that interaction so that i 4 it's not a tunnel vision environment.
5 Because you have both performers that meet the 6 requirements of their job, and you have outstanding performers.
7 And that's the real world we live in.
8 And to the extent that you have a --
9 DR. SIESS: And the institutional corporate memory l 10 isn't going to be able to tell one from the other. And you ask 11 me, it damn well better know how.
12 1 think you're getting the coordination too far up in n 13 'the atmosphere there. But that's beside the point.
14 MR. SWINK: That was my address of that first 15 question, do you think the overall process is effective, and i 16 what should be done to improve it?
1 17 This is what we discussed with research; I don't know 18 what the outcome of those discussions are going to be. We had 19 the first meeting for four hours. I thought it was a pretty 20 good meeting.
I 21 DR. SIESS: You haven't really answered whether you
]
22 think it's effective.
1
! 23 MR. SWINK: In general, I think the process is 24 effective. 1 1
'25 DR. SIESS: What's your measure of effectiveness? l l
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( 186 1 MR. SWINK: We identify a topic; we reasonably l 2 . articulate what that topic -- what's broke that needs to be l 3 fixed.
4 We have a reasonable process that looks at it in 5 terms of safety and says its worth pursuing or it isn't worth 6 pursuing; we have a reasonable process for peer review of both 7 -that identification and that prioritization early 'in the 8 process.
1 9 We have a resolution process that puts a lot of 1
10 dollars in FTE, and a dedicated Task Manager on dealing with l 11 that topic to resolve it.
12 That resolution is subject co peer review. That peer 13 review focuses principally on safety, although I would argue
('\,
(> 14 that the peer review is somewhat tunnel visioned in the same' 15 way that the resolution is tunnel visioned because it only gets
-16 that topic --
17 DR. SIESS: Are you describing the process or are you 18 answering my question?
19 MR. SWINK: I'm answering each part of the process on 20 why I conclude that generally the process is effective.
21 DR. SIESS: But I still don't understand what your 22 measure of effectiveness is.
23 MR. SWINK: I think that we have a --
24 DR. SIESS: vo you think the process has improved
! 25 safety?
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-[] 1 MR.'SWINK: Yes.
)
2 DR. SIESS: You think it's improved safety in a cost L l 3 beneficial manner? j 4 MR. SWINK: Cost beneficial? !
5 DR. SIESS: Yes. I mean, anything can improve ;
6 safety. I can think of lots of things that improve safety.
7 MR. SWINK: No.
8 DR. SIESS: I could shut down all the plants.
9 MR. SWINK: I think we could have maybe gotten more l
10 safety for the buck if we wouldn't be tunnel visioned by doing
- 11. things piece meal, i 12 DR. SIESS: But now that would've meant saving up 13 some of the items and doing them all at once. And if doing 14 them improves safety, was safety less during that period of 15 saving them up and waiting?
16 MR. SWINK: I'm thinking in terms of, like for 17 security we put up keys, doors, locks, and barriers. And for 18 operational safety, we want to have free access to all the 19 areas.
20 I don't think we've balanced that well.
21 DR. SIESS: A lot of people pointed that out a long 22 time ago.
l 23 MR. SWINK: But the reason is it's pursued in a l
24 piecemeal fashion. The Safeguards people want the very best l
l 25 safeguard system for their plants.
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188 1 The operational people -- the human factors people--
2 want the very most access by operators and maintainers. And 3 the occupational exposure people wan to have things spread out 4 so that the guy doesn't have to lay across pipes to get to a 5 pump to put a now seal in the pump.
6 I don't think we've calanced that because we've done 7 it piecemeal. Now, how bad have we done that? I don't think 8 we've done it too bad.
9 But the answer is, I think net safety at plants has 10 improved. And I base that on discussions with utility people 11 at meetings I've had.
12 I base it on what I see in the plants on trips where 13 I've been to the plants. I base it on participating in 9 14 meetings like this one -- that peer review; generic issues--
15 and recognizing how well that got peer reviewed.
16 DR. SIESS: Go back to effectiveness. If we maintain 17 a backlog of 20 or 30 issues to be prioritized; another 20 or 18 30 to be resolved -- is this effective, or should we do 19 something to keep a backlog to zero? Do we have a way of 20 processing a generic issue as soon as it comes in.
21 MR. SWINK: I'm going to give you an opinion; it may 22 not be popular. I don't think this agency's ready to say how 23 safe is safe enough. I don't think this agency's ready to come 24 out with a safety book yet.
25 DR. SIESS: You already said it; so, that's beside O
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[s 1 the point. We got five of them. Just in terms of the 2- operation process of handling generic issues, would it be more i
3 effective if we didn't have a backlog?
4- In other words, will safety be improv.4c , assuming 5 that safety is a measure of effectiveness? Or should we be-6 content to go,along with a backlog that, you know, might go up 7 and down if we get 20 new GIs out of AIT.
8 MR. SWINK: Let me answer it this way. I think 9 you're always going to have generic issues, and I think you 10 should because --
11 DR. SIESS: But shouldn't we have a backlog? f 12 MR. SWINK: --
because, if something happens -- an 13 event happens; a phenomena happens --
14 DR. GIESS: Yes, but the question is how fast should 15 we process on it? Should we speed up the process? You're 16 talking about improving it?
17 MR. SWINK: Yes. One of the recommendations we made 18 was that any generic issue that's identified is resolved within 19 two years.
20 DR. SIESS: Resolved within two years?
+
21 MR. SWINK: Resolved within two years.
22 DR. SIESS: That's never happened yet.
23 MR. SWINK: I understand that. But we're talking 24 about improving, and that was one of our recommendations, that 25 that be paid --
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l 190 1 DR. SIESS: Oh, you're going to have to quit sending 2 them out-to Sandia; places like that.
3 MR. SWINK: I understand, but what we were
- 4. recommending is that from the time you identify a generic 5 issue, that is a medium or a high. till the time that you come 6 up with a resolution should be no more than two years.
7 DR. SIESS: Now, what about --
8 MR. SWINK: Let me go a little further. If you have 9 to pursue rule-making to cause something to happen, we've 10 already put a standard of two years on rule-making.
l 11 If you allow a plant two alleges to put it in, you're.
12- ' talking six ' years from the time that you identified a safety
.13 concern till the time that the last plant makes the 14 modification.;
15 I would argue that if you get much longer than that, 16 you can't be too big a safety concern.
17 DR. SIESS: I know. But the thing is, maybe the 10 place to take that time out is out of the rule-making, and not 19 out of the technical resolution'.
20 MR. SWINK: We did that. We cut the rule-making time 21 from five years to two years.
22 DR. SIESS: I'm looking at a technical concern that I 23 want a proper technical fix, and not one that makes it worse.
24 I want to be sure that there's enough technical effort placed 25 on it.
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1 And I'd hate to see it limited to two years simply 2 because it's taking two years to do a damn rule.
3 MR. SWINK: I'm not arguing with your philosophy; 4 what I'm suggesting to you is, we've been through the rule-5 making process --
6 DR. SIESS: I agree that six years is a long time.
7 And if I've got 120 plants out there, I'm getting 720 reactor l 8 years while I'm waiting for that issue. i 9 Of course, if it was a really serious one, you can ,
i 10 probably do something about it before that. But you may not ]
i 11 know. )
12 MR. SWINK: That's exactly right. But we're talking 13 about improvements; that's what we're recommending, is that two l l
14 year process. q l
15 Now the rule-making part, I've gotten opinions from !
16 the legal people that say you can do a rule within a year.
17 I've gotten opinions from technical people that say you can get 18 a rule-making done in any less than five years.
19 There is an ideo-directive that says you shall get it 20 done in two years.
21 DR. SIESS: Yes. We can get it done in a year -- we 22 never have --
23 MR. SWINK: I understand. !
l 24 DR. SIESS: -- but that doesn't mean anything to a i 25 lawyer; he's not empirical at all.
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(): 1 MR. SWINK: 'Well, we're talking about improvements.
2 If we accept what has been done as the standard then we 3 shouldn't be talking improvements.
4 We've had these discussions with research; they 5 certainly have been receptive to what we recommended. I don't-6 know how it's going to come out as a final entity.
7 DR. SIESS: It's not a bad objective. Got any 8 comments on this, Tom?
9 MR. KING: Well, I'll say one; it may get me in 10 trouble but I'll say it anyway as a first opinion. We're here 11 talking about how to improve the process today, and you look 12 around, you see --
13 T MR. MICHELSON: Could you use the microphone so ve i
14 can get these words recorded for posterity?
15 MR. KING: We're here talking z. bout how to improve 16 the process,and you look around and you see the people you're 17 talking to --
we have some Task Managers here; we have some 10 Section Leaders here; we have some Branch Chiefs here.
19 The only people that are really going to improve the 20 process are the people at the top. The take a management 21 position.
22 This is important wor.'; we need to integrate it.
23 We're going to set schedules; we're going to meet and we're 24 going to get the right resources. Then the schedule's going to 25 improve; the process is going to improve.
t O
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193 1 We're struggling to, what I call, run this show from 2 the bottom. I think we need some struggles from the top to 3 help run it from the top.
i 4 I'll leaf it at that.
5 DR. SIESS: That's a good point.
6 MR. KING: It may be the end of my career here, but 7 that's my observation.
8 DR. SIESS: If this committee should decide that it 9 really needed improving, and it took more resources to do it, 10 we would make such a recommendation to the Commission.
11 Don't know whether they'd do anything about it. But 12 unless the Commission or the EDO decides that this whole thing 13 needs to be speeded up, it's going to be rough, but it's going 14 to get done.
15 MR. MICllELSON: On the other side of the coin, are 16 there any advantages to moving that less than most rapid pace?
17 In other words, is there fermentation time as an important 18 factor, or should you just rush into these and get them out as 19 quickly as possible?
20 Would do it on paper, but it sometimes is in too much 21 haste. On the other hand, dragging it out forever, meditating 22 over it is not necessarily good policy.
23 There's got to be some kind of an optimum in here. I 24 don't know what it is. I kind of suspect five years is not an 25 optimum.
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1 On the other hand, six months, I think, would be
- ]
2 dangerously fast.
3 DR. SIESS: Right.
4 MR. SWINK: Let me comment on that. I had an 5 opportunity in response to Commissioner Asselseine's comment 6 about the CRGR having a chilling effect, to looking at what was 7 submitted and what wound up as the final rule that the 8 Commission put out.
9 There was very little change. So, I would argue that 10 the fermentation that you're talking about probably takes place 11 in the very early stages -- the first one or two years of the 12 resolution.
13 Beyond that, I call it tinkering.
(3
\,J 14 MR. MICHELSON: I think if you start talking two 15 years you might be getting close to this optimum, whatever it 16 is. Clearly, there's got to be some time to let things settle 17 down, and make sure that all the information has come out of 18 the woodwork and whatever.
19 But five years sounds -- just intuitively seems a 20 very long time. Maybe two years is --
I think that's kind of i
21 what you're proposing, isn't it? A two year target.
22 That, at least intuitively it doesn't sound too bad. !
l 23 MR. KING: There has to be a balance in there. We're 24 trying to look at where is it getting excessive in terms of 25 just dragging out at the staff level, and trying to --
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{} 1 MR. MICllELSOll: Well, you just have to tell the 2 commissioner that they're sitting on-one of these for three, 3 four months. And don't let them change it.
4 MR. SWINK: how about safety related -- important to 5 safety? It's been down there for two and a half years.
6 MR. MICHELSON: Well, that one's a different issue.
7 DR. SIESS: It's words.
8 MR. MICHELSON: Yes. Well, there's concepts involved i
9 there that get into many areas. But right now, they're '
10 treating it as words.
11 But there's some real interesting concepts in there.
12 DR. SIESS: Oh, yes.
13 MR. MICHELSON: But, yes, two years might --
I would ti L 14 say 30 month --
two and a half years, something like that, is 15 probably a reasonable target.
16 DR. SIESS: I suspect that if you could reach the 17 technical resolution over night, the process would use up 18 several months.
19 MR. MICHELSON: Oh, I think it could take a year to 20 get it out. Some of these are not very complicated. And they 21 also take long times.
22 MR. SWINK: As I say, you mentioned the process -- if 23 it takes two years for the resolution; two years for the rule-1 24 making; and you allow two alleges for the plant to make the 25 modification, that's three years, roughly.
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() -1 You're talking about three, two -- seven years. So , .
2 'the best you could hope for is five, the worst would be seven.
3 MR. MICHELSON: Everything doesn't require rule-4 making.
5 MR. SWINK: No. I understand that. But I 6 personally have a problem saying on the one hand that something 7 is a very, very important safety issue, and on the other hand 8 saying, it's okay to wait seven years.
9 MR. MICHELSON: Well, if it's sufficiently important, 10 you don't wait at all; you have other means of taking care of 11- those. These are the ones that are not that important.
12 MR. FRAHN: And that should be stated too in the p- 13 identification process when an issue comes in. We do make an -
V 14 immediate action determination. And if it's really a safety 15 concern, then plants get shut down if that's the problem.
16 MR. SWINK: Well, station blackout's a concern, but 17 we haven't shut a plant down for it.
18 DR. SIESS: Sure station blackout's a concern, but we 19 recognized that one 40 years ago and put two diesels in the 20 plant, you know, of maybe one to start with; and then two.
21 And now we're down in fine-tuning it. At what level 22 have we got probability? We've always had a probability. Now 23 we'll see about what level it is.
24 And a lot of things that come in, you don't know how 25 important they are until you've spent a year on the darn l0 l Heritage Reporting Corporation (202) 628-4888 l
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197 l 7-V 1 things.
2 I think the PTS was an example of that.
3 MR. SWINK: I'm glad you didn't ask me that question 4 about how we improve safety in absolute terms versus relevant 5 terms. One could ask whether we're getting down into the noise 6 area.
7 DR. SIESS: I'm convinced we've done some things that 8 probably didn't improve safety at all.
9 MR. SWINK: We said that in the ISOP paper. We said 10 by requiring certain things we made it less safe.
11 DR. SIESS: And I'm all in favor of an ISOP approaJh 12 because I think a lot of the fixes would be better --
j3 13 MR. SWINK: Integrated.
V 14 DR. SIESS: --
integrated. Some of them could be 15 omitted.
16 MR. SWINK: Consolidated.
17 DR. SIESS: People think twice before they went out 18 and hung another pipe. It's something else. We don't seem to 19 be going that way.
20 MR. KING: I just wanted to mention one other thing.
I 21 Walter mentioned we had the meeting about recommending what's l 22 in tho process.
23 On October 21st, there's a meeting ocheduled with the 24 Commission to talk about the whole generic issue process. One 25 of the things we're going to try and do between now and then la Q
(>
lieritage Reporting Corporation (202) 628-4888
198 1 work with research; come up with some recommendations that we iCO 2 would.be willing to give to EEO and the Commission as to how it 3 can be improved.
4 So, in terms of scheduling, that's the due term 5 milestone we're shooting for, is that October 21st Commission 6 meeting.
7 DR. SIESS: We were never quite sure how serious'they 8 were when they included this on the list of things that they i
9 wanted us to do.
10 MR. KING: What the outcome will be, I don't know.
11 MR. SWINK: Tom, I think I fairly characterized what 12 we said at the meeting.
13 DR. SIESS: Be interesting to know whether they tell 14 you that they asked the ACRS to Jook for this or not. They 15 probably forgot.
'16 MR. SWINK: The next item on the agenda I think I've 17 somewhat addressed in addressing the first one. And that is, 18 the interaction with licensees in establishing schedules for 19 implementation, and reviewing the licensees proposal, and how 20 effective that process is.
21 Again, I would say, generally, it's pretty good. But 22 specifically, the things that I mentioned before about having 23 the key items identified that we want to focus on would improve 24 the process.
25 And then the other thing is fcecusing the whole o Heritage Reporting Corporation ]
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1 impocition -side and implementation side o,n the licensee
-2 physically implementing it at the plant, rather than a piece of 3 paper going out, asking him to do something.
4 The emphasis is changing within NRR both in the 5 licensing end and in the inspection end on physically changing 6 the plant, rather than --
7 DR. SIESS: Assuming that a physical fix is the fix.
8 MR. SWINK: Yes. Well, when I say a physical fix, I 9 mean you're going to change procedures, equipment or staffing.
10 DR. SIESS: That's so obvious I wonder how we got 11 into any other approach.
12 MR. MICHELSON: Well, I have one question in this
. 13 '. area and that is, many times it appears to me from the 14 resolution that the implementation is still fairly judgmental.
15 So, you've got over a hundred units out here. And 16 you've got to make the judgement on each. So, you've got to 17 get the Project Manager at this point? Is he the one that's 18 doing it?
19 MR. SWINK: No. You have two people.
20 DR. SIESS: We covered this. Vaun said he'il cover 21 it if we ever get to him. But we covered this in our 22 discussion with the Project Managers.
23 L1censeo makes a submittal of what he plans to do; l 24 the Project Manager sends that over to the Reviewers.
I 25 MR. MICHELSON: So, the Project Manager doesn't mai.e O
Heritage Reporting Corporation (202) 628-4888 L
200 h 1 the judgement then?
2 DR. SIESS: Oh, no, no.
3 MR. MICHELSON: So, the Reviewer is who now?
4 DR. SIESS: Technical Reviewers -- same people that 5 review the FSAR.
1 6 MR. MICHELSON: I'm trying to correlate this with 7 this earlier discussion about topic areas and so forth.
l 8 DR. SIESS: Oh, no. The Reviewers are NRR technical 9 reviewers. Technical branch people. I 10 MR. MICHELSON: Okay. Now how do they decide -- they 11 lave to make a judgement as to whatever is being proposed meets 12 the intent of the resolution.
13 DR. SIESS: Just like they do on an FSAR.
9 14 MR. MICHELSON: Now I guess the uniformity of 15 decision making is taken care of by the fact that it's the same 16 Reviewer passing on all the hundred plants?
17 DR. SIESS: Not necessarily, but it's probably about 18 as uniform an you get, anyway.
19 MR. MICHELSON: Well, I mean it's the same office--
20 the same branch or something at least, isn't it.?
21 MR. SWINK: In our recommendations to research, we 22 also asked that the research Task Leader, even though there's 23 been a resolution would be hung with that issue until the last 24 plant made the modification, so that he would be available to 25 control with the reviewer on that last plan, and also that PM.
O '
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v 1 MR. MICHELSON: Now, as a final closure on this 2 question, is there ever a process by wh!.ch somebody kind of 3 overviews how the resolutions are being implemented to see that 4 it met the intent of the resolution?
5 You've turned us over now to some technical person.
6 And he's' interpreting the resolution; and he's saying, "This is 7 okay," to each utility.
O Is there anybody ever go back to see if his decisions 9 are really matching the intent of the resolution? And that 10 ought to be somebody that made the resolution; ought to be the 11 one that goes back and does this overviewing -- which would be, 12 I guess, research.
.. 13 Do you recall anything?
(
14 DR. SIESS: To what extent -- wel:1, of course the 15 people'that did the resolution might well have included that 16 person. We have no assurance on it.
17 MR. MICHELSON: I'm being a little more hypothetical 10 I guess, but how are we assured that what's finally accepted 19 meets the intent of the resolution?
20 MR. SWINK: There's really tlkree components to it.
21 One is that the resolution would involve both the research 22 person who's involved in it; it would involve the lead reviewer 23 -- the lead technical review in NRR; and the lead project 24 manager.
25 MR. MICllELSON: Excuse me, the research person is the O
lieritage Reporting Corporation (202) 628-4808
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.' 1 one who worked on the resolution of that issue?
2 MR. FRAHN: That's the way it is now, Carl. Before 3 we were all in NRR. So, maybe your concern --
4 MR. MICHELSON: It would have been a little less than l 5 I think.
6 MR. FRAHN: -- it's a little less. Now, I think Walt 7 said that he would like, since we are splitting two different 8 offices now, to keep the Task Manager that is resolving the 9 issue in research involved during the implementation stage, 10 just to --
11 MR. MICHELSON: Just to track.
12 MR. FRAHN: -- just to track to make sure --
13 DR. SIESS: How involved at the implementation stage?-
14 The' order goes out, the licensee comes back and says, "Here's 15 what I plan to do," in as much detail as he can; he hasn't doe 16 it -- he might have gone ahead and designed it.
17 That's what the Project Manager saw. Some of them 18 design it and install it, and then say, "Look, I did it. Come 19 check me."
20 Others come back and say, "No. Here's what I plan to 21 do." Now that goes to the Project Manager for plant number 100 22 out of 100 plants.
l 23 He or she passes it on to a Reviewer. When does this 24 original group get involved?
25 MR. SWINK: Okay. My envision of the way it would l
Ileritage Reportir.g Corporation (202) 628-4888 u-____ -
203 1 work would be this lead research guy; he would participate in 2 the first plant review with the Technical Reviewer and the PM.
3 DR. SIESS: With the Technical Reviewer and the PM.
4 MR. SWINK: And for the last plant, he would also 5 participate in that one. And he would participate at least in 6 one inspection to see if it physically came out the way that 7 they thought.
8 DR. SIESS: How Ron says the same Technical Reviewer 9 would do all of these. But if it's something that covers a 10 hundred plants --
11 MR. SWINK: That's why I used the word " lead to - "
12 MR. HERNON: Walt's talking about future; I was 13 talking about present and past.
14 MR. MICHELSON: I'm kind of interested in present, 15 too.
16 MR. HERNON: I'm talking about all type of plant 17 actions.
18 DR. SIESS: Yes. Talking about generic issues.
19 MR. HERNON: Yes. One lead PM, and one lead Reviewer 20 --
21 DR. SIESS: On generic issues.
22 MR. HERHON: And one Branch Chief -- per issue. Yes.
23 DR. SIESS: On generic issues.
24 MR. HERNON: Yes, sir.
25 DR. SIESS: And if that branch, one branch has a lead
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' ~4 ': DR. SIESS: That Reviewer?-
'S MR. IIERNON: Yes. Or his Branch Chief.
c, s 6 DR. SIESS: Every Project. Manager for every plant
=7 takes it to~that Reviewer?
8: MR. HERNON: Yes. Or'that BA.
9 DR. SIESS: That Reviewer doesn't become a bottle 10 neck?
, 'll MR. SWINK: Yes.
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.a' 12 .- MR. IIERNON: Sometimes, yes.
13 DR. SIESS: Now, with the present system, for a whi.le rx D 14.' . wo organized by something. Now we organize by regions -- two 15 groups, isn't 'it?
< 16 MR. HERNON: Two divisions. ;
17' DR.. SIESS: Two divisions. Is there a lead Reviewer
'18 out of each' division? !
19 MR. SWINK: No. ;
20 MR..HERNON: The lead Reviewers are in the technical
]
21 ' side, not the project side. 4 22 DR. SIESS: Each division's got it's own technical--
23 no, there's a separate technical division? ]
I 24 MR ' IIERNON:
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5 DR. SIESS: That's right. Now, you're back to--
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there's just one set of technical reviewers for all of NRR.
% 7 MR. HERNON: Okay. Yes, I see what you're saying.
'DR.'SIESS:
'8- Okay.
h 9 MR. HERNON: With the interim NRR organization, 10 things were going in every which direction.
11 DR. SIESS: Okay, so we're back to the one set. Now, l
- 12 .I'd. forgotten that. I knew we were, but I thought we were back
- n. 1 13- 'to one for each division; we start a whole separate division z'- ).- -
14 with --
- 15 MR. .HERNON: Tadoni has a large number of --
' 16 -MR. MICHELSON: Now that they have researched back
- 17 <;doing the generic items, and having the lead responsibility for
- 18. them, is there presently an established means of getting their 191 . people involved.In your review of these fixes?
20 MR. SWINK: You're saying presently?
- 21. MR. MICHELSON: Yes.
'22 MR. IIERNON: From April to -- September?
- 23. MR. MICHELSON: Okay, right now -- but this is going 24 to be very soon -- is that right? Or do you know?
25 MR. SWINK: Well, it depends on what we como up with
.M'%)
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206 I as a final adaptation of all the recommendations and so forth.
2 MR. MICHELSON: So, right now, you're still doing it 3 the old way? By that --
you're doing it only within NRR; 4 research is'not involved?
l l 5 MR. SWINK: That's correct.
6 MR. HERNON: The old ways -- once the resolution was 7 achieved, the Task Manager pretty much became divorced from the.
l 8 project.
l l
9 DR. SIESS: But don't forget that NRR was involved in l
10- the resolution.
1 1
11 MR. MICHELSON: I realize that. Now they're not.
12 DR. SIESS: Oh, no. They still are. Task forces for 13 resolution cut across boundaries.
'O 14 MR. MICHELSON: Yes, but I don't know what part of l 15 NRR, and whether that same person is involved in the process 16 now of going from the Project Manager back to the particular l 17 technical --
18 DR. SIESS: Well, I would assume when you set up a 19 task force to handle a resolution that the people out of NRR l 20 are the technical people, aren't they?
21 MR. MICHELSON: Are you establishing a task force for 22 each resolution?
23 MR. NORIAN: Each issue has a take action plan; that 24 action plan lists all the branches that are going to help out l 25 on that action plan and what their function will be -- what O
Heritage Reporting Corporation (202) 628-4888
207 g 1 their job will be.
2 MR. MICHELSON: On implementation?
3 DR. SIESS: No, on resolution.
4 MR. MICHELSON: I'm talking implementation.
5 DR. SIESS: No, implementation goes to the Project 6 Manager.
7 MR. MICHELSON: Right, and the people involved in 8 reviewing the implementation may not have ever been involved in 9 a task force.
10 DR. SIESS: They might not have been. But.I said, 11 isn't it a high probability that if it's an electrical question l 12 that somebody in the Electrical Engineering Branch has been on 13 th$1t task force? And the answer was yes. l 9 14 MR. MICHELSON: Probably so. But there's a lot of l
l 15 people in that branch.
15 DR. SIESS: There's not an awful lot of people.
17 You'd be surprised.
18 MR. SWINK: Let's discuss the blackout right now.
19 Falsrose is there; Al Circus is there -- and they are working 20 to develop what the implementation imposition is going to be, 21 and making a decision about the licensing guidance, and also 22 about the inspection guidance.
23 So, you have the research lead person for that issue 24 working with the Technical Reviewer, who's going to do it. And 25 there's a lead PM that's being assigned to work with them, to O
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I work up the licensing guidance.
2 MR. MICHELSON: By the time you begin to turn out new 3 resolutions with research responsibility -- by that time you'll 4 have worked out some arrangement to keep those people fed back 5 into the NRR process.
6 You just don't know quite what that --
1 7 DR. SIESS: It's only a proposal.
8 MR. SWINK: That's correct.
9 DR. SIESS: What additional resources are needed to 10 go down that route?
11 MR. SWINK: So far, and I can't speak for everyone--
12 but in my opinion, I don't think it'll take any more than what 13 we currently have.
14 It'll mean reallocating them in different ways.
15 DR. SIESS: It's going to keep people involved beyond 16 the time they're involved now, which seems to me, it's got to 17 take more of their effort.
18 MR. SWINK: But the key is that you wouldn't expect a 19 research person to spend full-time in the implementation phase.
20 DR. SIESS: No.
21 MR. SWINK: You'd expect him to spend lees and less.
22 23 24 25 l
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KA4 209 NRC/ACRS 1 points, key meetings, key decision points.
30Sr 87 COI 2 DR. SIESS: You feel that just by bringing in some Tp9 3 people from NRR to help in the process of what's going on, 4 you won't require any more people?
5 MR. SWINK: We think where we will get the benefit 6 is,rather than having to make those decisions at a hundred 7 plants and requiring an intensise decision-making process for a those hundred plants, if we put the bucks in the front end and 9 do it well, we'll be able to take the bucks out of the left 10 end -- or, the back end and spend less time in it.
11 DR. SIESS: Well, NRR can give some resources to 12 research?
lllll 13 MR. SWINK: No, because we're going to have more 14 generic issues to deal with and more licensing actions than l
15 what we've had in the past. l l
16 DR. SIESS: Okay.
17 MR. MICHELSON: Do you understand it, so you can put 1g it into the minutes?
39 D R. SIESS: Oh, I understand what he's proposing.
20 I'm just not quite sure I understahd why it won't take more !
l l
21 resources. Like other things it --
on MR. WYLIE: I'd like to see a diagram from start to lh finish on the first one, and then on what's being proposed.
23 24 DR. SIESS: Well, maybe somebody could provide one 25 for you. Tell them what you want.
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10 KA5 1 MR. SWINK: Well, we're working up this presentation
(_) 2 for the commission. I guess we could send a copy here without 3 any problem.
(~)
(_/ 4 MR. MICHELSON: Will it include how you used to work?
5 MR. WYLIE: Well, I don't know, I guess I'm kind of 6 used to diagrams.
7 MR. MICl!ULSON: Walt mentioned the presentation for 8 the commission. I'm certain that that material could certainly 9 come to ACRS.
10 MR. SWINK: We don't have it now.
11 DR. SIESS: All I heard that I think is important 12 is that having this group of three people that stay with it llll 13 the whole time, and follow it through from the first plant to 14 the last, provide some consistency, and of course, at the 15 same time, provide just what Carl said, proper interpretation 16 of what the objective was, whether the plant-sepcific change 17 is going to solve the problem that they thought they were 18 solving. And that makes a lot of sense.
19 MR. HERNAN: Walt, do you know who the lead PM and 20 the lead technical person on the station blackout- are by 21 name, been assigned to a specific --
22 MR. SWINK: Yeah, Faust is taking the lead for 6
'b 23 station blackout, but he's got two people that are dedicated 34 that are following like B-56 and I think the other one is A-30 .
7
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25 I don't know. I mean, I can go back and get you the names, Acme Reporting Company n, w an
KA6 211 1 but there have been, because I've been in the meetings and --
,) 2 Part of the meetings that we've had.
3 MR. HERNAN: For A-44, though?
4 MR. SWINK: Faust is doing that personally.
5 MR. HERNAN: Well, Faust is the branch chief, though.
6 MR. SWINK: But he's doing that personally. He has 7 been assigned by the senior management to d~ that personally 8 as well as his branch chiefing, and he's got two people under 9 him staffwise who are also assigned to it. That's an issue 10 that was decided to be bigger than one man, but there had to I
ji be one man in charge, just like --
12 MR. :lERNAN: But eventually there's going to be a lllh 13 lead technical person other than the branch chief?
14 MR. SWINK: That's correct.
15 MR. HERNAN: That has no other duties?
l j(; MR. SWINK: There'll be one of those two people he l
j7 has working on it right now.
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18 MR. HERNAN: And the lead PM, do you know who that's l l
19 g ing to be? {
20 MR. SWINK: There's a request over to Margaret to 21 assign one, because we're getting into writing the licensing ;
1 22 guide, and I expect to have that within a week or so.
7-V MR. MICHELSON: Would that PM be responsible for l 23 l l
gw 34 station blackout as a project and also maybe for a couple of d
25 plants?
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KA7 212 1 MR. SWINK: Yes.
() 2 MR. MICHELSON: That he's working on? Is that the 3 way that works?
(-) 4 MR. SWINK: Yes.
5 MR. MICHELSON: It's a part-time job on A-44.
6 D R. SIESS: They would be representing the PM 7 approach in the resolution of that problem, which wouldn' t 8 take, presumably, a tremendous amount of their time away from 9 the plant duties.
10 MR. SWINK: The view is he could answer the 11 licensing kinds of questions.
12 DR. SIESS: Okay, you got -- you about finished?
MR. SWINK:
lllll 13 I'm done.
14 DR. SIESS: Okay. Now, Ron, what were you proposing 15 to do? Something formal, or just show up and answer questions?
16 MR. HERNAN: I've got a presentation on behalf of the 17 project manager.
18 DR. SIESS: How long wi]l it take?
19 MR. HERNAN: llow long do you want it to take?
20 DR. SIESS: I'm leaving at five minutes to 2:00.
21 MR. HERNAN: That's how long it'll take.
l 22 DR. SIESS: No, you guys can continue without me if J tN.J')
l 23 you have no -- l l
1 24 MR. IIERNAN: My name is Ron flernan, I'm with NRR. I
<~3 q) 25 We were originally asked to have one or all three of the l
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KA8 213 1 project managers assigned to the Duke Power Company plants 2 come today to respond to Duke Power's comments. I 3 understand that Duke Power cancelled out at the last minute, I^'N )
(> 4 so we tried to at least salvage some of the things that we had 1 5 intended to discuss, and one of the questions was to go G through some typical USIs or generic issues from the point at 7 which the resolution was declared until they were resolved. j g Like to point out that most of my career with the l 9 NRC has been as project manager, and as a matter of fact, prior 10 to coming into the position I'm in now as the ACRS liaison, I 11 was the backup PM for Occonee. So I do feel qualified to 12 speak for Mrs. Pastus, who could not be here today due to 13 illness, 14 One thing that you'd asked for was a list. Helen, 15 at our last meeting, had mentioned a list of outstanding 16 generic issues that -- on the Occonee plant, so that's the 17 first page of your handout. You can see that there's a total Ig of 12 outstanding generic issues on each of the three Occonee 19 units, for a total of 36.
20 DR. SIESS: Let's see, MPA is what?
21 MR. HERNAN: MPA stands for multi-plant actions.
22 It's been the NRR system for implementing generic issues in 7
i) 23 the past.
24 DR. SIESS: MPA actions is redundant.
(v'T 25 Go ahead.
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1 MR. HERNAN: Well, it's neither here nor there.
I
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I 2 You'll notice in looking at the 12 specific items on l l 3 Occonee that most of them are either residual TMI action plan i /~s
(_) 4 items or, on Items 6 through 9, which just have an item 5 number -- it's not obvious -- but those are items that came 6 from the generic letter on the Salem ATWS event. So most of ,
f 7 those items have not gone through the generic issue process, 8 as you've been discussing with research this morning. So I 9 didn't consider either the TMI action plan items or the Salem 10 ATWS as good examples of demonstrating how the process works.
11 I handed out just a limited number of copies of the 12 sims fof Occonee to give you a flavor for -- here you have 36 llll 13 generic items, 12 for each plant, but the total number of items 14 on the platter for Occonee is 45 pages' worth. So most of the 15 items that the project manager deals with on a daily basis are 16 plant-specific items, just to put things in perspective.
17 DR. SIESS: Now I got the impression that a lot of 18 those plant-specific items were tech-spec changes and things 19 of that sort.
20 MR. HERNAN: Certainly.
21 DR. SIESS: The important item -- she thought they
- 22 were important -- is the basis for LCOs and so forth. But 23 they weren't hardware-type items.
<~x 24 MR. HERNAN: Well, let me --
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And some of them -- now, these are all 25 D3. SIESS:
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KA10 215 k i NRC-imposed items, right? Them sims?
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_ 2 MR. HERNAN: No, these are -- the sims printout is 3 the total management list of outstanding licensing actions --
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(, 4 DR. SIESS: Okay, but they're licensing actions.
5 This doesn't include plant improvement items?
6 MR. HERNAN: Yes, it does. Anything that 7 represents an interaction between the project manager and the 8 licensee is a licensing action.
9 DR. SIESS: Now, that's something they want to do 19 but they have to get permission to do it?
11 MR. HERNAN: No, a licensing action includes l l
12 everything. {
1 DR. SIESS: I guess I'm not getting through.
lllh 13 1
14 The utility wants to do something, maybe {
I 15 safety-related. You haven't required it. They want to 16 replace a part, or they want to put in a different kind of 17 valve. Is that on the sims list? You didn't --
jg MR. HERNAN: Only if it comes to the NRC for review, 19 i.e., if they do not do it under 50.59.
20 DR. SIESS: Okay, if they do it under 50.59, it's 21 not on --
, 22 MR. HERNAN: If they do it under 50.59, it doesn't
( show up. A lot of these are tech-spec changes. A number of 1
23 There's probably
(
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24 them, as I mentioned, are TMI action items.
25 some from various major plant events, such as Davis-Besse and Acme Reporting Company
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KAll 216 1 Salem ATWS.
() 2 The process, I wanted to summarize that briefly, 3 because at least one of the members wasn't at the meeting we
,n L.) 4 had with the project managers. At such time as research would 5 declare a resolution available for generic issue, then it 6 would be decided how it would be imposed, and there're several 7 methods of imposition. A common one is to issue a generic 8 letter to either all licensees or all permit holders or, if 9 it just applied to a certain class of reactors, just to 10 certain ones. A number of the generic issues have resulted in 11 new rules, and the rules are basically self-imposing. We 12 don't need any other additional tool from NRR.
A number of them go out as information items that llll) 13 14 don't necessarily require a utility to change something, but 15 tell them what the results of the NRC's evaluation was, and 16 suggest they might look at that particular area in their 17 plant. The change might be represented in a change to the 18 standard review plan, which generally would not necessarily 19 affect a reactor that was already in operation, but may affect 20 one that's in the licensing process or will affect future 21 reactors.
22 If you look through the history of how most of these
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m 23 generic issues have been implemented, that is, the ones that 1
{ r^x 24 have an imposition and an implementation associated with it, I (.-) I think, based on my review of 25 you'll find various means.
Acme Reporting Company 42026 M B d P P fe l
KAl2 1 generic issues, most of them do not require anything of the in
(._) 2 plants.
3 MR. MICHELSON: Could we review for a moment one h
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\_ - 4 that does, in order to understand the process? One of the TMI 5 action items, I believe, was a reactor vessel level G instrumentation requirement. I guess that's Item No. 5; is 7 that correct? Your Item 57 8 MR. HERNAN: No. No, it's not.
9 MR. MICHELSON: Where -- which one of these is 10 reactor vessel level instrumentation?
11 MR. HERNAN: It's not on there.-- ,
12 MR. MICHELSON: Oh, it's been implemented --
MR. HERNAN: -- which means it's been resolved for lllh 13 i
14 Occonee. It's been resolved for Occonee, so it's not on this ]
l 15 list. l l
n; MR. WYLIE: It's already in place at Occonee. l 17 MR. HERNAN: That's right. These items on the list n; are outstanding ones. )
39 MR. MICHELSON: Oh, these are the ones that are stil:
20 to be done?
21 MR. HERNAN: Right.
,. 22 MR. MICHELSON: Okay.
V Now, in the case of Occonee, did they put it on the )
23 l
l vessel or did they put it on the hot leg?
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l 25 MR. WYLIE: Put it on the vessel.
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2 18 KA13 1 MR. MICHELSON: You sure?
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(,) 2 MR. WYLIE: Yeah, they had a tap at the bottom of thc 3 vessel.
3
(_) 4 MR. HERNAN: Yeah, they lucked out.
5 MR. MICHELSON: Okay, the reason I am asking, and 6 that it won't pertain to Occonee, but there are other utilitier 7 in which they're putting it only on the hot leg, and the staff 8 did not require it on the vessel, as I understand it.
9 MR. HERNAN: The staff did not and will not require 10 other B&W plants to install a new penetration at the bottom of 11 the reactor vcssel. In the case of Occc , it was already 12 there.
llll 13 MR. MICHELSON: Refresh my memory. In the 14 resolution of the generic issue -- I think it was a generic 15 issue.
16 MR. HERNAN: Which?
17 MR. MICHELSON: The reactor vessel level --
18 MR. HERNAN: No, it was a TMI action item.
39 MR. MICHELSON: Oh, that was an order?
20 MR. HERNAN: It was a generic issue in the broad 21 sense, but not in the sense that Dr. Siess defined a while ago ,
,- 22 MR. MICHELSON: Okay, not in the sense of going
%)
23 through this process at all?
l l
l -
34 MR. IIERNAN: That's right.
,.s 25 MR. MICHELSON: Okay. Well, then my question won't l
Acme Reporting Company a n . s ., . ., n
KA14 219 1 pertain. Okay.
,m
(_) 2 DR. SIESS: But now what Ron has here is two --
3 MR. HERNAN: I've picked out two.
/ 4 D R. SIESS: -- two examples where he can take you 5 right through the process, and I think it'd be fascinating to 6 go through that.
7 MR. HERNAN: The first one I know is of interest to g everybody, because it affects not only seismic, but seismic 9 qualification of aux feed water systems. In the case of to Occonee, they call their system emergency feed water, but it's 11 the sane thing.
12 The history of this in October of 1980 -- this is gglg 13 obviously a post-TMI concern -- an ad hoc task force was 14 established by NRR to make a determination what should be done, 15 Shortly thereafter, early in 1981, a generic letter was issued 16 to all operating PWRs. I've included a copy of that generic 17 letter with the handout just so you could get a feel for what's 18 in it.
19 The generic letter stated the problem, stated why the 20 NRC is concerned, and required that all utilities make a 21 survey cif their aux feed water or emergency water systems to 7- 22 determine which parts of it were not seismically qualified.
?
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23 So the responses came back in over a period of time from all utilities in the country. In the case of Duke Power, that 24 survey took approximately one year. It came back in January 23 l Acme Reporting Company
220 KA15 1 of 1982 with their first response. The staff considered that
) 2 initial response incomplete; went back to Duke Power with a 3 request for additional information, and about five months,
, 4 four months later, they supplemented their response.
5 But essentially by the middle of 1982 we had Duke 6 Power's evaluation of how they thought Occonee's emergency 7 feed water stacked up in terms of being seismically qualified.
8 At that point we had a contractor consultant, Lawrence 1
9 Livermore Laboratory, evaluate the Duke Power responses. j 10 Lawrence Livermore prepared a technical evaluation report near j i
11 the end of 1982, and that provided basis for establishing a j 12 staff position on where things should go for Occonee.
Now, if you read through the generic letter, it lllll 13 14 says basically the generic letter triggers an evaluation of 15 each system, and that any modifications to those plants would be handled on a case-by-case, plant-by-plant basis. It I 10 17 depends on what they found, obviously. So clearly in this 18 case the staff couldn't specify any generic fix for all 19 plants because we didr;t know what was out there.
i 20 It took, as you can see, from late '82 till sometime 21 in 1985, and in this period, of course, there was a lot of 1
-s 23 correspondence back and forth between us and Duke Power. It l
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23 took till that point to decide here's what should be done for :
I e3 24 Occonce, and an agreement by all concerned within the agency
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25 and between Duke and the agency that this represented a i
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1 1 plant-specific backfit. l
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/m l 2 So in early 1985 we then got into the backfit mode i
3 on this particular issue for this plant. It took about
(~b 1
' _) 4 another year or so to go through the analysis required to l 5 support a backfit, and early of this year, January 1987, after o the backfit analysis and the safety evaluation report, all the 7 pieces were brought together, and everybody agreed on them.
l 8 Keep in mind there were two NRR reorganizations in that time l 1
9 frame. We finally issued the safety evaluation report to the I t
10 licensee. l 11 I do have a copy of that. I didn't make extra 12 copies because it's,very thick, but if you're interested in llll 13 looking at what that looks like, I have that.
14 So from 1980 to early 1987, basically we're talking 15 determining what's in the plant and specifically what should be 16 fixed and justifying it from a regulator's standpoint whether 17 these things should be fixed.
18 A couple months after the safety evaluation report 39 was issued this year, then Duke acknowledged the commitments 20 as well as the schedule. This is on each of the three 31 Occonee plants, and to work in with their refueling schedule,
-- 22 the last of the three plants will be completed early in 1990.
/
()) And so Duke has confirmed that schedule, acknowledging things 23
,- 24 may slip, but that's their planned end point implementation V
25 date.
Acme Reporting Company (2021 628 4 R60
222 1 DR, SIESS. Ron, did Livermore deal'with everything !
2 that came up?
r i -3 MR. HERNON: I don't know. I don't know if they did 4 them all or just BMW or just Duke.
l 5 DR. SIESS: Well, it was a plant specific? l 6 MR. HERNON: It was a plant specific evaluation. It 7 is included in the safety evaluation report that we sent to 8 Duke. (
{
9 Now, the second page of this handout is a list of l 10 accomplishments of this whole effort, and you have to read 11 through the multi-page report to pick these out, so that if i
12 there are any there that are confusing, I would not be 13 surprised, but maybe I can explain them to you.
14 But the first one, there is a number of boundary 15 valves which are presently are, you know, the plants operate d 16 with those valves normally open. And the issue was either to 17 qualify those valves, and make them remotely operated, or 18 operate with them normally closed, and of course, some valves 19 that p.robably would not be the solution, depending on the 20 valve.
21 Or, go through an evaluation of why those valves 22 being open would not have an impact on it, following a seismic 23 event anyway.
24 And that analysis will take a couple of years, and in 25 the meantime, they have made compensatory measures in terms of I
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()~ 1 interim procedures.to run up and shut those valves, if there is "
2~ a seismic event, as well as other steps.
3 The next item, there are some seismically end 4 qualified piping, they plan to make the appropriate analysis 5 and instal) a support for that piping. ]
l 6 Thera are a number of unqualified valves, and the
]
7 valves will either be replaced with seismically qualified- U 8 valves, or shown already to be capable of the particular 9 seismic event in question. Or it will be demonstrated that 10 failure of that valve would have no impact on plant safety.
11 Again, on a valve-by-valve basis, 12 MR. MICHELSON: Is there an essential air system to 13 supply these valves?
O 14 MR. HERNON: We are getting down to the next items, i
15 here. I l
16 MR. MICHELSON: Oh, okay. l l
17 MR. HERNON: There is an item there about heating l
18 lights for the emergency diesel generator room that they are 19 going to analyze and modify support in seismic qualification 20 for space heating, for things that would affect the diesel 21 generator operation.
-22 And the next item is to qualify or replace air-23 operated valves, that one is fairly straightforward, and the j 24 last one, there are some air-operated valves that are float 25 control valves for the emergency feedwater system.
'O Heritage Reporting Corporation (202) 628-4888
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() 1 The.fix for that one is to have on standby a bank of 2 emergency nitrogen to act'as a motive force for the valve, in. l l
3 case the al.r system should fall so that they will have, I )
4 believe like'it is about 20 bottles of nitrogen and a big 5 nitrogen truck permanently connected, ready to operate the flow j 6 control valves if they lose the air system.
7 MR. MICIIELSON: Is that a seismically qualified 8 nitrogen system?
9 MR. HERNON: I don't know.
10 MR. MICllELSON: Probably some bottles that they hook 11 up.
12 Well,.it has got to be more than bottles like pipes 13 and things that hook it up, f] 14 DR. SIESS: It is awfully hard to see how it took six 15 years to arrive at --
16 MR. HERNON: Well, on any of these, or most of these l 17 issues, there is a lot of correspondence back and forth, 18 between the NRC and the utilities. And the utility will 19 typically take the attitude that everything is okay, nothing J 20 needs to be fixed, and people cannot' justify making any changes 21 in the plant. l 22 So, you might see a round or two of letters of that 23 nature of the NRC saying, you have got to do something, -- the l 24 plant saying th . everything is great.
l 25 DR. SIESS: Ron, I cannot see that anybody could l
I
() lleritage Reporting Corporation (202) 628-4888 1.
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q(,f - 1 argue that the aux feedwater system was seismically qualified
'2 when it was not designed to be seismically qualified. Now, 3 they could argue that they don't need a seismically qualified l
4 aux feedwater system, but was that not settled when this 5 generic letter was issued?
6 MR. HERNON: The generic letter told them to go out 7 and look and see what they have and take it from there.
8 DR. SIESS: Okay.
9 MR. HERNON: The taking it from there part took about f 10 six more years.
11 DR. SIESS: It did not say that you must have a 12 seismically qualified aux feedwater system? I 13 MR. HERNON: No, because the Staff realized that most 14 of them were not. They were not designed to be totally 15 seismically qualified.
16 DR. SIESS: So it said --
l 17 MR. HERNON: I think, as it turned out, that most of j 18 them or a large portions of the systems were, but not the
]
19 entire system.
20 DR. SIESS: So this is what they had to do to show I 21 that the aux feedwater system would survive an earthquake? l 22 MR. HERNON: Well, this 'as what was ultimately 23' agreed between the Staff and the Oconee, and of course, the 24 fixes would be unique to different plants, each plant would 25 have their own fix, but Oconee, and Peach Bottom, I think, were O
Heritage Reporting Corporation l (202) 628-4888 l
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226 s i 1 the last two plants to reach resolution on this issue.
} '
2 DR. SIESS: From the time that the generic letter was 3 issued until Duke acknowledged the commitments, is how long it 4 took.
1 5 MR. BAIRD: I was just going from 1980 to 1990. i
)
6 DR. SIESS: No, I am just going from when they 7 decided what to do, l
8 MR. IIERNON: The other point I wanted to bring up and l 9 it was brought up by the project managers in the previous 10 meeting, that even though there may be a fairly straightforward 11 fix for a given problem, you still have to go through another 12 resolution phase at the time that you try to apply it to a 13 particular plant. j O
NJ 14 In other words, research may resolve, you know, you i
15 have to install another widget and that is the fix of the ]
i 1 l 16 problem. Now, when you get to posing that particular generic {
1 17 issue, on your plant, it may not fit, so that you have to go 18 through an evaluation. Well, if you cannot do what the generic
]
1 19 resolution is, what do you have to do to meet the intent?
20 DR. SIESS: Now, actually these items are the plant 21 specific back-lits, I assume, that were identified back in 1 22 1985.
23 MR. HERNON: Right.
l' 24 DR. SIESS: And then it took another two years to get 1
25 the safety evaluation report out l
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1 MR. HERHON: Hell, and the backfit analysis, the 2 regulatory analysis is no menial task.
3 DR. SIESS: How, what was their response in 1982? I 4 mean, did it propose this sort of thing or less, do you have l 5 any idea?
6 MR. HERNON: I am not familiar with the details of 7 the response to 1982, I have it with me, if you are interested.
i 8 But it was basically, here is what we have, and here is why we 9 think what we have is okay.
10 DR. SIESS: Oaky, now, the Livermore report came out 11 in late in 19827 12 MR. HERNON: Right.
g 13 DR. SIESS: And it took the staff 2.5 years to b
14 identify the backfits.
15 MR. HERNON: Yes, and as I mentioned, there was a 16 number of negotiations between us, and Livermore and us and 17 Oconee, during that period of time, to figure out what the i 18 right, you know, to understand what they had and to figure out 19 what has to be done to make them safer.
20 So, I don't know if you would consider this whole 21 list of things a major improvement in Oconee, you know, people 22 havo said, major improvements, and I don't think that most of 23 these generic issues resulted in a major hardware improvements 24 in plants.
25 DR. SIESS: No, maybe not major hardware, but it l Heritage Reporting Corporation i
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() 1- might be a major safety improvement.
either, I am not sure of that 2
3 But now, Duke actually responded to generic letter in 4 11 months. And it took the rest of that time to reach an S . agreement on -- I assume in that response, they said what they 6 were willing to do.
7 MR. HERNON: No, not totally. If you look at the 8 record, and there is a series of letters and references to 9 letters that are discussing the safety evaluations, and there 10 were several different areas of concern that it looked like 11 they were pursued one at a time, rather than all at once.
12 But-they concentrated on this area, and you can see 13 letters through 1982, 1983, and then they go over this area, 14 and it seemed like a very difficult task to figure out, what 15 they had that did not meet seismic requirements and what the 16 right thing to do to fix it would be.
17 DR. SIESS: Interesting.
18 MR. HERNON: And there was a certain amount of foot-19 dragging, I think, that is just my opinion.
20 DR. SIESS: On which side?
21 MR. HERNON: By the utility.
22 DR. SIESS: It looks to me like there is plenty of 23 opportunity for foot-dragging by the NRC in here, too.
24 MR. HERNON: Well, there were two reorganizations i
i 25 that did not help. )
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( 1 DR SIESS: Carl, I am sorry.
2 MR. MICHELSON: Yes, I have a procedural question.
3 In the case of a, you know, you have a particular generic issue 4 and you finally reach a resolution, internally in NRC, and 5- maybe that resolution prescribes that a certain system or a 6 certain device is to be added. That was the resolution.
7 Now, we get to the case where we are trying to 8 implement it and I think that you pointed this out earlier, and L 9 it turns out that we cannot add device A, but we could use a 10 device B that would work.
11 What is done to go back and work through with the 12 original resolvers of this issue to determine if that is
- 13 acceptable, or does NRR just do that on its own?
14 MR. HERNON: I don't think that there is any uniform 15 way of handling that situation. )
16 MR. MICHELSON: I would think, intuitively, that if 17 you could not meet the resolution requirements, then it would 18 be that you are required go back to the people that arrived at 19 that resolution for concurrence on some other resolution.
20 MR. HERNON: You look at resolutions and I think that 21 they are intentionally non-prescriptive. So that we don't get 22 into that.
23 MR. MICHELSON: Some of them are and some of them are ,
24 not.
25 DR. SIESS: What do you think that your water level O
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-1 thing, that probably said provide something?
2 MR, MICHELSCN: I would have to go back and review 3 it, because that was not a generic issue, as I understood it.
4 MR. HERHON: The water level instrumentations are 5 interesting.
6 MR. MICHELSON: But in theory you don't ever have to 7 go back to change the resolution, you can just negotiate any b other fix? In other words, it is not a requirement. The 9 resolution is really not a requirement in the sense of having 10 to meet what the resolution asked for and the intent is 11 determined by'the licensing people.
12 DR. SIESS: I think that you might say that it is ,
13 sort of like a reviewer deciding whether somebody meets the 14 general design criteria.
15 MR. MICHELSON: Yes, I just wanted to clarify that 16 that is the way it is.
17 MR. HERNON: I think in the past, there has been a 18 fairly open dialogue between the person who signed, as the 19 technical reviewer for all plants on that issue, and the person 20 who was involved in the resolution.
21 Because both people were then part of the NRR --
22 MR. MICHELSON: The reason that I asked only is that 23 I can read a resolution and I would not necessarily find --
24 cannot necessarily go and look for a one-to-one correspondence 25 in the implementations.
{ Heritage Reporting Corporation (202) 628-4888
1~ MR. IlER140ll: Yes, technical reviewers for the most 2 part being responsible enough to where I think that they would 3 have recognized, that maybe they had to get back to the 4 originator to figure out what it was.
5 MR. MICliELSOll: There was no concern on my part, just 6 a clarification.
7 MR. IIERNON: The second issue 1 picked up as an 8 example was whatever happened to good old USI A-3, 4, and 5, 9 which is still kind of current but the original concern of 10 course, was what to do to upgrade, if necessary, steam 11 generator integrity.
12 And I think that most of you are familiar with the 13 resolution process. I wanted to show you a little bit how that t
O 14 issue was imposed on plants and again, it was done by a generic 15 letter, which is generic letter number 8502, and I have also 16 included that in the handout.
17 18 19 20 21 22 23 24 25 O IIeritage Reporting Corporation (202) 628-4888
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INRC/ACRS 1 MR. MICIIELSON: Well, it gave seven recommendations.
'30Sr-97 lCOFk_) 2 MR. HERNAN: Yeah, it had recommendations,
- Tp10 3 prevention detection of looze parts and foreign objects, g
(_) 4 steam generator tube in-service inspection, secondary water 5 chemistry program, condensor in-service inspection program, 6 primary-to-secondary leakage limit, coolant iodine activity 7 limit, and safety injection signal reset.
8 These are recommendations the staff made. The 9 responses came back with here's what we're going to do in our 10 plant to address each of these rather detailed recommendations.
11 If you look at the generic letter enclosure, each one of these 12 seven recommendations has a one-page description, discussion, lllk 13 and references to NUREG-0844.
14 Duke Power came back in about three months with their 15 response to Generic Letter 8502 in April of -- or, I'm sorry, 16 July of 1985; went through an item-by-item description of this 17 is why we think the Occonee steam generators and chemistry 18 control and so forth, you know, meet the requirements as is 19 and don't need to be improved.
20 At this point in time there is one improvement that 21 we're pursuing with Duke as a result of this, and that's to
,~ 22 adapt the standard tech-spec limitations on primary and L,)
23 secondary leak rate. Duke has a situation on Occonee where 24 Unit 1 has a limit of 0.3 gallons per minute, and Units 2 and l
(^}
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25 3 have a limit of 10 gallons per minute. The staff's Acme Reporting Company L2O2h 6FB eBBB
KA2 233 1 recommendation was to go to one gallon per minute, which is i the standard tech-spec.
2 3 Duke, or Occonee, does not have standard tech-specs.
t,) 4 They were licensed before standard tech-specs came into being.
5 So anything along those lines, I guess, would be construed 6 as a backfit.
1 7 We're still going back and forth with Duke Power on i 8 this, so I can't tell you how it came out because it hasn't 1
9 yet. At the same time, I guess, final resolution of generic jo issue is being pursued. This is one of the 17 items that NRR 11 hung onto after the reorganization, and there was a 12 commission paper. I'm not sure what else has happened after l
that. But there was a, you know, identification of a lllh 13 14 tech-spec glitch for Occonee that came out of this effort, I
15 I think the even more significant thing is that it's )
16 caused the NRC and Duke to go through and consider each of ;
i 17 the seven areas that we feel affect the integrity of the 18 steam generators and make a plant-specific evaluation on how gg they stack up compared to the NFi's recommendations.
20 So those are two examples. What I found in trying 21 to find some examples for any of the Duke plants was that, A, 22 most of the generic issues ,x a't ultimately require anything
- V different to be done in the plant. They're either resolved as 23 l 24 a non-problem, or they change the standard review plan for 25 future plants, or they result in an information, an optional f
Acme Reporting Company
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234 s KA3 1 program for a plant, or they're dropped. But it is a, you (j 2 know, an effort to go through and evaluate whether an issue is 3 a problem in terms of reactor safety.
(_/ 4 Are there any questions?
5 MR. MICHELSON: I see no indication of questions.
6 Thank you very much, Ron.
7 I believe, unless there are other subjects that the 8 subcommittee would like to bring up, that we have finished 9 what we were looking for today. Are there any other comments 10 on the part of the staff?
11 I see none, so why -- seeing no comments, I believe 12 we're finished. Thank you very much.
(Whereupon, at 1:57 p.m., the hearing in the lllh 13 14 above-entitled matter was concluded.)
15 16 17 18 19 20 21 22 xm/
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235 i 1 CERTIFICATE LO 2 3- This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in'the matter of:
5 Name:- Advisory Committee on Reactor Safeguards Subcommittee on Generic Items
! 6 4
7 Docket Number:
8 Places Washington, D.C.
9 Date: September 30, 1987 l 10 were held as herein appears, and that this is the original 11 transcript'thereof for the file of the United States Nuclear l 12 Regulatory Commission taken stenographically by me and, L
13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a l
15 true and accurate record of the foregoing proceedings.
' 16 /S/ h 2/MA i 17 (Signature typed): Irwin T. Co nbe Nrry 18 Official Reporter 19 Heritage Reporting Corporation 20 f
21 22 l '
23 t i 25 i
i O l Heritage Reporting Corporation ;
(202) 628-4888 i i
m INTRODUCTORY STATEMENT BY THE GENERIC ITEMS SUBCOMMITTEE CHAIRMAN ,
(]~ SEPTEMBER 30, 1987 The meeting will now come to order. This is a meeting of the Advisory Committee on Reactor Safeguards Subcommittee on the Generic Items.
t I am Chester Siess, Subcommittee Chainnan. I I
The other ACRS Members in attendance are: Jesse Ebersole,
'Carlyle Michelson, and Charles Wylie.
The purpose of this meeting is to continue the discussion on the I
effectiveness of the NRC Staff pr~ograms that address generic issues and USIs.
Sam Dura k.amy is the cognizant ACRS Staff Engineer for this meeting.
The rules for participation in today's meeting have been announced as Q part of the notice of this meeting previously published in the Federal l
Register on Wednesday, September 16, 1987.
A transcript of the meeting is being kept and will be made available as !
stated in the Federal Register Notice. It is requested that each speaker first identify himself or herself and speak with sufficient clarity and volume so that he or she can be readily heard.
We have received no written comments from members of the public.
We.have received no requests for time to make oral statements from members of the public.
O ,
-__ _---_-_ . --__-_ - . _ _ a
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USI A-46 SEISMIC QUALIFICATION OF EQUIPMENT IN OPERATING PLANTS PRESENTED TO ACRS SUBCOMMITTEE MEETING ON GENERIC ITEMS O
T, Y. CHANG RES/DE/EIB SEPTEMBER 30, 1987 i
u _ . _ - . . _ _ . _ _
l Q NATURE OF RESOLUT10fl IDENTIFIED AS USI 12/80 5 ALTERilATIVES TO CURRENT SEISMIC QUALIFICATION!! STUDIED BY TECHNICAL ASSISTANCE CONTRACTS USE OF SEISMIC AND TEST EXPERIEllCE DATA APPROACH THE MOST REAS0llABLE AND COST EFFECTIVE EXTEllSIVE lilDUSTRY INVOLVEMENT PROPOSED USE OF EXPERIENCE DATA AND FORMATION i 0F SQUG ( ~ 81)
L O. -
' PROPOSED FORMATION OF SSRAP (6/83)
ASSUMED RESPONSIBILITY FOR DEVELOPMEllT OF IMPLEMENTATION PROCEDURES SQUG/SSRAP/NRC RELATIONSHIP Ull10VE FOR USI/ GENERIC ISSUE RESOLUTION FOLLOW-THROUGH ON IMPLEMENTAT10ll WITH THE RESOLUT10!! TASK l MANAGER i
STAFF REVIEW GROUP FORMED EARLY, ACTIVE THROUGH IMPLEMENTATION ANCHORAGE GUIDELINES REVIEW GROUP O -
RELAY REVIEW GROUP
O TIME FOR RESOLUTION DESIGNATED AS USl 12/80 PRELIMINARY PROPOSED RESOLUT10ll READY 3/84 IST CRGR MEETING 12/84 2flD CRGR MEETit!G 7/85 CRGR PACKAGE ISSUED FOR PUBLIC COMMEllT 9/85 3RD CRGR MEETillG ON FINAL RESOLUTI0ft 10/86 1
RESOLUTION ISSUED 2/19/87 IN FORM OF GENERIC LETTER 87-02, AND I4UREG-1211 AND NUREG-1030 l
0
O. 1 RESOURCES USED FOR RESOLUTION-l- TECHillCAL ASSISTANCE EXPEllSE WORK TIME 75K TASK 4-
-LLNL COMPLETED 83
-300K TASK 3
-IflEL COMPLETED 84-320K TASK-1, 5
-BHL. COMPLETED 84 200K SUPPORT 1
-SNL 84 - DATE 895K SSRAP MEMBER SOUG COMMITTED EXTENSIVE RESOURCES FOR EXPERIENCE DATA COLLECTIO!), SSRAP, GIP, CABLE TRAYS, TRAINING SEMINARS
- TO DATE APPROX. 200K PER MEMBER
i O l l
l O l RESEARCH PROGRAMS SWRI - COMPARIS0li 0F OLDER QUALIFICATI0f4 METHODS WITH CURREllT CRITERI A (TASK 2)
- Oti-G0ll1G RESEARCli PROGRAM i
- MODIFIED TO ACCOMMODATE A fl6 NEEDS l
(CHAT 4GES Ili SCHEDULE AllD TASK ORDER)
- Il0T THE PREFERRED METHOD FOR A-46 i Bill /LLI4L - EQUIPMEllT FRAGILITY PROGRAM
- PROVIDES FRAGILITY INFORMATI0ll FOR USE Ill A-46 O IMPLEMEllTA 10f1
- Oil-G0lf1G RESEARCH PROGRAM I
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NATURE OF RESOLUTION OF GSI-20 0
- 1. ISSUE WAS RAISED BY A STAFF MEMBER, D. BASDEKAS, IN 1976 (NUREG-0153, ISSUE 27)
- 2. ISSUE RAISED AGAIN BY D. BASDEKAS, 1979
- 3. STAFF STUDY AUTHORIZED BY COMMISSION MID-1979
- 4. CONTRACT WITH SANDIA NATIONAL LABORATORY INITIATE
- 5. SANDI A PROGRAM COMPLETED JANUARY 1983, NUREG/CR-3069, FEB.1 SCOPE:
- LIMITED TO SAFE SHUTDOWN SYSTEMS
- BASED ON WORST CASE EMP/ CONFIGURATION ,
- PERMANENT DAMAGE FAILURE CRITERION l
- PEER REVIEW PANEL SAFE SHUTDOWN CAPABILITY WOULD NOT BE DISAB O
CONCLUSION: l
- 6. STAFF REPORT TO COMMISSION SECY-83-367, SEPTEMBER '83 SCOPE:
- EXTENDED T0 INCLUDE SIGNAL UPSET EFFECTS
- ADDRESSED PENDING PETIT 10t!S FOR RULEMAKING CONCLUSION: SAFE SHUTDOWN CAPABILITY WOULD NOT BE DISAB RECOMMENDED: THAT NO FURTHER ACTION BE TAKEN ON EMP COMMISSION APPROVAL (UNANIMOUS) NOVEMBER 15, 1983
- 7. CLOSE00T:
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- R N O L E F T M I : H A C S G S O A E H S ) G E B U N N N S G 8 U Y U O I E N I N I 1 O / S I K F O D O D 1 R S V A N E I R E 1 H R L E M O D TO MW
- T A N R E I A O A S A E S P L TH T C R S Y U A T N G D N E R R I E L O N I C F : E W MN R A F R F E R P U S P N O O N C / )
( U A O T O F O O O F E G S S S N C I D F O R T E S T A D F S R 3 Y N Y A E T (
O 3 L O R N T S G C F . L I T I E N N F 0 A T S D L E I A L A I I U R P S O M N T T T D O MO G R S S N E N O O L N E E P I C C C O G S
. . S i 1 E * * * * * *
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l GENERIC SAFETY ISSLE 61 SRV LINE BREAK INSIDE THE WETWELL AIR SPACE OF MK 1 & 11 CONTAINMENTS Nature of Resolution Resources Expended Nature of Related Research O
l A.W. Serkiz RES/DRPS/RPSIB 301/492-7487 Presented to: '
The ACRS Subcommittee on Generic Items September 30,1987 Q
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l NATLRE OF RESOLLTION GSI-61 .
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- 2) Safety concerns were studied by BNL and reported in BNL-NUREG-31940 (10/82) .
- 3) Issue was prioritized a level " Medium" In 11/83. 4 l
- 4) BNL-NUREG-31940 was reviewed by NRC staff and the I BWROG; the assumptions and findings were questioned (3/85).
O S) BNL there-evaluated GSI-61 based on comments (6/86) received and
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results are reported in NUREG/CR-4S94 61 BNL's re-assessment showed a much lower effect on CMF
, and potential releases.
4
- 7) GSI-61 was therefore declared resolved in 8/86 without any need for additional expenditure of resources.
4 years to arrive at resolution. I Resolution acheived after issue was assigned to a dedicated Task Manager Another 1-2 grs if CRGR & ACRS review needed.
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GSI-61 RESOLRCES EXPENDED l
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- 1) BNL costs (Fin A-3793) 1/85 - 6/86 FY 85 5 99.6 K .
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FY 86 $ 75.2K , $ 174.8K Total
- 2) Prior Costs (before 1985):
O Estimated to be less that $ SOK
- 3) Concluding Phase:
Jan 85 to May 86 (Dedicated PM assigned)
NATLRE OF REI ATED RESEARCH
- 1) No special research required to resolve GSI-61.
- 2) Resolution was based on re-assessment based use of actual plant data, pipe break probability based on more current theories, revised CONTEMPT code calculations and internal models.
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NRR STAFF PRESENTATION TO THE l O ACRS 1
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SUBJECT:
GENERIC ISSUE IMPLEMENTATION I
1 DATE: SEPTEMBER 30, 1987 I
PRESENTER: R. W. HERNAN l
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PRESENTER'S TITLE / BRANCH /DIV: ACRS COORDINA'IOR, PTSB, PMAS PRESENTER'S NRC TEL. NO.: 492-9519 I
SUBCOMMITTEE: cENERIC ITEMS l
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'J ,. Unit 1 Unit ? Unit 3 To tal
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Active Actions 33 32 32 97 Actions Com. 'M FY87 50 50 50 150 Active MPA Actions 12 12 12 36 1
- 1. RV and SV Testing (F-14)
- 2. 111. A.2.2. Meteorological Data Upgrade (F-68)
- 3. 11.K.3.31 Compliance with 10 CFR 50.46 (F-58)
- 4. Reactor Coolant Pump Trip (G-01)
- 5. Instrumentation to follow the course of an accident (R.G. 1.97) (A-17)
- 6. Item 2.1 (B-77)
- 7. Item 2.2 (B-86)
- 8. Items 4.2.3 and 4.2.4 (B-89)
- 9. Items 4.5.2 and 4.5.3 (B-93)
- 10. RCS Vents TS II.B.1 (B-83)
- 11. GL 83-37 TS (B-83)
- 12. 10 CFR 50.62 (A-20) l l
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S SElSMIC QUALIFICATION OF AFW SYSTEMS
'gENERICIS'UE:
. (NULT-1-PLANT ACTION C-14)
IMPOSED-BY: GENERIC LETTER-81-14 (FEBRUARY- 10, 1981) 1 PLANT: 1,2,3 4
-CHRONOLOGY:
10/80 AD HOC TASK GROUP ESTABLISHED BY NRR O
2/81 G.L. 81-14 ISSUED TO ALL OPERATING PWR'S 1/82 DUKE' POWER RESPONSE TO G.L. 81-14 (SUPPLEMENTED 5/82) 8/82 EVALUATION REPORT FROM NRC CONSULTANT (LLL) 2/85 PLANT-SPECIFIC BACKFITS IDENTIFIED FOR OCONEE
'3/86 BACKFIT ANALYSIS COMPLETED 1/87 SAFETY EVALUATION REPORT ISSUED TO DUKE POWER LO l
3/87' DUKE ACKNOWLEDGED COMMITMENTS, COMPLETION DATE - 3/90 l
$ 1 2
ay
-IMPROVEMENTS TO BE ACCOMPLISHED NORMALLY OPEN' BOUNDARY VALVES WILL BE CLOSED OR MODIFIED T0.
BE REMOTELY OPERATED OR BE ANALYZED TO SHOW N0 IMPACT OF FAILURE (INTERIM PROCEDURE CHANGES HAVE BEEN MADE)
SEISMICALLY UNQUALIFIED PlPING'WILL BE ANALYZED AND SUPPORTED SEISMICALLY UNQUALIFIED VALVES WILL BE REPLACED OR SHOWN TO BE CAPABLE OF WITHSTANDING SEISMIC EVENT OR DEMONSTRATED TO HAVE N0 IMPACT OF FAILURE ;
O* ANALYZE AND MODIFY (AS REQUIRED) HEATING LINES OVALIFY OR REPLACE CERTAIN AIR OPERATED VALVES l
AUTOMATIC NITROGEN SUPPLY PROVIDED FOR AIR OPERATED FCV'S GENERIC ISSUE: STAFF RECOMMENDATIONS CONCERNING STEAM GENERATORS (USl A-3, 4, 5)
GENERIC LETTER 85-02 (APRIL 17, 1985) c)
% IMPOSED BY:
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~g UNITED STATES ,
j NUCLEAR REGULATORY COMMISSION v
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- WASHINGTON, D. C 20655
, %.....* FEB 101981 1
TO ALL OPERATING. PRESSURIZED WATER REACTOR LICENSEES J>
J
SUBJECT:
. SEISMIC QUALIFICATION OF AUXILIARY FEEDWATER SYSTEMS (Generic Letter No. 81-14)
Our letter to you dated October 21, 1980, identified concerns regarding l the seismic qualification of Auxiliary Feedwater (AFW) systems. That 1 letter outlined the continuing evaluation program being conducted by the staff with regard to this issue to assure conformance of each plant with General Design Criteria 2 and 34, of Appendix A to Part 50. As a result of the NRC's continuing review of this issue, including the completion of site visits described in our previous letter, we have i determined that it is necessary to request certain information from )
PWR licensees and to request that certain actions be performed by PWR l I
licensees, as described below. The purpose of our information request j
is to obtain sufficient information that identifies the extent to which I AFW systems are seismically qualified. We are also requesting that PWR licensees perform a walk-down of the non-seismically qualified portions
/3 of their AFW systems to identify apparent and practically correctable deficiencies that may exist.
Q For plants with AFW systems that are not seismically qualified either in whole.or in part, our plan involves increasing the seismic resistance ;
of the systems in a timely, systematic manner to ultimately provide reasonable assurance, where necessary, that they are able to function I following the occurrence of: earthquakes up to and including the design Safe Shutdown Earthquake (SSE) for the plant. This plan is a result of a study of the seismic requirements which should be applied to AFW systems for those not presently seismically qualified, as discussed in NUREG-0667, " Transient Response of Babcock and Wilcox-Designed Reactors."
Enclosure 1 to this. letter contains a request for information from all operating PWRs concerning AFW system seismic design. We have determined t '
that docketed information from licensees is not sufficient to In allow us addition, to conduct a detailed review of this aspect of AFW systems.
for a number of older plants, this information is likely not to be
,' current. Furthermore, since the safety significance of the system may
.not have been defined for all plants, the AFW system may not have been adequately maintained and considered to be included within the scope of IE Bulletins 79-02, 79-04, 79-07, 79-14, and 80-11, and IE Information Notice 80-21. Therefore, the existing AFW systems, eitner in total or in part, may have as-built characteristics which result in uncertain seismic design characteristics. For plants with AFW systems, or portions thereof, which are not seismically qualified, Enclosure 1 also requests 5 -
information concerning systems which provide an alternate decay heat
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removal path.
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FEB 101981
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We are also requesting that you conduct a walk-down b. ' arsonnel experienced in the analysis, design and evaluation of such structut es, systems and -
components, of the non-seismically qualified portions of the. AN system for the purpose;of identifying more readily recognized deficiencies in seismic resistance. These walk-downs are requested for only those portions of the AW system which have not been designed, constructed.
- and maintained as seismically qualified systems in accordance with the criteria for safety-grade systems at the facility. The scope of the walk-down should include the types of equipment, components, and piping ,
described in Enclosure 2. Enc.osurel 1 describes what we consider to i comprise the bounds of the AFW system,-and any alternate decay heat removal paths.
For plants with AFW systems that are not seismically qualified, we consi- j l
der that actions should be taken soon to ensure a reasonable icvel of !
earthquake resistance. This applies to both the AFW system and the alternate' system used for decay heat removal if portions of it are not )
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seismically qualified. Based upon the consideration of the past perfor- I fnance of nuclear and fossil power plants, and other non-nuclear facilities subject to large earthquakes, we note that well engineered structures, equipment, :omponents and piping possess a substantial amount of inherent seismic resistance, even without the rigorous seismic qualification l l7 performed for safety-grade portions of nuclear facilities. Of the failures of structures, piping, equipment and components noted in these past earthquakes, a large fraction have been due to brittle failure, lack of restraint, large displacements, or some other obvious deficiency which would have been easily identified before the failure l 1
caused by the seismic event. Such identified deficiencies could have been corrected to significantly enhance reliability without detailed ,
i seismic analyses but by exercising careful engineering judgement. These considerations were factored into the development of Enclosure 2. In addition, certain of these deficiencies were noted as existing at the i several facilities for which we conducted AFW system walk-downs (see Enclosure 3 for details of the visits). Accordingly, your walk-down of the non-seismically qualified portions of the AFW system and other alternate decay heat removal systems should identify any appropriate modifications in the context of the above discussion.
. Enclosure 2 identifies in more detail the actions we consitar appropriate for plants with AFW systems, or portions thereof, that are not seismically qualified. Although we are not at this time requesting that the AFW system be modified to be in conformance with the facility design seismic requirements, we have stated that our plan is to increase the seismic l
resistance, where necessary, to ultimately provide reasonabic assurance i that the system will function after the occurrence of earthquakes up to and including the SSE. .
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- . FEB 101981
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Accordingly, the following actions are requested by this letter: -
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- 1. In accordan'ce with 10 CFR 50.54(f) of the Commission's regulations, I all PWR licensees are requested to provide the information contained In' Enclosure 1 within 120 days of receipt of this letter; and i
- 2. The resuits of any walk-downs are requested within 120 days of j receipt of this letter. These results should ir.clude all identi- j
. fied deficiencies and all corrective actions taken, or planned l along with the schedules for such. Such modifications, if any, shall be handled in the customary manner consistent with the provisions of your license and the Comission's regulations.
Responses should be submitted to enable us to detennine whether or not l your license should be modified, s spended, or revoked. f i
arre G. pisenhut, Director Division of Licensing (9
Enclosures:
1 As stated "This request for information was approved by GA0 under a blanket clearance number R0072 which expires November 30, 1983. Comments on burden and duplication may be directed to the U.S. General Accounting Office, Regulatory Reports Review, Room 5106, 441 G Street, N.W.,
Washington, D. C. 20548."
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- Enclosure 1 th REQUEST FOR INFORMATION
, AUXILIARY FEEDWATER SEISMIC DESIGN
.- l In responding to this letter, the AF14 system boundary from suction to discharge (including the water source and heat sink) shall include those portions of the system required to accomplish the AFW system function and connected branch i piping up to and including the second valve which is normally closed or .!
capable of automatic closure when the safety function is required. The AFW system boundary shall also include any portion of branch piping that is structurally coupled to the AFW system boundary such that the seismic response of the branch piping transmits loads to the AFW system. As a minimum, this includes the branch lines outside the AFW system boundary to a point of three orthogonal restraints. All mechanical and electrical equip-4 ment, piping (e.g., instrument air), conduits and cable trays, which are necessary or contain items which are necessary, for the operation of the AFW system shall also be considered. In addition, the structures housing l these systems and components shall be included. Similar considerations J shall be applied when considering alternate means of decay heat removal.
A. Specify whether your AFW system is (a) designed, constructed, and maintained (and included within the scope of seismic related Bulletins 79-02, 79-04, 79-07, 79-14, and 80-11, and IE Informa- !
tion Notice 80-21), in accordance with Seismic Category I require-ments (e.g. ,- conformance to Regulatory Guides 1.29 and the ,
applicable portions of the Standard Review Plan or comparable criteria) or (b) designed, constructed and maintained (and ;
1 included within the scope of seismic related Bulletins 79-02, 79-04, 79-07, 79-14, and 80-11, and IE Information Notice 80-21) to withstand a Safe Shutdown Earthquake (SSE) utilizing the analytical, testing, evaluation methods and acceptable criteria consistent with other safety-grade systems in your plant. To assist the staf f in an expedious assessment of your plant, if _
your AFW system.or portions thereof, is not qualified to with-stand an SSE utilizing the analytical, testing and evaluation criteria consistent with other safety-grade systems in your plant, we request that you identify those components and structures not seismically qualified in the appropriate row of the attached Table 1.
- B. Where seismic qualification is indicated by leaving Table 1 blank, provide a description of the methodologies and acceptance criteria used to support your conclusion of seismic qualification, including:
- Seismic analyses methods employed, seismic input, load combinations which include the SSE, allowable stresses, qualification testing l
l and engineering evaluations performed.
In addition, where seismic qualification of a secondary water supply or path is relied upon, provide a sunmary of the proce-t dures which would be followed to enable you to switch from the
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primary to secondary source.
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4 0 C. If a lack of ' seismic qualif- ' tion is indicated for i
items 1, 2, 3, 4, . 5 and 6, 7, c- B in Table 1, provide additional information which specifies the level of seismic qualification afforded in the original design for each of these areas.
D. If substantial lack of seismic' qualification is indicated for items 1, 2, 3, 4, 5 and 6, 7, or 8'in Table 1, provide the .
same information requested in A through C for any alternate decay heat removal system. The bounds of these systems shall i be considered to a similar extent as that described for the i AFW system. Provide a summary of the procedures by which operation of these alternate heat removal systems will be accomplished.
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f L, TABLE 1 AUXILIARY FEEDWATER SEISMIC QUALIFICATION ,
(1) Pumps / Motors (2) Piping-(3) Valves /Actyators-(4) Power Supplies (5) Primary Water and Supply Path (6) Secondary Water and Supply Path *
(7) Initiation and Control System (8) Structures Supporting or Housing ,
these AFW System Items !
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- Applicable only to those plants where the primary water supply or path is not provided, however, a seismically qualified alternate
' path exists.
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'. - ENCLOSURE 2 n
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. ACTIONS REQUESTED,,0F PRESSURIZED WATER REACTOR LICENSEES WITHOUT A SEISMICALLY OUALIFIED AUXILIARY FEE 0 WATER SYSTEM l
- 1. For all mechanical and electrical equipment and components including battery racks, controls, instruments, motors, compressors, tanks electrical supplies and the cabinets containing such items, note all items which are not securely attached to their supporting j i
structures such that there is substantial resistance to movement caused by seismically induced forces.
- 2. For piping, note cases where relatively large deflections cannot i be, accommodated without impairing system function. Where such {
displacements will lead to loss of system function, note where 1 sufficient amounts of restraint could be afforded,' thus signifi- 1 cantly reducing stresses that would be imparted to such items as pump nozzles and branch connections, as appropriate. Further, note eccentric valve operators that are not sufficiently supported and act to severly overload the pipe. Where such support is g lacking, you should note where substantial restraints could be added to the extent practical. Also, where pipes are resting t]4 on existing supports, note where substantial resistance to the pipe moving off these supports could be added where it does not already exist. .
- 3. For cable trays and conduits, assure that relatively large displacements can be accommodated without impairing system function where seismic restraint is substantially less than required for these which are seismically qualified. Focus j l
particular attention on preventing the breakage of the electrical and control cables they contain at such places as points of attachment of the cables to equipment or other relatively
- fixed points. Note where any deficiencies exist.
Given the time frame we are recommending for the completion of these l
actions, no explicit analyses are requested to demonstrate system qualiff-cation unless deemed necessary by you. However, sound engineering judgement should be. applied considering the level' of seismicity specified for '
your site and the design requirements for other seismically qualified
- systems in the facility when judging the necessity for and adequacy of c any modifications (e.g. , piping, cable trays, conduit, equipmentFurther, and i component restraints,and estimations of displacement levels).
these acticns shall be accomplished using personnel who are experienced in the analysis, design and evaluation of such structures, systems and components.
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Where you have determined that it is prudent to institute modifications, l no modifications should be instituted which will detrimentally affect -
I' the function of the piping, equipment and components of the system, considering all other loads in addition'to seismic. For example, when providing additional restraints to piping systems, assure that they do not have a detrimental impact on the system considering all loads, in
- - addition to seismic, including thermal loads and support displacement i
induced loads.
Similar considerations as described above should be given to other non-seismically qualified piping, equipment and components in the vicinity of the non-seismically qualified portions of the AFW and the l alternate decay heat renoval systems to provide for a substantial decrease in their susceptibility to failure if such failure could impact the function of the AFW and alternate decay heat removal systems.
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i ENCLOSURE 3 PESULTS OF NRC STAFF WALK-DOWM OF AR4 SYSTEMS i
Plant 1 - Seismically Qualified AFW System (Operating Lice.nse issued in 1975) l Several locations were found in which the supports for the control-air j for the auxiliary feedwater pumps or for the auxiliary feedwater control l valve were disconnected from their intendt.d mounting locations. These I were examples of important, but non-essential systems (i.e.o local !
manual controi of the pumps and v61ves could be used ff.the air-system )
were damaged) which could be easily upgraded to increase the plants j ability to remove decay heat following an SSE.
plant 2 - Non-Seismically Qualifried AFW System (Operating License issued in 1963)
At least two supports to the auxiliary feedwater piping were either not connected to piping'or not connected at the mounting location. ' j The bolts securing the t.uxiliary feedwater water supply tank (deminer- l alized water tar.k) to its pad were rusted and not tightened down (i.e.. I 3/4 inch space between the support and nut intended to hold it down). {
/ S Also, a long span of 2-inch piping was found having vertical support Q) only to which lateral support could easily be provided.
plant 3 - Non-Seismically) issued in 1967 Qualified AFW System (Operating License Three areas wer e identified for which remedial actions could be implemented in a reasonably short time. The fit st of these was one of the station's battery racks. While the existing racks provided for some degree of lateral seismic and resistance, the configuration did not appest to have <
a level of integrity commensurate with the important of the batteries to plant safety. These racks appeared flimsy in comparisan to these which were installed to current seismic design criterie prescribed by the licenrn for safety related systems. j The second area was the suction side of the Auxiliary Feedwater pum?s which consists of a single header from the condensate storage tank-
- The header has some lateral support, however, the condensate storage tank was not galified. The tar.k h noc anchored at ite base and the j permanent alternate supply is through the tank. There is a capability '
to install is bose from e qurlified water source to the pump suction I ed bypasc the condensate stcrage tenk. Keeping such a hose in place {
would enhance system reliability.
The third area was the main iristrumantation and contro) panels in the control roon. These ere supprted at the bottom by a concrete channel
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v and at the top by stee" knee braces anchored to the concrete ceiling
' with expansion anthon. The requirements of IE Bulletin 79-02 had not I
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been applied to these anchor bolts and base plates. Conformance with the IE Bulin :; requirements for the factors of safety and considering _ !
base plate flexibility for the original seismic loads would increase l reliability. Also, some loose and missing screws were noted in these panels which could be easily tightened and replaced.
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<n kvLANT: OCONEE 1, 2, 3 l
CHRONOLOGY: 1978 IDENTIFIED AS A USI 4/85 GENERIC LETTER 85-02 ISSUED TO ALL PWR'S 7/85 DUKE POWER RESPONSE TO G.L. 85-02 IMPROVEMENTS TO BE ACCOMPLISHED:
(~) j PRIMARY - SECONDARY LEAK RATE TECHNICAL SPECIFICATION LIMIT TO BE REDUCED FROM 10 GPM TO 1.0 GPM f
e a atc(h ' UNITED *TATES I.j,e][h E
& l NUCLEAR REGULt. TORY COMMISSION WASHINGTON, D. C. 20555 April 17,198,5.
%{%4.. .. + / g TO ALL'PWR LICENSEES OF OPERATI M 0.EACTORS, APPLICANTS FOR OPERATING LICENSES, AND HOLDERS OF CONSTRU G ON PERMITS, AND FT. ST. YRAIN s
o Gentlemen:
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SUBJECT:
STAFF RECOMMENDED ACTIONS STEMMING FROM NRC INTEGRATED PROGRAM FOR THE RESOLUTION OF UNRESOLVED SAFETY ISSUES REGARDING STEAM GENEPATOR TUBE INTEGRITY (GENERIC LETTER 85-02) i The Commission has recently approved issuance of this generic letter to all nuclear power plants utilizing steam generators, to obtain infortnation on their overall program for rteam generator tube integrity and steam generator tube rupture mitication. This information will allow the staff to assess the areas of concern addressed by the staff's recommended actions (see Enclosure 1) which were developed as part of the integrated program for the resolution of Unresolved i Safety Issues A-3, A-4 and A-5 regarding steam generator tube integrity. The
! staff's procram report, NUREG-0844 (draft report for comment), is provided as l' Enclosure 3. NdREG-0844 will be issued in final form following a 90-day period i for public comment. 1
! O Steam generator tube integrity was designated an unresolved safety issue (USI) in 1978 and Task Action Plans (TAP) A-3, A 4 and A-5 were established to evaluate I
L the safety significance of degradation in Westinghouse, Combustion Engineering i and Babcock & W'lcox steam generators, respectively. These studies were later f combined into one effort due to the similarity of many problems among the PWR vendors.
Staff concerns relative to steam generator tube degradation stem from the fact that the steam generator tubes are a part of the reactor coolant system (RCS) boundary and that tube ruptures allow primary coolant into the secondary system J where its isolation from the environment is not fully ensured. The leakage of 1 primary coolant into the secondary system has two potential safety implications j which were considered. The first is the direct release of radioactive fissici l products to the environment; and the second is the loss of primary coolant water j which is needed to prevent core damage. An extended, uncontrolled loss of I coolant outside of containment could result in the depletion of the inittel RCS l water inver tory and ECCS water without the capability to recirculate the water, t
An integrated prooran was initiated by the staff in May 1982 to consider initial
'l recommendations from the !!S1 effort, and to assess the lessons which could be
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learned from the four domestic SGTR events; PMnt Beach 1 in 1975: Surry ? in 1976; Prairie Island 1 in 1979; and Ginna in 1982. A number of potential require-ments for industry were identified and sub.iected to a value impact evaluation.
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V These analyses indicate that: the probability of core melt from events involving steam generator tube ruptures is not a major -tributor to total core melt risk; that steam generator tube ruptures are an important contributor to-the ,
probability of significant non-core melt releases; and that steam generator tube degradation <is a ma.ior contributor to occupational radiation exposure at PWR's. .
Based upon the results of the staff's integrated program, the staff has developed recommended actions in the following areas:
- 1. Prevention and Detection of Loose Parts and Foreign Objects
- 2. Stean Generator Tube Inservice Inspection
! 3. Secondary Water Chemistry Program l l
- 4. Condenser Inservice Inspection Program
- 5. Primary to Secondary Leakage Limit l 6. Coolant lodice Activity Limit
- 7. Safety injection Signal Reset 1
The staff's recommended actions have been found to be effective measures on a l plant specific basis for significantly reducing (1) the incidence of tube degradation, (2) the frequency of tube ruptures and the corresponding potential for significant non-core melt releases, and (3) occupational exposures, and are consistent with good operating and engineering practices.
Accordingly, operating reactor licensees and applicants for an operating license
! (this letter is for information on'y for those utilities that have not applied for an operating license) are requested to furnish to the Director, Division of Licensing, Office of kuclear Reactor Regulation, no later than 60 cays from the date of this letter, a description of their overall programs for assuring steam ganerator tube integrity and for steam generator tube rupture mitigation. The
, description of the plant specific programs should be sufficiently detailed to I
allow the staff to compare these actions with the staff recommended actions as presented in Enclosure 1.
l The staf f recommended actions above do not address suoplenental tube sample -
l inspections 'or the case where Catecnry C-2 results are obtained during initial sample inspections. The sta#f initially considered a proposed upgrading of ,
existing Technical Specification requirements in this area (see Section P.9.1 -
of the enclosed &af t NUpEG-0844), and this proposal was commented upon extensively by ir.dustrv. The staff has concluded that the particular proposal considered was not warranted as e neneric staff onsition nr recnnmendation.
However, as part of the information reaupsted by tHs letter, licensees and s' applicants are requested to describe practices thev employ to ensure edequate inspection samples are teken in tbc rvent that Catenory C-2 results are I obtained durina initial sampling. The information requested is described in additional detail in Enclosure 2.
o
.ne staff will review each response from licensees ant' e nlicants, and evaluate the overall effectiveness of plant-specific programs to prevent and mitrgate the occurrence of steam generator tube ruptures. The staff recognizes, however, that plants specific programs may differ from the staff recommended actions, and still be adequately effective. The results of the staff review will be reported directly to the Commission. The Commission has specifically requested that the staff include in its report the number and quality of the responses, noting in particular any utilities delinquent in providing the requested information and any recommended corrective actions.
The staff will continue to monitor licensees' commitments and programs relative to steam generator integrity and SGTP mitigation to determine if they are being effectively implemented. As has been true in the past, additional actions may become necessary in piant specific instances of extensive or severe degradation.
This request for information was approved by the Office of Management and Budget under clearance number 3150-0011 which expires April 30, 1985. Comments on burden and duplication may be directed to the Office of Management and Budget.
Report Manaoenent Room 3208, New Executive Office Building, Washington, D. C.
20503.
Mr. Emmett Murphy, Operating Reactors Assessment Branch, will be the point of contact. If you have ouestions or desire additional information, he can be Q reached on (301) 492-7457.
Sincerely,
/711 ugh L. Thompson, Jr. Dire 'r Div s on of Licensin Office of Nuclear Reactor Regulation
Enclosures:
- 1. Staff Recommended Actions Stemming from NRC Integrated Prooram for the Resolution of Onresolved Safety issues
- . RecardinC Stean Generator Tube Intesrity P. Request for Information
'. Concerning Category C-2 Steam Generator Tube Inspections 1
- 3. NUPEG-0844 (Draft Report For Comnent). NRC Integrated i Program for the Resolution (p of Unresolved Safety issues
- 4. List of Generic Letters L_______________________ __.
ENCLOSUPE 1
-f STAFF DECOMMENDFD ACTIONS AND REVIEW Gti!DELINES
. STEMMING FROM NRC INTFGDATED PROGRAM FOP THE RESOLUTION OF llNDFSOLVEn SAFETY ISSUES _
, PEGADDING STEAM GENERt. TOR TI'PE INTEGRITY 1.a PREVENTION AND DETECTION OF LOOSE PARTS (INSPECTIONS)
Staff Recommended Action Visual inspections-should be parformed on the steam generator seconderv side in the vicinity of tha tube sheet, both alono the entire periphery of the tube bundle and along the tube lane, for puronses of identifyirp j loose parts or foreign ob4ects on the tubasheet, end external damage to 1 peripheral tubes .4uct abnve the tubeshaat. An appropriate optical device should be used (e.g., mini-TV camera, fiber optics). Loose carts or foreign ob,iects which ere found should be renoved frnn the steam cenerators. Tubes observed to have visual damage shnuld he eddy current inspected and plugged if found tn be dafective.
Thase visual inspections should be performed: (11 fer all steam gener- !
ators at each plant Pt the next plannad outaqe #or eddy current testina, l I?i after any secondary side modifications, or repairs, to steam generator S internals. and (3) wher addy current indicatinrs are found in the #ree span onetinn of peripharal tubas, unless it has been established that the l-irdication did not result ' rom danaae bv a loose pr.rt nr foref on oh.iect.
For PWR OL applicants. such inspections shnuld he part nf the preservice j l inspection. :
For stear eenerator mndels where certain segments nf tha peripheral reginn l can be shnwn not tn be accassible to an appropriate optical device.
licensees and applicants should implement alternative actions to address l these inaccessible areas, as appropriate.
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Licensees should take appropriate precautions to minimize the potential for corrnsion while the tube burdle is exrnsed to air. The presence o' ;
chenical species such as sulfur ray angravate this pntential, ard may make exposure to the atmnsphere ir.edvisabin until appropriate reredial neesures are taken.
Referance Sectinn ?.1 of NuDEC.n84a.
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2-C 1.b PREVENTION AND DETECTION OF LOOSE PARTS (OVALITY ASSURANCE) ,
Staff Recommended c, tion Quality assurance / quality control procedures for steam generators shnMd' '
be reviewed and revised as necessary to ensure that an effective system exists to preclude introduction of foreign ob.iects into either the primary or secondary side of the steam generator whenever it is opened (e.g., for
- maintenance, sludge lancing, repairs, inspection operations, modifications).
As a minimum, such procedures should include: (1) detailed accountability procedures for all tocis and equipment used during an operation, (2) appropriate controls on foreign obiects such as eye glasses and film
' badges, (3) cleanliness requirements, and (4) accountability procedures for components and parts removed from the internals of ma.ior components (e.g., reassembly of cut and removed components).
Reference
, Section 2.1 of NUREG-0844 o O a
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3-2.a INSERVICE INSPECTION PROGRAM (FULL LENGTH TUBE INSPECTION)
Staff Recommended Action The Standard Technical Specifications (STS) and Regulatory Guide 1.83, Part C.2.f. currently define a U-tube inspection as meaning an inspection of the steam generator tube from the point of entry on the hot-leg side completely around the U-bend to the top support of the cold-leg side.
The staff recommends that tube inspections should include an inspection of the entire length of the tube (tube end to tube end) including the hot leg side, U-bend, and cold leg side.
This recommended action does not mean that the hot leg inspection sample and the cold leg inspection sample should necessarily involve the same tubes. That is, it does not preclude making separate entries from the hot and cold leg sides and selecting different tubes on the hot and cold leg sides to meet the minimum sampling requirements for inspection.
Consistent with the current STS requirement, supplemental sample inspections (after the initial 3% sample) under this staff recommended ection may be limited to a partial length inspection provided the inspection includes e those portions of the tube length where degradation was found during initial sampling.
Reference Secticn 2.2.2 of NUREG-0844
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2.b INSERVICE INSPECTION PROGRAM (INSPECTIin .i;TERVAL)
Staff Recommended Action' .
The maximum allowable. time between eddy current _ inspections of an individual steam generator should be limited in a manner consistent with Section 4.4.5.3 of the Standard Technical Specifications, and in addition should not extend beyond 72 months.
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1 Reference Section 2.2.4 of NUREG-0844.
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l 3.a SECONDARY WATER CHEMISTRY PROGRAM
- Staff Recommended Action I
Licensees an'd applicants should have a secondary water chemistry progran (SWCP) to minimize steam generator tube degradation, j i
The specific plant program should incorporate the secondary water chemistry guidelines in SGOG Special Peport EPRT-NP-2704, "PWD Secondary Water !
Chemistry Guidelines," October 1082, and sh'ould address measures taken to mininiza steam generator corrosion, including materials selection, chemistry !
I limits, and control methods. In addition, the specific plant procedures should include progressively more strinoent corrective actions for out-of-specification water chemistry conditions. These corrective actions should include power reductions and shutdowns, as appropriate, when excessively corrosive conditions exist. Specific functional individuals should be identified as having the responsibility / authority to interpret plant water chemistry information and initiate appropriate plant actions to adjust l
I chemistry, as necessary.
The raferenced SGOG guidelines above were prepared by the Steam Generator Owners Group W.ater Chemistry Guidelines Committee and represent and consensus l
1 opinion of a significant portion of the industry for state-of-the-art i _
secondary water chemistry control.
Reference Section ?.5 of NUREG-0844 l
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3.b CONDENSER INSERVICE INSPECTION PROGRAM Staff Recommended Action -
Licensees should implement a condenser inservice inspection program.
The program should be defined in plant specific safety-related procedures
- and include:
- 1. Procedures to implement a condenser inservice inspection program that will be initiated if condenser leakage is of such a magnitude that a power reduction corrective action is required more then once per three month period; and
- 2. Identification and location of leakage sourcels), either rater or air;
- 3. Methnds of repair of leakage; 4 Methodology for determining the cause(s) of leakage;
- 5. A preventive maintenance penaram.
Reference
() Saction ?.6 of NURrr..n844
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4 -FAIMARY TO SECONDARY LEAKAGE LIMIT
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Staff Reconnended Action All PWRs that have Technical Specifications limits for primary to secondary leakage rates which are less restrictive than the Standard Technical Specifications (STS) limits should implement the STS limits.
Reference Section 2.8 of NUREG-0844.
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- 5. C0bLAN1'.'0INEACTIVITYLIMIT Staff Recommended Action
- l PWRs that h' ave Technical Specifications limits and surveillance for l'
coolant iodine activity that are less restrictive than the Standard ,
Technical Specification (STS) should implement the STS limits. Those plants identified above that also have inw head high pressure safety injection pumps should either: (1) implement iodine limits which l are 20% nf the STS values, nr (2) implement reactor coolant pump trip I criteria which will ensure that if offsite pnwer is retained, no loss of forced reactor conlant system flow will nr. cur for steam generator tube rupture events up to and includina the design basis double-ended L
break of a single steam nenerator tube, and implement iodine limits consistent with the STS.
Reference Section 7.9 of NUREG-0844 O ,
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- 6. SAFETY INJECTION SIGNAL RESET Staff Recommended Action The control logic associated with the safety injection pump suction flow path should be reviewed and modified as necessary, by licensees, to minimize the loss of safety function associated with safety injection reset during an SGTR event. Automatic switchover of safety injection pump suction from ,
the boric acid storage tanks (BAST) to the refueling water storage tanks i should be evaluated with respect to whether the switchover should be made -
on the basis of low BAST level alone without consideration of the condition of the SI signal.
Reference Section 2.11 of NUREG-0844.
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l ENCLOSURE 2
)
RE00EST FOR INFORMATION CONCERNING CATEGORY C-? .
STEAM GENERA 10? TURE INSPECTIONS Information Requested The enclosed dre.ft NUREG-0844 Section 2.P.1.? describes certain limitations which the staff believes to be inherent in the precent Technical Specification steam generator 151 requirements pertaining to Category C-2 inspection results.
Licensees and applicants are reouested to provide a description of their current policy and actions relative to this issue and any reennmendations they have concerning how existing Technical Specification steam generator IST requirements pertaining to Catetnry C.? insnection results enuld be improved to better ensure that adequate inspections will be performed. This description should include a resonnse to the following questions:
- 1. What factors do, or would, the licensee nr applicant consider in determining (a) whether additional tubas chould he inspected beyond whet is recuired by the Technical Specifications, (b) whether all staan aenerators should be included in the incpectinn pronram, and (c) when the steam generators should be reinspected.
O P. To what extent do these factors include consideration of the degradation mechanism itself and its potential for causing a tube to be vulnerable to rupture during severe transients or postulated accident before rupture or leakeae of thet tube occurs during normal operation.
Reference Section P.? nf HUPEG-0844 i
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RESOLUTION OF GENERIC ISSUES t]
NO FORMAL, S1EP-BY-STEP METHOD "DIFFERENT STR0KES..."
" GENERIC" METHOD UNDESIRABLE
" SQUARE PEG" IN "ROUND H0LE.. "
INAPPLICABLE FORMS, ETC.
ALL USI's ARE UNIQUE
\
, I'LL NARRATE HOW A-49 (PTS) WAS DONE l
R. WOODS FOR ACRS SUBCOMMITTEE i SEPTEMBER 30, 1987 )
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LJ DISCOVERY PHASE "WHAT IFS" FOLLOWED 1978 EVENT DETERMINISTIC CALCULATIONS - EVENT COULD FAIL VESSEL RISK UNKNOWN
) SYSTEMS ASPECTS WERE LEAST WELL UNDERSTOOD RECRUITED * " SYSTEMS EXPERT"
- (0UTSIDE CROWN BOOKS IN BETHESDA)
(A,)
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t-EARLY WORK COMMENT ON ORNL REPORT k
"USI DESIGNATION" PAPERWORK (DECEMBER, 1981)
TAP (* APRIL, 1982)
CO-0RDINATE EFFORTS NRC (20 - 30 PSY)
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eNL ("c0nSEautscES". 5400x)
INDUSTRY (0.G.'s) (ONLY PRAs COMPLETE WHEN RULE DRAFTED)
CONGRESSIONAL HEARING (JUNE, 1982)
O
g J TECHNICAL " CLOSURE" SECY-82-465 TO COMMISSION (NOVEMBER,'1982)
PTS RISK ESTIMATED, BASED ON EFFORTS AB0VE, PLUS PART OF: l 1
HSST ($10M/YR) l INCLUDED COMPLETE OUTLINE OF RECOMMENDED NEW RULE T0:
ESTABLISH EMBRITTLEMENT SCREENING LIMIT ENCOURAGE VOLUNTARY FLUX REDUCTION REQUIRE EMBRITTLEMENT REPORTING O -
REQUIRE EXTENSIVE ANALYSES AND COMMISSION APPROVAL TO OPERATE OVER LIMIT I
WITH ACRS AND CRGR AGREEMENT, WE WERE TOLD AT COMMISSION MEETING (DECEMBER 9, 1982):
"SECY-82-465 IS APPROVED" "GO MAKE A RULE..."
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FORMAL " CLOSURE" ELAPSED MONTHS TOOK UNTIL JULY,.1985 TO 00 IT!
12 DECEMBER 9, 1982, WE STARTED PROCESS, WITH BROAD STAFF SUPPORT WROTE " PROPOSED RULE" PACKAGE (T0OK s 1 MONTH)
REVIEWED, CHANGED, REVIEWED. . . ('.' DISASTER ON BUS")
l CONCURRENCE BY NRC STAFF, STAFF LAWYERS CONCURRENCE BY ACRS, CRGR 19 JULY 15, 1983, PROPOSED RULE (SECY-83-288) TO' COMMISSION REVIEWED BY COMMISSION STAFF AND LAWYERS 21 -
SEPTEMBER 5, 1983, CHAIRMAN PALLADIN0 APPROVAL (FIRST) 23 -
NOVEMBER 16, 1983, COMM1SSIONER GILINSKY APPROVAL (LAST) 25* JANUARY 13, 1984, FORMAL COMMISSION APPROVAL (NO SIGNIFICANT CHANGES) 26 FEBRUARY 7, 1984, PUBLISHED " PROPOSED RULE" 29 MAY 7, 1984, PUBLIC COMMENT PERIOD ENDED WR0TE " FINAL RULE" PACKAGE (NO SIGNIFICANT CHANGES) 38 FEBRUARY 20, 1985, FINAL RULE (SECY-85-60) TO COMMISSION 42 JUNE 20, 1985, FORMAL COMMISSION APPROVAL (N0 SIGNIFICANT CHANGES) 43* JULY 23, 1985, FINAL RULE PUBLISHED
^
Was 62 months including Regulatory Guide. Would take longer now.
(Average USI time 54 months, range 45 to 81 months).
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COMMENTS
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\_) i CONFIRMATORY WORK BECAME AVAILABLE DURING PERIOD FLUX REDUCTION WAS STRONGLY ENCOURAGED DURING PERIOD (CONSIDERABLE SUCCESS)
SIGNIFICANT CHANGES DURING PROCESS?
CHANGES WORTH TIME REQUIRED?
SHOULD PROCESS HAVE ALL THESE STEPS, INCLUDING PUBLIC COMMENTS?
V WHY SO LONG?
LARGE ORGANIZATION, TECHNICAL AND ADMINISTRATIVE INVOLVEMENT WIDESPREAD.
(
NO PART OF ORGANIZATION WILLING TO BE LEFT OUT.
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1 COMPLETION 4
l REGULATORY GUIDE PUBLISHED !
l JANUARY 16, 1986 FOR PUBLIC COMMENT 1 FEBRUARY 9, 1987 FINAL I
USI A-49 CLOSED, BUT: l 1
" PTS" NOT FINALLY RESOLVED R.G. 1.99 REVISION
" PTS" NOT FINALLY IMPLEMENTED RULE DETERMINES WHEN ANALYSES REQUIRED
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WILL DETERMINE PLANT-SPECIFIC RISK NRC MUST THEN " RESOLVE PTS" FOR EACH EMBRITTLED PLANT PTS THUS REMAINS AN ISSUE, AT LEAST FOR LIFE EXTENSION DECISIONS.
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O 5 Discussion of e enosed ne.r-term Action.
(1) Proposed Rulemaking: The staff proposes to develop a notice of proposed rulemaking. The proposed rule
- would: establish an RT screening criterion of 270*F for axial welds, N 300*F for circumferential welds; require that licensees of all operating PWRs submit a determination of the present RTHDT values i
for their reacto'r vessels, and the estimated date at which the RT value will exceed the screening criter' ion; rhire licensees to implement such flux
/ reduction programs as are feasible and necessary to l avoid reaching the screening criterion before v Ss'd}C'y expiration of,the operating license; and require licensees of operating PWRs for which the RT
)
valueisprojectedtoexceedthescreeningcNerion '
(& before the expiration of the operating license to dod submit a plant-specific PTS safety analysis, of the V type outlined in Section 9 of Enclosure A, three years before the screening criterion is exceeded, or
- one year after the effective date of the regulation, lj
,f hichever is later. For purposes of comparisch with the screening criterion, the rule would require j p,W(f calculatiipn of RT values in the manner described iaSecticasofEmosureA. During the public
.O r-omment period on the proposed rulemaking, the staff j p: y would develop more detailed guidance on the, 8(r.
Q plant-specific analyses to be required and on the acceptance criteria to be used in judging the acceptability of the results. Since most of the j ,g
\
l technical bas,is for such a rulemaking has already '
)
been assembled in Enclosure A and the documents referenced therein, the staff believes that the notice of proposed rulemaking could be prepared for Comission approval in 'about six months or less.
RECOMMEN0ATIONS: We recommend that the Commission:
(1) Direct 'the staff to ' develop a Noticeof Proposed' Rulemaking,that would establish an RT screening l criterion, require licensees to submiUDfresent and -
l
. projected values of RT N require implementation i of such flux reduction ko, grams as are feasible and needed to avoid reaching the screening criterion, and require plant-specific PTS safety analyses when plants are within three calendar years of reaching )
the screening criterion, i I
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