ML20235N647

Summary of 870527 ACRS Subcommittee of Generic Items Meeting in Washington,Dc to Discuss NRC Processing of Generic Issues & Usi.List of Documents Submitted,Presentation Schedule & Presentation Matl Encl

ML20235N647
Person / Time
Issue date:	06/15/1987
From:	Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
References
ACRS-2504, NUDOCS 8707200161
Download: ML20235N647 (55)

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SUMMARY

/ MINUTES OF THE i

ACRS SUBCOMMITTEE MEETING ON THE GENERIC ITEMS j MAY 27, 1987 ) WASHINGTON, D.C. INTRODUCTION The ACRS Subcommittee en Generic Items held a meeting on Wednesday, May ) 27, 1987, at 1717 H Street, N.W., Washington, D.C., to discuss the NRC l Staff's process involved in identifying, prioritizing, resolving, and I implementing generic issues and Unresolved Safety Issues (USIs). The entire meeting was open to public attendance. Mr. Sam Duraiswamy was 1 the cognizant ACRS Staff for this meeting. A list of documents submitted to the Subcommittee is included in Attachment A'. A copy of the presentation schedule for the meeting is included in Attachment B. ATTENDEES l ACRS: C. P. Siess (Subcommittee Chairman), J. C. Ebersole, C. Michelson, D. W. Moeller, F. J. Remick, and l C. J. Wylie SamDuraiswamy(CognizantACRSSte.ff) Principal NRC Speakers: W. Minners, R. Emrit, W. Schwink, F. Hebdon, and C. Fitzgerald l EXECUTIVE SESSION Dr. Siess, the Subcommittee Chairman, convened the meeting at 8:30 a.m. and stated that the purpose of this meeting was to hold discussions with the NRC Staff with respect to the process dealing with generic issues and USIs ard gather information for use by the ACRS in preparing a report to the Commission on the effectiveness of this process. In l l prsICHM ED ORIGINAL Certified B?/ 4

t s Generic Items Meeting Minutes May 27, 1987 i addition, the Subcommittee will hear a brief report on the Safety Issues ManagementSystem(SIMS). He said that the Subcommittee had received i neither written comments nor requests for time to make oral statements from members of the public. PREAMBLE Prior to holding discussions with the Staff on the scheduled items, Dr. Siess provided a preamble. He'said that in a memorandum to Mr. Ward, dated September 18, 1986, NRC Chairman Zech reque=i.eu, ouvos v6her i things, that the ACRS-l " Advise the Comission on the effectiveness of programs which l address generic and unresolved safety issues." j i l Subsequent to receiving the above memorandum, the ACRS met with the Comission in December 1986. At that meeting he asked the Comission:

• Whether the ACRS should look at the effectiveness of the Staff's program in terms of how fast generic issues are prioritized, resolved, and implemented.

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• Whether it should look at it in tenns of the increase in the safety of operating plants resulting from the implementation of the resolved generic issues and USIs.

The Comission suggested that the ACRS-try to measure the effectiveness I of the program in terms of how fast generic issues are prioritized, resolved, and implemented and also in terms of.the enntribution to plant safety resulting from the implementation of the resolved generic issues and USIs. Dr. Siess said that at the subject meeting he plans to discuss and understand the process involving identification, prioritization. l .l

y' Generic Items Meeting Minutes May 27, 1987 resolution, and implementation of generic issues and USIs. At the-second meeting, the Subcommittee may look at selected generic issues and USIs and follow them through the entire process, with emphasis on the implementation process, to determine the efficiency of the process and also the contribution to plant safety resulting from the implementation of the resolved issues. Dr. Siess stated that he does not believe there are too many things I wrono in the process up to the point of implementation. He is not sure L whether there is really anything wrong with the implementation process either. Further, it is not clear how the plant-specific issues and the issues resulting from the resolution of generic issues and USIs have been integrated. Mr. Michelson comented that over the past few months he has been observing that scme issues that had been resolved only partially had l been classified as resolved. He believes that until the remaining parts of the issues hid been resolved, they should not be declared as re-l solved. He is concerned also about the fact that only part of the issues that had been resolved are going tu be implemented in new plants. He believes that the remaining parts of the issues should be resolved and considered for implementation in new plants. Mr. Michelson stated that there are several generic issues and USIs that are inter-related. For example, USI A-17. " Systems Interactions" interplays with the issue associated with control systems. Also, USI A-44, " Station Blackout", and USI A-45, " Shutdown Decay Heat Removal Requirements" fall into this category. He believes that the resolutions of such issues should be integrated very carefully. OVERVIEW OF THE GENERIC ISSUES PROCESS - MR. W. MINNERS Mr. Minners provided an overview of the process associated with generic issues (Attachment C, pages 1-3).

1 Generic Items Meeting Minutes May 27, 1987 He said that the Office for Analysis and Evaluation of Operational Data (AE0D) has the primary responsibility for identifying new generic issues. However, RES, NRR, ACRS, etc., also identify new generic l issues. In fact everybody is involved in the identification process. RES has the primary responsibility for prioritizing and resolving generic issues. These functior,s, formerly under NRR, have been I transferred to RES in the new organization. Imposition of the fixes 4 resulting from resolved generic issues and USIs is done by NRR. Implementation of the results of the resolved issues is the responsibil-l ity of the licensees. The project managers in NRR have the responsibil-ity to ensure that fixes applicable to their plancs have been incor-porated by the licensees. Verification as to whether licensees had implemented all the fixes correctly is done by NRR and regional offices. j l Mr. Minners expressed his appreciation for the attention being paid by the ACRS on matters associated with generic issues. However, he is concerned that the ACRS has been paying more attention to the technica', issues and less attention to the overall process. He believes that an understanding of the overall process is very important. Further, ACRS has been involved in reviewing the adequacy of the proposed priovity rankings for all generic issues and also the technical resolution of certain important generic issues. ACRS coments on these matt (rs have l been helpful. He believes that the implementation process is a very difficult and important one and suggested that the ACRS get involved in this process also. l Mr. Ebersole asked at what stage of the process cost-risk-benefit analysis is done. Mr. Minners responded that such analysis is done at the prioritization, resolution, and imposition stages. 1 l Stating that personnel working at the plants may have some valuable suggestions, based on their involvement in the day-to-day operation of the plant, for resolving a generic issues, Dr. Remick asked how the l l

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,a - t,_ Generic Items Meeting Minutes May-27. 1987 Staff factors such suggestions into the resolution process. Mr. Minners.- responded that all~ the information associated with the resolution of-generic issues have been sentlout for public and industry comments. (They pay much attention to the comments'and suggestions received from the public and.the industry, i Nr. Ebersole asked whether all the resolved issues had been implemented. j Mr. Minners responded that several resolved issues still remain to be implemented. He mentioned that some of the resolved issues do not impose any fixes and issues of that category do not get implemented. Mr. Michelson. asked about the procedures being used to handle-partially resolved generic issues. Mr. Minners responded that those parts of.the issues that are not resolved are normally redesignated as.new generic-issues as soon as possible and reprioritized. q Dr.'Moeller asked whether the licensees are required to implement the ~ fixes resulting from the resolution"of generic issues within a specified period of time. Mr. Minners responoed that they normally-do not impo.se time limit for implementation. They try to work with the licensees to come up with a schedule for implementation without affecting the plant operation. RES PRESENTATION Prioritization Process - Mr. R. Emrit i Mr. Emrit reviewed briefly the prioritization process (Attachment C. pages4-11). 'He said that the Advanced Reactors and Generic Issues Branch in the Division of Regulatory Applications is responsible for prioritizing - 9eneric issues. -The safety concerns of a specific generic issue are .{ defined clearly first and then prioritized using the Value/ Impact - .l s

l ) i Generic Items Meeting Minutes May 27, 1987 Methodology described ir. NUREG-0933, "Prioritization of Generic Safety Issues." If there is a need for technical assistance to obtain addi-tional data, such as frequency estimates, consequence estimates, cost estimates, etc., for use in the prioritization process, they normally use the Pacific Northwest Laboratories for such purpose. ) Based on the evaluation, generic issues are ranked in the following categories: HIGH MEDIUM LOW { DROP j In addition, some of the issues are classified as " Licensing Issues" and " Regulatory Impact Issues." These are not considered to be safety j issuee i As soon as an issue is prioritized and peer review process is completed, related information is sent to the regional offices and the ACRS for review and cumment. That information is also put in the Public Document Room to enable the public and industry to provide comments. Once the priority ranking of an issue is finalized, it is included in the supple-ment to NUREG-0933. Mr. Michelson stated that when an issue is first identified, there seems to be a tendency to limit the scope of the issue so that it can be handled easily. For example, although the real concern outside the containment might be the loss of pressure beundary, it was not handled as pressure boundary failure; instead, it was handled as pipe failure. He asked why issues are not identified with a broad scope so as to include the real concerns. Mr. Minners respnnded that it is up to the L

j 4 i Generic Items Meeting Minutes May 27, 1987 j originator of the issue to define the scope of the issue correctly., ] He does not know why that issue was not identified as a pressure boundary failure issue. . Mr. Emrit discussed briefly the Staff's responses to the Subcommittee questions included in the agenda (Attachment C, pages 5-10). In summa-ry, he said that there are about 40 generie issues identified per year, including 4 issues to be reprioritized. Of this, about 30 issues are prioritized per year by four Staff engineers and the remaining 10 issues are added to the backlog list. The average time to prioritize a generic issue is about 6 months. There are 61 issues, identified sometime ago, that still remain to be prioritized. Based on a preliminary evaluation of these issues, they found that most of these issues do not have major safety significance. He believes that the prioritization process is effective because it benefits the Staff, industry, and the public. Mr. Michelson asked whether there is any effort made periodically, after j gaining more information on the issues that were dropped, to make sure that they are still not worth pursuing. 'Mr. Minners responded that they have reprioritized some of tnose issues after obtaining more informa-tion. However, it is not done on a systematic basis. j ihl .Mr. M c e son commented that it would be advisable to look at the issues with Low and Drop priority rankings periodically to make sere that there is no new information that would change the priority rankings of these issues. Dr. Siess asked whether they would go back and look at the applicabil-i ity of the Low and Drop category issues as well as other issues for new reactor designs, Mr. Hernan responded that the program at the Electric Power Research Institute (EPRI) is intended to look at the applicability of all generic issues to new reactor designs.

i N Generic Items Meeting Minutes May 27, 1987 1 Stating.that the list of backlog issues will keep on increasing unless something is done, Dr. Siess asked whether the Staff has asked for additional resources to handle these issues. Mr. Minners responded that they are in the process of making some recommendations to the Executive . Director for Operations (ED0) on how to improve the whole process. If i approved, that will take care of this problem. Dr. Siess asked whether they ' allocate more resources for the resolution of USIs than for the High-priority generic issues. Mr. Minners responded that equal emphasis is given to both. However, USIs have score-visibility because they have to submit an annual report to' the Congress i on the progress being made in resolving them. Dr. Siess asked on what basis the Staff claims that the prioritization process is effective. Mr. Emrit responded that it is considered to be i effective based on the following: 1 s l l I

• It helps to identify those issues with major safety significance, thereby allowing the Staff to concentrate on more important issues.
• It provides proper documentation of issues so as to prevent the possibility of the same issues getting raised again in the future.

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• It helps to integrate issues of similar type.

1 i l ' It prevents the Staff from spending resources on issues with less i or no safety significance. I

• It allows only important safety issues to go into the resolution

) process.

• It helps the industry to understand which issues are considered important by the NRC.

l i L__________________._______..________1. ij

7 j Generic Items Meeting Minutes May 27, 1987

• It prevents the industry fro'n spending time and resources on issues that are not important to safety.

J Resolution Process - Mr. W. Minners Mr. Minners discussed the resolution process associated with generic I issues and USIs (Attachment C, pages 12-20). He said that the following Branches / Divisions in RES are responsible for the resolution of generic issues and USIs. He mentioned that this function was in NRR under the old organization:

• Engineering Issues Branch / Division of Engineering 1
• Reactor and Plant Safety Issues Branch / Division of Reactor and j

Plants Systems

• Reliability and Human Factors Branch / Division of Reactoi and' Plant Systems He said that the Reliability and Human Factors Branch is responsible for i

the resolution of only those issues associated with human factors. Mr. Minners said that previously resources have been allocated for the resolution of only'High-priority issues and USIs. Fawever, since the whole resolution function is now under RES, he expr. cts that resources may also be allocated for the resolution of some 'Aedium-priority issues, i Resolution process starts with the develops.;.nt of a Task Action Plan (TAP) for a particular issue to be resolved. The TAP includes a clear definition of the scope of the issue and what needs to be done to accomplish that scope. Resolution of certain issues are sometimes done by National L. laboratories under a contract. = - - --------

l l Generic Items Meeting Minutes May 27, 1987 l Resolution of an issue includes intermediate resolution, technical resolution, and regulatory analysis. Intermediate resolution, which j includes issteance of a bulletin or generic letter to make the licensees aware of the problems immediately, does not normally apply to all l issues. It is done on an ad hoc basis as warranted, j l Once an issue is considered resolved, associeted information will be sent to other offices for review and comment. After the completion of l the review process, it is published in the Federal Register for public comment. After the public coment period, the coments received are resolved and changes made, as appropriate, and sent for review by other j offices once again. After this review, it gets approved and published in the Federal Register. Resolution of an issue may result in the development of a new rule or regulatory guide or changes to an existing rule, regulatory guide, or standard review plan. Sometimes, a generic 1 i letter will be issued to all licensees notifying them of the results of { resolution of an issue and what needs to be done. l j Mr. Minners said that, based on experience, the minimum time to resolve a USI is 45 months; maximum time 83 months; and average time 54 mpnths. For resolution of generic issues, the minimum time is 4 months; maximum time 51 months; and average time 28 months. I He said that as of May 1987, there are 69 issues, including 9 USIs, still remaining to be resolved. So far,, 77. percent of the prioritized l items had been resolved. He believes that the resolution process is l Very effective. l l Mr. Minners discussed briefly some of the incidents that might have been j prevented if certain generic issues and USIs had been resolved and implemented sooner (Attachment C, page 21). l

Generic Items Meeting Minutes May 27, 1987 Dr. Siess commented that-it seems that the ACRS does not always get the 1 i resolution packages for all resolved generic issues. He suggested that 4 the Staff make sure that the ACRS gets copies of all information on resolved issues. Dr. Remick asked whether the Staff has ever held any meetings with reactor vendors and licensees to obtain'their opinions on the possible { or proposed resolution for an issue. Mr. Minners responded that they { hold such meetings-frequently. For example, they have fad several I meetings with such people on USI A-44, " Station Blackout," USI A-45, I l " Shutdown Decay Heat Removal Requirements," and USI A-46, " Seismic Qualification of Equipment in Operating Plants." l l l Stating that fixes resulting from the resolution of certain issues do 1 l r.ot always apply to all plants but may apply only to certain plants, Dr. l l Remick asked how that situation is handled by the Staff. ' Mr. Minners l 1 responded that under such circumstances, a generic letter will be sent l l to all licensees describing the' generic resolution of the issue, and detailed requirements will be sent to the licensees of those plants that are affected. I Mr. Michelson commented that in some cases the process seems to be ) breaking down. For example, the analyses done for USI A-45 concerning fire did not account for system interaction effects resulting from inadvertent actuation of fire protection systems, propagation of heat and smoke, etc. He is not sure which generic issue or USI is integrat-ing all such issues associated with fire. Mr. Minners responded that a good regulatory analysis shculd. address such issues raised by Mr. Michelson. Mr. Michelson commented that it seems that all regulatory analyses are q l really not well written. Mr. Minners said that it takes a lot of time to write a regulatory analysis and he is not sure it is always done

y; ] Generic Items' Meeting Minutes May 27, 1987 well. He believes that mch things are not an indication of deficiency { in the process but it is an indication of the deficiency in the execu-l tion of the process. Dr. Siess asked whether the Staff believes that they are as effective as they could be 'in defining the scope of issues that need redefinition. Mr. Minners responded that it is difficult to say. It is very hard to think of all important technical issues to be included in the scope, i-If the scope is too broad, it would be hard to handle. They have been trying to achieve some balance by having the scope small enough to j i handle but large enough to include important issues. However, they are not always successful in achieving this balance. Dr. Siess said that the Subcommittee needs to pay more attention to how l they divide an issue for easy resolution and at the same time keep them broad enough to be meaningful. l l Nr. Wylie commented that since several important issues seem to be { subsuined in USI A-45, he believes that this USI should be resolved as soon as possible, even before resolving USI A-44. The Staff should allocate adequate resources to resolve this issue sooner. 1 I Mr. Michelson asked whether they have given any consideration to how the resolution of a generic issue would apply to future plants.. Mr. Minners responded that at present they are concerned only about operating-plants. I i Mr. Michelson suggested that sometime in the future the Subcommittee discuss the generic issue process as it applies to future plants. Dr. Siess stated that since there are only two meetings allocated to the Subcommittee to handle this assignment, it would be better to 'look at the effectiveness of the process as it relates to existing plants. ~ i ~

i 1 l Generic Items Meeting Minutes May 27, 1987 l NRR PRESENTATION 1 Implementation Process - Mr. W. Schwink l Mr. Schwink reviewed the implementation process (Attachment C, pages 22-28). He said that this process is divided into three steps: i Imposition Implementation Verification Imposition of the requirements resulting from the resolution of generic issues and USIs is the the responsibility of NRR. Implementation is the responsibility of the licensees, and verification is the responsibility of NRR and regional offices. Inspection, Licensing and Research Integration Branch of the Division of Program Management, Policy Development, and Analysis in NRR is responsible for coordinating the implementation activities. 1 Mr. Schwink said that sometimes imposition of a resolved item is done in two parts: short-term action, and long-term action. If it is de-i termined that there is a significant safety problem and something needs to be done immediately, a short-term action will be imposed. 1 Imposition of the technical resolution of an issue is done through legislative proposals, rulemaking, order, policy statement, regulatory guidances generic letter, and bulletin. Other options for disposition of technical resolution include information notice, licensing guidance, and inspection guidance, i The Project Managers in NRR are responsible to ensure that implementa-tion of all issues applicable to the plants for which they are respon-sible is done correctly by the licensees. The Project Managers work with the licensees to develop priorities (High, Medium, and Low) and a schedule for implementing the applicable issues.

Generic Items Meeting Minutes May 27, 1987 Mr. Schwink said that the maximum time for imposition of high priority items is.131 months; minimum time 5 months; and average time 41 months. The maximum time taken by the licensees to implement-these issues is 42 months; minimum time one month; and average time 28 months. For medium priority issues, maximum time for imposition is 130 months; minimum time 2 months; and average time 45 months. <For implementing these issues, the maximum time is 69 months; minimum time one month;.and'- average time 30 months. Mr. Schwink discussed briefly the status of the impicsentation of the resolved issues (Attachment C, page 28-31). There are 387 issues technically resolved. Of these, 285 have been imposed on all affected plants and 198 have been implemented. l He said that as of May 22, 1987, there are 17,067_ plant level items resulting from the resolution of generic issues and USIs. Of these 14,280 have been implemented and 11,970 have been verified.. Mr. Schwink said that the new Director of NRR is going through all of l the outstanding issues that need to be implemented in each plant. He emphasized that under the new organization, the implementation process l will be improved. Dr. Siess asked who decides which plant should implement which issues. Mr. Schwink responded that at the resolution stage it is normally. decided which issues-should be implemented at which plant. Dr. Siess asked who prepares the generic letter to inform the licensees about_ the results ^f the resolution of an issue. Mr. Schwink responded that the Gelleric Communications Branch in the Division of Operational Events Assessment is responsible for preparing such a letter, e s.-

V. t Generic Items Meeting Minutes May 27, 1987 Dr. Siess asked what proportion of generic issue resolutions results in hardware changes in a plant as opposed to procedural or some other changes. Mr. Schwink responded that, in his judgment, about 75 percent of the resolutions result in hardware changes. Mr. Michelson comented that the flow diagram (Attachment C, page 22) that describes the generic issue resolution / implementation process indicates that when a decision is made not to impose any new require-l ments as a result of the resciution of a generic issue that decision is 1 not going to be notified to the ACRS. He believes-that whatever the nature of the decision is it should be notified to the ACRS. Mr. Hernan stated that the Memorandum of Understanding (M00) between the ACRS and the EDO on Rulemaking and Policy making Activities does not require that items associated with generic issues should be sent to ACRS for review. Dr. Siess commented that the ACRS has always been more inter 6sted in the things that the Comission decides not to do something about thaa in the things they decide to do something about.. ACRS is always more concerned about omissions than commissions. When the list of generic issues identified by the ACRS was combined with the NRC Staff's list of generic issues, the ACRS was under the impression that it would be kept informed of how generic issues were disposed of. He does not believe that the existing NOU is really applicable to this case. However, if the ED0 feels that this issue should be included in the.MOU, he is willing to l write a new MOU to cover the generic issues. He said that the Staff should submit all the information associated with the generic issues to the ACRS, irrespective af the Staff's decision whether to pursue or'not. The ACRS will decide which issues it wants to review in detail. i l Dr. Siess requested that the Staff send to the.ACRS information associ-sted with the resolution of the last 15 generic issues. The Staff agreed to do so. l \\ 'l

l Generic Items Meeting Minutes May 27, 1987 i l In response to questions from the Subcommittee members, Mr. Schwink said ] that an Information Notice does not impose'any requirements nor does it ] require any kind of response from the licensees. It is intended to i inform the licensees about a specific problem and suggest that tiiey check to make sure that it does not apply to their plants. A G'ineric Letter may or may not require response from licensees. Sometimes it may I be used to impcse new requirements. A Bulletin usually requires some kind of response from the licensees. l t Dr. Siess asked how much contribution has been made to plant safety by j implementing the resolved issues. Mr. Schwink responded that RES is in the process of looking at certain items that have not yet been imple-mented to determine the risk reduction potential. An examination of three such issues showed that implementation of these issues would reduce the core-melt frequency from 1.85 x 10-5 to about 1.5 x 10-5 Dr. Siess asked whether the Staff feels that the resolved items should be implemented at a more rapid rate. Mr. Schwink responded that he believes that first they have to determine the safety significance of tne items in the backlog list. If they are found to have major safety significance, adequate rescurces should be allocated to implement them quicirly. Dr. Siess asked whether they are satisfied that the backlog items are not that important to safety. Mr. Schwink responded that they have not been able to convince themselves that these items are not important to safety. He believes that to be conservative, they should try to dispose of these issues as soon as possible. Safety Issues Manacement System - Mr. W. Schwink SIMS has been developed as directed by the EDO, presumably in response to the criticism made by the General Accounting Office, in September 1984. It is a computer-based system that provides a single source of

i Generic Items Meeting Minutes May 27, 1987 validated, reliable information concerning the management of generic issues from cradle to grave. SIMS contains information basically at two. levels: l

• Issue Level - Issue level data and pYocesses describe the issue, l

the resolution, the requirements and the tracking of milestones and status as the issue progresses these phases. 1

• Plant Level - Plant. level data and processes identify and track milestones and status of resolved issues as they are imposed, implemented, and verified at each affected plant.

l Mr. Schwink said that SIMS has been very helpful in providing several .) important information to the Staff, as noted below. l

• It provides information on how many plant-specific and generic issues need to be implemented in each plant.

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• It provides a complete summary of the-number of items resolved, l

number of requirements resulting fr'am the resolution of issues, j number of items imposed on licensees, number of items implemented, and the number of items inspected arid verified, j i 1 l j l-

• It helps to consolidate and integrate issues of similar type for I

ease of implementation.

• It helped the Staff to find out that'.some of the TMI issues, USIs, and High-priority generic issues that should have been implemented long time ago in certain plants have not yet been implemented.

~ Dr. Siess asked why some of these old items still remain to be imple-mented. Mr. Schwink. responded that they are not sure, and they do not have any records to show why these items have not yet been implemented.

l n Generic Items Meeting Minutes May 27, 1987 Dr. Siess commented that if there was an adequate Quality Assurance Program.in NRC, such things cou'id have been identified and taken care of j sooner. Mr. Ebersole asked Ehy USI A-9, Anticipated Transients Without Scram, that had been resolved somstme ago is not. included in the SIMS report. l Mr. Hebdon responded that he will check to see what is the status of USI A-9 and why it has not been included. He stated that the whole data system for SIMS is still being developed..They have not yet done a verification of the adequacy of the data already in the system. f TOPICS FOR THE NEXT MEETING _ Dr. Siess solicited the opinions of the Subcommittee members on the topics to be included for discussion at the next meeting. Mr. Wylie said that, probably, we should select some of those generic issues and USIs that took a long time to resolve and find out the reasons. j Dr. Remick said that since the Subcommittee has not reviewed the imple-l mentation process ir, detail, it would be helpful to look at how certain issues were implemented. Mr. Michelson suggested that the Subcommittee look at USI A-1, Water Hammer, and find out how it is being. Implemented. Mr. Emrit said that the resolution of USI A-1 affects only the future plants. He does not believe that it would be a good candidate for discussion. i Dr. Siess commented that he is not sure whether compartmentalization of. certain issues facilitates resolution but adversely affects the imple-mentation.

-1 i Generic Items Meeting Minutes May 27, 1987 l I Dr..Remick commented that it is not clear whether tnose issues that are divided into parts for easy resolution have ever been~ integrated after l l resolution and checked to make sure that they resolved the uriginal l j concern. After further discussion..the Subctamittee decided to concentrate on the following at the next meeting:

• Select certain generic issues and USIs.and follow them through the I

whole process with major emphasis on the implementation process.

• Hear presentations from and hold discussions with selected licensees.to learn how effectively resolved items have been implemented in their plants and whether they have contributed to plant safety.

Dr. Siess suggested that the Subcommittee members try to select certain issues for consideration at the next Subcommittee meeting and provide that information to him during the June ACRS meeting. Dr. Siest thanked all participants and adjourned the meeting at 5:10 j p.m. J NOTE: Additional meeting details can be obtained from a transcript i ~~ of this meeting available in the NRC Public Document Room, i 1717 H Street, N.W., Washington, D.C., or it can be purchased from ACE-Federal Reporters, 444 North Capitol Street, Wash-ington, DC 20001,(20P.)347-3700. I . =. _ __ _ ____ : J

i a J l 1 i LIST OF DOCUMENTS SUBMITTED TO THE SUBCOMMITTEE GENERIC ITEMS SUBCOMMITTEE MEETING MAY 27, 1987 l ] 1. i I. Tentative presentation schedule. I 2. Memorandum from Chairman Zech to D. Ward, dated September 18, 1986. J 3. Excyrst from the Generic Issue Management Control System - List of T 6les dealing with the status of generic isrues and USIs. 4. Table III, excerpted from NUREG-0933, Rev. 5, Summary of the f prioritization of all TMI Action Plan Items,. Task Action Plan j i Ithms, New Generic Issues and Human Factors Issues. l l 5. NRR Office Letter No. 40 - Management of Proposed Generic Issues. l 6. Table 1 - Screening Criteria for,Unrese,1ved Safcty Issues. 7., GA0 Report to the Congress, dated September 19, 1984. l 8. Information on Safety Issuss Mansgcment System. 1 l 9. Presentation Materials provided by the Staff during the meeting. i i .i l$ l 1 ATTACHMENT A 1 s 1 i' N. L ____Q ^

REVISED: 5/20/87 j-TENTATIVE PRESENTATION' SCHEDULE' .ACRS SUBCOMMITTEE MEETING ON GENERIC ITEMS MAY 27, 1987 ROOM 1046, 1717-H STREET, N.W. WASHINGTON, D.C. ACRS CONTACT: Sam Duraiswamy 202-634-3267 s_ NOTES:

• Presentation Time should not exceed 50" of the Total Time allocated for a specific item. The remaining 50% of the time is reserved for the Subcommittee questions and answers from the Staff.

Number of copies of the presentation materials to be submitted ~ ~ to the Subcommittee: 25 copies TOTAL PRESENTATION ITEM PRESENTER TIME ACTUAL TIME 15 min 8:30 - 8:45am 1. EXECUTIVE, SESSION 2. OVERVIEW Overview of the Themis Speis/ 45 min-8:45 - 9:30am process, involving Warren Minners Identification, Prioritization, Resolution, and Implementation of Generic Issues and USIs. Identify the staff units involved in the process. 3. PRESENTATION BY RES far:t 3.1 Prioritization Ron F,+bm 60 min 9:30 - 10:30am Process

• How fast Typical

' - 0 Generic-Issues are prioritized? Are there'any Generic Issues that were'iden-tified several years ago but U yet to be prioritized? .If so, why?. ATTACHusar 8 a1-1

Generic' Items Schedule. May 27, 1987 - Tentative Presentation Schedule - 1 TOTAL PRESENTATION ITEM PRESENTER TIME ACTUAL TIME 3.1 Prioritization Ron Frahm Process (Cont'd)

• What criteria are used to decide which Generic Issues should be priori-i.

I tized first? I_

• Do you consider l

the prioritiza-tion process effective? Why or why not?

• • • BREAK ***

15 min 10:30 - 10:45am-3.2 Resolution Process Warren Minners 105 min 10:45 - 12:30pm

• Are all pertinent Generic Issues resolved fast enough?

" What is the range of time (naximum and minimum) for ^ resolving a generic issue subsequent to its I prioritization?

• What are the factors involved j

in deciding which generic issues should be re-l solved first? l

- - - - -8 2-i

C:ntric Items Schedule May 27, 1987 ~ - Tentative Presentation Schedule - l TOTAL PRESENTATION l ITEM PRESENTER TIME ACTUAL TIME, 3.2 Resolution Process Warren Minners (Cont'd) ' Are there any Generic Issues that.were prioritized several years ago but yet to be resolved? If so, why?

• • • LUNCH ***

60 min 12:30 - 1:30pm 4. PRESENTATION BY NRR 4.1 Implementation Walter Schwink/ 120 min 1:30 - 3:30pm Process Fred Hebdon

• Describe briefly typical factors involved in the Implementation process.
• What is the range of time (maximumand minimum) to implement re-solved issues for a plant and/or for all plants?

I J

• What is the cur-I rent status of the implementa-tion of the resolved generic j

issues and USIs? ( l l l 8.3

4 s Generic Items Schedule May 27, 1987 1 - Tentative Presentation Schedule - ^ TOTAL PRESENTATION ITEM PRESENTER TIME ACTUAL TIME 4.1 Implementation Walter Schwink/ f Process (Cont'd) Fred Hebdon i-

• What criteria are used to decide which items (such as fixes resulting from the resolu-tion of Generic Issues /USIs and plant-specific fixes,etc.)

l should be imple-mented first?

• Are there any recent incidents that could have been avoided if certain Generic Issues and/or USIs had been resolved and implemented sooner?
  • • BREAK ***

15 min 3:30 - 3:45pm i 4.2 Safety Issues Ch: 'en rit:;;r:ld/ 30 min 3:45 - 4:15pm i Management Eichard ";rtficl? l System (SIMS) >4altey s ekvin a. I

• Provide a i

brief summary of what it does and how it helps the NRC. ] i

• Has it contri-buted to the effectiveness of the' Staff process dealing i

with Generic Issues and USIs? B-9

l Generic Items Schedule - May 27,-1987 - Tentative Presentation Schedule - I TOTAL PRESENTATION ITEM PRESENTER. TIME ACTUAL TI!45 i 4 S. TOPICS'FOR THE SEC07 D Subcommittee / 45 min A:15 - 5:00pm MEETING Staff

• Follow certain number

>{ of Generic Issues through the whole . process (prioritiza-tion, resolution, ) and implementation

• How many issues'to I

be considered

• How to choose the issues. Should it be based on:
• Maximum Time
• Minimun Time
• Importance (USI vsHighorMedium)
• Written Input r

expected from the i Staff prior to the next meeting 15 min 5:00 - 5:15pm 6. SUBCOMMITTEE REMARKS 5.15pm

• • • ADJOURN
• 1 1

s l l i l B-s _A

..e as a GEN 3RIC ISSEES PROGRAM FOCT::0X RES?0NSI3IIZTY D3X"::F:: CAT ON KL

?R:0IS:ZAT::0X R3S 3ES0I'::0N R3S

Y?0S"" ION NR1

) l

XZZY3N"f'::0N L" CENSE 3S O

V33IFICAT::0X XRR & REGIONS c-1

I.......... GENERIC ISSUE PROCESS i IDENTIITICATION ALL i. -I I NRC S T A l= F C OF Fr I CE LETTERS > l l ACRS I I INDUSTRY I i PUBLIC 1 I I V I PRIORITIZATION RES I-i SAFETY I NON-SAf=ETY I l l i HIGH I LI I I MEDIUM i E I I NR I I I LOW l I I DROP l I I SUBSUMED I I l l RESOLVED I I { REGULATORY I -{ l IMPACT I. l I I I GIMCS I I i i I i i HIGH I I I I I MEDIUM i< >1 NUREG-0933 I I NR I I I I RI I I I I LI I l = = 1 I I I I V I R E S:OLUTION I RES .I 3 I V g a O*b J

4 .j GENERIC ISSUES PROCESS CCONT N I .I ~ v hIMPOSITION NRR h 1 1 3 ) I ONLY ISSUES RESOLVED WITH I I REQUIREMENTS l l l 9 ESTABLISH SCHEDULES WITH I I LICENSEES I I l A A I Iv l IMPLEMENTATION LICENSEES I 1 LICENSEE PERFORMS NECESSARY -'I I ACTIONS I I I I NRR TRACKS IN SIMS l E A I Iv I VER I Fr I C AT I ON NRR Sc REGIONS I I I I VER I fry LICENBEE ACTION BY I I INSPECTIONS AND/OR AUDITS I I I e g,3

P3IOE'IZATIOX PROC 3SS

• IDENTIFY & DEFINE l
• ESTIMATES
• PRIORITY RANK P
• OTHER CONSIDERATIONS
• CONCLUSIONS
• PEER REVIEW
• 0FFICE DIRECTOR APPROVAL
• DOCUMENTATION

1. HOW FAST ARE GENERIC ISSUES BEING PROCESSED ? ANSWER: Past experience shows 30' GIs are prioritized per year. The average time to complete prioritization (receipt of issue through Office Director approval) is 6 months. O C-5 ~~ c.< 3

4'i ) l GENERIC ' I S f3 U E AVERAGE f= L O N FOR fr Y 83-S7 1 ) I NEW l' l REPRIORITIZAT.TONI I ISSUES I I ISSUES I 8 36/YR .I l 4/YR ,8 i \\ I V 1 IPRIORITIZATION I I BACKLOG I. l l-30/YR F-1 6 HIGH I I 10/YR' I d 1 I 6 MEDIUM i I 3 NR l 1 2 RI/LI I I V --v IRESOLVED 8 V 'i i REEsOLUT I ON I ( i 13/YR I i 17/YR I 12 LOW I I5 DROP I l l6 SUBSUM ED I { i l l 4 I 1 I i I 1 C-6 i c.L

2. ARE THERE ANY ISSUES THAT YERE IDENTauD YEARS AG0, BUT NOT YET PRIORITIZED ?

ANSER : YES; we have a backlog of older issues that have not been formally prioritized. However; the backlog GIs have been screened and many have preliminary draft assessments. The work load has prevented the staff from formally documenting the prioritization results. ) O c-7

4 REMEXING ISSUES TO BE PRIORITIZED AS OF (5/87) t r a s. -:.., sua...y y

a. a.,.

e.,, i. ~ SCREENED RANI NO. 07 ISSUES l EIGH c " s, > 2 r.J r, < = s s. " > 3 i MEDIUM 11 NEA3LY RESOLVED 3 RESO:JEJ 4 LOW 14 i DRO:? 10 SUBSUMED 6 LI 7 RI 3 TOTA 1 61 C-8 9 't.

w. 1 i i l i 3. YHAT CRITERIA ARE USED TO DECIDE YHICH GIs SHOUID BE PRIORITIZED FIRST ? ANSTER: { Preliminary assessments of the older issues indicated they are of low safety significance, and therefore ~ i generally remain as backlog issues. Never issues are also given a preliminary ~ assessment of their safety significance. } i t However, the EDO, Commission, or ACRS interests may [ cause a highly visible issue to be prioritized first. 9 c-9 Y a

4 4. DOES THE STAFF CONSIDER THE PROCESS TO BE EFFECTIVE ? I ANSTER i Yes; the staff considers the Generic Issue Process i to be effective. STAFF BENEFITS INDUSTRY BENEFITS PUBUC BENEFITS 1 i l i l I i l l l l l l l l C -10 c.3e

e CONCLUSION I \\ T3E PIORITIZATION PROCESS IS END3RS"00D AXD ACCEPTED BY: ~ GA0 '9/19/84,' l l ACRS {1/11/83} i IXDEST3Y (AIJR PROGRAM} 1 C0YESSIOX {:.2/9/83} l e C-//

.s ~ :'. . GENERIC SAFELY-ISSUES RESOLUTION PROCESS v ASSIGN'NEW ISSUE i DNLY HIGH PRIORITY DEFER MEDIUM PRIORITY TASK ACTION PLAN CONTRACT 1 ' TRACK IN GIMCS/SIMS RESULUTION INTERMEDIATE RESOLUTION TECHNICAL REGULATORY. ANALYSIS PUBLIC COMMENT l STAFF REVIEW CRGR ACRS COMMISSION FRN C -/Z ' l [, f }'

l 1 APPRCVAL RESOLVE COMMENTS STAFF REVIEW CHGR ACPS COMMISSION i l WPOSE 1 l FHN i RULE /GL/SRP/R,E. l l l-l 1 i 1 l ) 1 G-73 l

_...s._._ g r J ,,,#w-. ...;,y c ]:

t.

>'e 4 i m a / l ' GENERIC SAFETY ISSUES-l, RESOLUTION TIME (RESOLVED IN-1983-1987). USI'S l i MIN 45 MOS s AVG 54 MOS-1 MAX 83 MOS-GSI MIN kMOS 1 AVG 28 MOS MAX 51 MOS 'I d l l l l q. o C-/4 c;,e

1 2

<=* ;c i t. s 3 7

e_-

? -GENERICSAFETY,/lSSUES .:L LRESOLUTION PRIORITY- / PP.IURJZA110N /L j c. UNRESOLVED \\! TMI ACIION: PLAN (1980) 1 4 18 GSI I 4 TASK ACTION-PLAN (1979) a 4 USI 2 -10 GSI ~";. I .j~ l' .!.'{. l I ') 4 \\ l. i i: J 't i 5.. '. ] i C-15~ h l. ~ -

sLENERIC ISSUE RESOLUTION PLANT SPECIFIC IMPLEPD RATION OF THE APPROVED GEERIC ISSUE RESOLUTION TECHNICAL REVIEW OF LICENSEE'S PROPOSED MODIFICATIONS GENERIC REQUIREMENTS / GUIDANCE l LICENSING GUIDANCE CONSOLIDATION / INTEGRATION OF NRC EQUIRED PDDIFICATIONS WITH THOSE OF LICENSEE (NRR) 1 1 l CONSOLIDATED RATER THAN "PIECEEAL" MODIFICATIONS SAFETY PRIORITIZATION OF PLANT MODIFICATIONS-l IhTEGRATED SCHEDULING SAFETYPDDIFICATIONS I PESOURCE NEEDS } PLAhT STATUS VERIFICATION OF LICENSEE'S IFPLEPENTATION SPECIAL AUDIT INSPECTION (BALANCE WITH l l LICENSE REVIEW) ROUTINE AUDIT INSPECTION I C _/6-u i /. {f .t

e / 5 1 J d GEFERIC ISSUE RESOLUTION 'l LICENSEE PRIORITIZATION OF PLAS,7 EQUIRBOTS/MDDIFICATI0t6 PUBLICSAFETY. RADIOLOGICAL MATERIAL RELEASE FP&.THE PLANT HAZARDOUS MATERIAL RELEASE FROM THE PLARI PERS0tA'EL SAFETY OCCUPATIONAL RADIATION EXPCSURE INDUSTRIAL SAFETY l ECONOMIC PERFORMANCE PLANT AVAILABILIW PLANT EFFICIENCY ELECTRICAL OUTPUT CORE POWER RATING PERSONNEL PRODUCTIVIW EFFECTS ON PEOPLE EFFECTS ON EQUIPtBIT EFFECTS ON WORK ENVIRON E KT EXTERNAL ItPACTS NRCACTIONS 0THER FEDERAL AGENCY ACTIONS i l STATE / LOCAL GOVEfRENT ACTIONS INDUSTRf ORGANIZATION ACTIONS i C-!7 Cb L

i. 6 1 a GENERIC ISSUE RESOLtJTION l{ I TIE FOR IMPOSITION /IFFLEMEhTATION OF APPROVED' ISSUE RESOLUTION ) HIGH PRIORITY EXPERIENCE j GOAL

• AVE MINI M MAXI M IFFOSITION-LICENSING 6M 41 M 5M 131 M LICBEEE IMPLEMENTATION

+ 18 M 28 M-1M 42 M 24 M L VERIFICATION / INSPECTION + 12 M 36 M EDIUM PRIORITY ' EXPERIENCE GOAL AVE MINIPUM MAXI M !MPOSITION-LICBGING 12 M 45 M 2M 130 ML LICENSEE IMPLBENTATION 36 M 30 M 1M 69 M + 48 M VERIFICATION / INSPECTION + 36 M 84 M i LOW PRIORITY EXPERIENCE G0AL AVE MINI M MAXI M IPPOSITION-LICENSING 12 M 45 M 10 M 114 M LICENSEE IPPLEENTATION + 54 M 21 M 1M 59 M 66 M VERIFICATION / INSPECTION + 36 M 102 M C-. / g 't 'NOT ALL CASES b

7 1 l } ( GENERIC ISSUE RESOLlTfl0N PROCESS ~ i STATUS OF APPROVED GENERIC ISSUE RESOLUTIONS J IFFOSED . IPPLEPENTED PRIORITY APPROVED ~(ALL AFFECTED PLAhTS) (ALL AFFECTED PLAhTS) j HIGH 43 30 22 PEDIUM 44 32 24 ] LOW + 36 35 25 123 97 71 OTHER + 300 + + TOTAL 423 l l l l l ) l c-At -_-_._E__---__-_______ . _ _ _ _. - _ _ _ _ - - - - _.. - -. _ - - ~ - _ _ _ _. _ - _ _ _ _

<s i RESOLtTICY OF GSIs 1 t STATUS AS OF {5 87j' i i TYM ::SS";3 X0. '20 3E 33SCCVED { { USI S' GSI 3IGH 32 i N3DIY 13 NR 12 \\ TO'. AL 6S' C-20 {. #o \\'

GENERIC SAFETY ISSUES RECENT INCIDENTS ~ UAVIS-BESSE LOSS 0F AFW 124 AFW RELIABILITY DIABLO CANYON LOSS OF RHR t 99 RCS/RHR SUCTION VALVE INTERLOCKS ON PWRS BRUNSWICK / HATCH SRV STICKING / LEAKING B-55 IMPROVED RELIABILITY OF TARGEl-RODE SRV-OCONEE/ NORTH ANNA SERVICE WATER FOULING 51 - PROPOSED REQUIREMENTS FOR IMPROVING THE OPEN CYCLE SERVICE WATER SYSTEMS TROJAN CONTROL ROOM HABITABILITY 83 CONTROL ROOM HABITABILITY-TURKEY POINT CONTROL RCD DRIVE HOUSING LEAK 29 BOLTING DEGRADATION OR FAILURE i IN NUCLEAR POWER PLANTS l 12 PLANTS YEAR 4C 95% AVAILABILITY ,t B56 . DIESEL' GENERATOR RELIABILITY I 'o l c-2j .,t

] e e e i" e REGULATORY PROCESS TO ADDRESS REACTOR RELATED ISSUES nis, man ass o.e man mes,soo seen tefan Pensseessagt ,,s,,e,n, a go e, h_ g j ( L j v N Actaen ,_e - A,se.e _ nIE. a=_ ="r-ee C.' -'/ I .:=e. - r aa-i he 5 q l l I t G og j i se heereorese snows tsom Otho, q Gehees Huants eena. l .Onise OHis** cRen Acas acesse one

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.e nec aam na ~ ____________________________.J maa -nas t ,,ma. ae.,e, use.or.e 8" " gnen smaa Desse** j g ( SMoM E#e't t g j t j v v-C y v-a tenue Pohs, t,aewesed L e.s. o se.e e r se mac nos. ee. se.e e a

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se geaC - aseeere8 P f t P goosee Aetens Aseems u Cfser:s to sos. e sien 1'l -i .ma,no w ( esea <beresen g 3 Heat j v v man snea t j a e to mac \\ '" s2*"'"...* # e w l . * >=es=' . sos -e ,see,ee, .e _ Yam 4suostason Progesen - s y teous _ Figure 1 Generic leeue Resolution Process for Power Meectors C - 2. 2.

3 x j' ^ 7 r, 2 s GENEP,IC ISSUE RESOLUTION y i NRR PARTICIPATION IN THE, GENERIC ISSUE RESOLIITION PROCESS a,. IDENTIMCATION OF A FOTENTIAL ISSUE FOR RESOLUTION' '( i PRIORITIZATION OF tie ISSUE DEVELOPWNT OF THE TECHNICAL RESOLUTION FOR THE ISSUE ' I l \\, I*y PLANT SPECIFIC IT OSITION OF V1E TECHNICAL RESOLUTION. m LICENSING ) VERIFICATION OF LICENSEE IWLEEhTATION. 1 s ,3 1,j 3 ROUTINE INSPECTION ' j s_ ja y i d ~,_ % hi i. c 9- , w; ;

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.a e? > v p C-23 1 y e s. Oi!}g[O l(. 1 3 L' JE.. i-9=._

t 3 7 Q, GENERIC ISSLE PESOLUTION IVPOSITION OF TECHNICAL RESOLWION OF THE ISSUE LEGISLATIVE PROPOSALS RulB% KING OPDER ) l POLICY STATEE NT 1 REGULATORY' GUIDANCE 4 1 GaiERIC LETTER L 8Uu m N l l l OTHER OPTIONS FOR DISPOSITION OF THE TECHNICAL PESOLMION l i INFORMATION NOTICE LICENSING GUIDANCE y l' INSPECTION GUIDANCE -.C-2t

L-e J $ 4 1' 'EENERIC ISSUE REmLUT!nN PLANT SECIFIC IPPLEEhTATION OF THE-APPROVdD GENERIC ISSUE ESOLUTION TECHNICAL EVIEW 0F LICENSEE'S PROPOSED MODIFICATIONS l GENERIC EQUIREENTS/ GUIDANCE LICENSING GUIDANCE CONSOLIDATION / INTEGRATION _0F NRC EQUIRED PDDIFICATIOFS WITH Th0SE OF LICENSEE CONSOLIDATED RATHER THAN "PIECEEAL" MDDIFICATI0tG SAFETY PRIORITIZATICH OF PLANT MODIFICATIONS INTEGRAiTD SCHEDULING l SAFETYPDDIFICATIONS l RESOURCE NEEDS l PLANT STATUS 1 VERIFICATION OF LICENSEE'S IPPLEE NTATION l SPECIAL INSPECTION BALANCE WITH LICENSE REVIEW ROLTTINE INSPECTION l l l 4 C L.--__ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _. _ _ _ _ _ _ __m-m____._.

5 i GENERIC ISSUE RESOLiffl0N PRIORITIZATION OF PLANT SPECIFIC PEQUIREENTS/ MODIFICATIONS l l (LARGEST NET SAFETY IMPROVEEfff FIRST) 'l EXISTING REQUIRBENTS OLTISTANDING 1MI ACTION ITEMS RESOLVED GENERIC ISSUES (USI, HIGH, EDIUM AND LOW) NEW E0JIEENTS/ GUIDANCE 1 OERATING EXPERIENCE l LICENSEE PERFORMANCE I!SIGliS FROM PRA (GENERIC AND PLAhT SKCIFIC) i I. UTILITY IIPROVEEhTS C-26

6 GENERIC ISSUE RESOLUTION

TIE FOR IPPOSITION/ IMPLEMENTATION OF APPf0ED ISSUE RESOLUTION HIGH PRIORITY AVERAGE MINIMJM MAXIMJM IPPOSITION-LICENSING 41 M 5M 131 M LICENSEE IPPLEENTATION 28 M 1M 42 M EDIUM PRIORITY AVERAGE MINIKN

,MAXIKFJ f IFFOSITION-LICENSING 45 M 2M 130 M LICENSEEIFPLEMENTATION 30 M 1M -69 M LCW PRIORITY AVERAGE MINIKIM - MAXIKN IPPOSITION-LICENSING 45 M 10 M 114 M LICENSEE IPPLEENTATION 21 M 1M 59 M 1 l C-27

{ 7 GENERIC ISSUE RESOLlTTION PROCESS l STATUS OF GENERIC ISSUES I IPPOSED IPPLEENTED VERIFICATION (ALL (ALL SPECIAL/ AFFECTED AtttLitu R0lHINE PRIORIT_f TOTAL APPROVED P! ANTS) - PLANTS)- (ALL PLANTS) ~ TMI-0660 24 18 11 .11 11 1 TMI-0737 178 178 145 109 170 l USI 19 5 2 3 3 HIGH 79 37 27 12 -22 i l-1 i EDIUM 65 47 32 21 26 i .l LOW 36 35 34 22 25 i 1 .l l OTHER + 94 +1 + 34 + 20 + 43 TOTAL 495 387 285 198 300 ] l b-28 y

L A 8 9 8 5 T 7 1 9 9 O 2 4 1 T SE D 7 U E 8 S V / S L I 8 5 4 7 2 O 7 0 8 2 C S 1 I E 2 3 / R R S E U 5 O S N I R F E A G V O M N N O F I O E T S I A A R C I D A I R F E A E D I S V N R A E T B L V A M O D E D D U S 0 4 4 6 V N S S L A N E 1 9 0 O E R 1 S N C + E O O + L N R T P R I + A U Y A + T L T N O L N O A E I T C M T U I E N L L H P O S C M E E I E T R P N N E Y 7 E O H I T 3 E T T B I 7 S N E O E 0 R L V P E I U E A A M R H T H I I A S I M S T O S F S E O S I T U O T U S U E S E S S G S I I A 7 T 9 8 S 0 3 1

L 8 0 1 9 A 6 6 6 8 T O 0, 7 3, 1 T 9 1 1 1 2 S M E D T E 8 9 0 7 I V 6 9 0 6 L L O 0, 8, 0, 7 1 E S 9 7 7 8 V E 1 / E R L 2 2 S T / N A E 5 M L B A P D F E H C O I F V I O O L I 1 1 2 l W 5 6 6 2 O S R S S 5 5 1 M S A E M E E 3 4 T E B R T A I I M N E C L TA U U V IF E D N L C I E T P L N S + + A A E L T U T P N S O A S 0 L T 8 I P E 1 C 1 0 I P 2 5 R Y 7 E 1, T 3 E N 9 S E 7 S U S G E 0 R L A N A U E A C IA H T S T N I I S S M T O E N I S T U U O D I O T S C E S T I O O S O 5 L 9 R A 4 T S E O I M N I I T. S.

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