ML20247B676

Transcript of 890425 Briefing on Generic Issues in Rockville,Md.Pp 1-62.Viewgraphs Encl

ML20247B676
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Issue date:	04/25/1989
From:	NRC COMMISSION (OCM)
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REF-10CFR9.7 NUDOCS 8905240200
Download: ML20247B676 (87)

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l-4 (% DISCLAIMER 2 -t i This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held. on April 25, 1989 in the Commission's office at One White Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies. k The transcript is intended solely for general -~. 5 .O informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize. 4 NEAL R. GROSS court REPORTERS AND TRAN5CRisER5 1323 RHoOf ISLAND AVINUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232-6600

.a '] ,4 j.; 7-Bj d. p-l~ T!!~TED STATES OF - AMERICA <(. 2 17UCLEAR REGULATORY COMMISSIO!! '3 -4 BRIEFIl1G 011 THE STATUS OF GE!!ERIC ISSUES .r s .5 6 PUBLIC HEETIl!G ~ E 11uclear Regulatory Commission 9 One White Flint North 1C' Rockville. Maryland. 13 12 Tuesday. April 25, 1989 h 13 14 The Commission met in open session, pursuant to 15 notice. at 10:00 a.m., the Honorable LANDO W.

ZECH, JR.,

16 Chairman of the Commission. presiding. 1" IS COMMISSIONERS PRESENT: 10 LANDO W. SECH. JR.. Chairman of the Commission 20 THOMAS M. ROBERTS. Member of the Commission 21 KENNETH C. ROGERS, Member of the Commission 22 JAMES R. CURTISS, Member of the Commission 23 24 ? 4 25 (202)234-4433 UEAL R. GROSS & COMPANY. INC. (202)232-6600' ~ _

l A W l STAFF AtID PRESEllTERS SEATED AT THE COMMISSION TABLE: 'J l 2 FAMUEL ?. CHILE. Secretary l l 3 MARY WAG!!ER. General Counsel's Office 4 JAMES TAYLOR. Deputy Executive Director, Operations 1 j 2 THEMIS SPEIS. RES 6 17 ARE Eli MTlil1FR S. RES 7

1. RAi!E GILLESPIE. ?!RR P

17 ALT SCHWIIIE. 11RR 9

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(. ..,7 3 s L P R O C E E D.I N G S o ?,( L 'I (10:02 a.m.) 3 C H A I RM A!! ZECH: Good morning, ladies and 4 . gentlemen. 5 Today the Commission will be briefed by ;. the 6. ITEC's Office of Research and the Nuclear Reactor-L Regulation Office concerning the status.of the Generic ~ 8 Safety Issues Program. 9 We last. heard from the staff on this subject-in 10 a public meeting in October, October 21, 1987. At that 11

time, the staff's briefing. focused on the process and 12 perential improvements plan for resolving generic. safety 13 issues.

14 And, subsequent to that meeting, the Commission 15 specifically requested that the staff provide a-progress 16 report to the Commission. concerning improvements in 17 processing and resolving the unresolved and generic safety 18 issues. including the status of each remaining unresolved 19 safety issue. 20 The resolution of generic safety issues is an 21 important aspect of HRC's overall program, to assure the 22 continuing safety of nuclear power plants. 23 The commission reviews the staff's progress in 24 reselving these issues on a quarterly basis. and today's .( 25' inferration briefing will provide us an opportunity to (202) 234-4 433 !!EAL R. GROSS & COMPANY. INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.. WASHINGTON, D.C. 20005

e hear frem the staff concerning the effectiveness of the f._ ] improvements instituted in 1987. I understand that copies of the staff slides are a available at the entrance to the meeting room. 5 Do any of my fellow Commissioners have any 6 opaning cornents to make? (17 0 response.) If not. Mr. Taylor, you may proceed. C MF. TAYLOR: Good morning, sir. 10 'NAIRMAN ZECH: Good morning. 11 MR. TAYLOR: At the table with-me are Mr. 12 Schwink and Mr. Gillespie from fiRR. and Mr. Minners and 13 Mr. Speds from the Office of Research. y ]j 5._. 14 The briefing will be in two parts. The areas of 15 identification, prioritization and resolution will be 16 given by the Office of Research, and then the areas 17 covering imposition. implementation and verification will 18 be provided by tJRR. 19 Mr. Speis will start the briefing. 2 C' CHAIRMATI ZECH: All right. Thank you very much. 21 You may proceed. 22 DR. SPEIS: Mr. Chairman, Commissioners. 23 The first Vu-Graph, please? (Slide) The i 2d contents. Basically, in today's presentation, I will 25 briefly go over the history of the generic issue progran. '202)234-4433 NEAL R. GROSS & COMPANY. INC. (2021232-6600 ( l 1323 RHODE ISLA11D AVE 11UE, N.U.. WASHI!JGTON. D.C. 20005 i L-_---__-_______.__-_.--__.__-_

l i q e i i including the precess and its key parts, and aisc l ? rr,rize the progress made since the October 21st. '87 I ( Pr'.efing that y e t. mentioned. Mr. Chairman. J Also I will provide a status of the remaining 5 unrescived safety issues and a selected number of generie 6 issues: discuss our other activities involving a re-review 7 of lev-pricrity issues. and share with you some reasons A frr occasional schedule slippages and, of course, as Mr. 9 Tayler m e r. r i o r. e d. the later part of the briefing will be ". O provided by 1:PR. ".1 The first Vu-Graph -- (slide) -- I have provided 12 to ycu a graphic illustration of the generic issues 13 precess. You see the number of steps identified in the 14 Vu-craph, the step which involves the identification, 15 pricritization and resolution. These are the three parts 16 cf the process which are done in the Office of Research, 17 and then the imposition, implementation and verification 15 by the Office of IIRR and the regions. 19 The identification of the process is the first 20 part of course. This is where the issues are identified. 21 based on concerns raised by ACRS. staff operating 22 e::pe rie n c e, technical reviews, risk assessment studies. 23 Alse. once in a while, we have some issues from the 24 public. In fact. the last four or five years, two issues ( 25 have been raised by the public, which I'll mention them (2 21:34-4433 1!EAL R. GROSS & COMPA17Y, I11C. (202)232-6600 1323 PHODE ISLAliD AVE!!UE, !!. W, WA SHIliGTO!I. D.C. 20005

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this is- ~t '3 where. an assessment is m'ade of the potential safety. i 4 significance of these issues. Basically. this process is .nstly-risk-based., but als o - 'i t involves different 5 w 'l 6 and distinct overviews. 7 The resolution -part of the process - this :is i 8 where-the resolution is developed. Potential .9 identification of improvements are made'at this stage of 10 the process.

Also, any. potential ' requirements are 11

. developed here. .This is' a very intensive effort. It 'n addition to the. staf f, the CRGR. the 'ACRS i 12

involves, 13

.and. if the process leads toca rule, the. Commission, of <. b; 14 course, gets involved. So, the approval ' -- this stage 15 also involves regulatory analysis. 16 Then, once this process has been completed, if, 1 ~1 as a result of the resolution, something has to be done in 18 a power plant then the process proceeds and the-19 implementation is implemented by rules, or generic 20 letters or changes into the standard review plant. 21 regulatory guides, and so on and so forth. 22 -This whole process is struck by SIMS, which URR 23 people will be discussed later. In addition to the SIMS, 24 we in the Office of Research would have a document called . {- it's a kind of a depository. Every i 25 ITUREG 0933, which '(202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 PHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

ai -,7 i > 4 'I issue has been identified. Even. issues that turn out'to ( 'I N of: no safety significance. they-are documented there. -3 Tne pricritization of the process is described:in liUP EG w 4 0933. 'Sc. we have a very well dc;umented system where 5 every issue -- any issue has been' raised the last 10 or 15L 6 years can be found in those two documents, especia11y ' in 7 IIUREG 0933. S So, with~this brief overview of'the' process -- 9 COMMISSIOllEE ROGERS: Just before you leave 1C thar. Il DR. SPEIS: "le s. '12 COMMISSIOllER ROGERS: I assume that there really. 13 is - .that.it is as you've said, that it 's a much more 4k 14 .ccmplex interactive-situation than this little line~ 15 diagram-implies. that in any ' one.- of these areas. general 16 areas of responsibility -- other parts of the organization. 17 are called upon and is consulted and so on. ~18 DR. SPEIS: Of course, let me.-- 'no question 19 about it. The prioritization, for example. We'take -- we 3 20 in the Office of Research. take the lead in prioritizing 21 an issue, and then every issue is sent to NRR for their 22 review. .Also, the ACRS participates in the. 1 1 '23 prioritization. And, of course, in the resolution, the 24 process is much more. compact. 25 COMMISSIO!IEP ROGERS: There's a certain amount c, (2S2i234-4433 !!EAL E. GROSS & COMFAliY, IliC. (202)232-6600 1323'PHODE ISLATID'AVEffUE. !!. W.. WA SHI!!GTON. D.C. 20005

i i 3 I 1 cf cycling back and forth. (_ 2 DR. 57EIS: Yes. this is too linear. This is fer 3 presentational purposes. yes, sir. 1 C UIRMAM ZECH: Let's proceed, please. E DR. SPEIS: On Vu-Graph number two -- (slidei-- 6 I have surmarized the process. the accumulation of the issues fron: the beginning of the process. The formal 3 program start in 1981, with 511 issues identified to be 9 pricritizad. Three hundred sixty-nine of those issues 'O care from TMT-related reviews. and the remesning 142 came i 1 frer a nurber cf other documents that the staff had put 12 together. 13 For example, the THI-related issues. if you I 14 recall came from the Rogovin Commission, from the I 15 Presidential Commission, and fron. other internal staff 16 reviews related to the THI accident. 17 So, if we go to the next Vu-Graph -- (slide)-- 18 in addition to the 511 mentioned already. we had an 19 additional 224 irsues, including human factors issues that 20 have been identified in the past eight years. So, that 21 gives us a total cf 735 issues. In fact, these are four 22 more since the briefing we made to you back in October of 23 -- 21. 1987 24 CHAIRMAli ZECH: Four more? 25 DR. SPEIS: Yes, sir. (202 ) 2 34-4 433 !!EAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 't-

9 2 CHAIEMAN SECH: We had 220 -- l 2 DR. SPEIS: We had 731. We had 731 in 10-21-87. 3 and now we have 735 issues. So, we have added four more a issues since October. 5 CHAIEMAN ZECH: Thank you. 6 DR. SPEIS: So. as I said earlier, every one of 7 these issues can be found documented in NUREG 0933, and 8 their disposition. For your information, these additional 224 1C issues. the large majority of them came from reviews done 11 by the Office of Huclear Reactor Regulation, as well as 12 fren prograus directed by the Office of Research. The (', 33 AEOD previded 31 issues, the ACRS 12, and the public came 14 up with two issues and. also, the regions provided one I 15 issue. So, that's kind of a -- I have 1 16 On page number 4 (slide) "t ? summarized the progress we have made since the November 18 21, '87 briefing. I guess I can address some of this. 19 For example, the subtotal in '87, we had resolved 610. } 20 When we briefed you on the progress of the program back in 1 21 May 12. '88. we had resolved 628, and today's briefing we l 22 can report that we have completed the resolution of 655 23 issues. 1 h 24 You see here that when I say resolution, they 25 fall under a spectrum of categories, some of them _m

10 ~ 1 prioritized low, some issues have been itstegra ted with II I 2 other issues, some issues turned out to be non-safety 5..J 3 issues -- for example, what we characterize as licensing l 4

issues, regulatory improvements, environmental.

For 5 exerpie, licensing issues are issues that involve getting 6 knowledge and expertise in the staff itself, to be able to I you know, like having depend 7 review the submittals 8 capability for audits, either calculational or otherwise. 9 So. on the next Vu-Graph -- (slide) -- I have 10 summarized the issues still to be resolved. The most 11 important category of unresolved safety issues, you see 12 that we have reduced the number to three and, as I will 13 address each one of them shortly, hopefully, those issues 0g 14 will be finished within the next four or five months. 15 So, we have three USIs to complete. We have 20 16 high generic issues, we have 13 medium. So, we have a i j 17 total -- 18 COMMISSIONER ROGERS: Just a second. I'm a 19 little confused about the distinction there between those 20 top three. f 21 DR. SPEIS: Yes.

Actually, in practice, we L

l 22 really have three categories. We have high, mediums and okay -- generic issues, but earlier on, by 23 low 24 congressional mandate, the number of high priority generic 25 issues assumed more importance and they were designated as (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 l

g +,n-, 11 l1. USIs.. This.was at the beginning of the program. S o -. we [o 2 have to report progress made on'the resolution of USIs to Jt. 3 Congrass. and we do that now via the NRC's annual' report. J COMMISSIO!!ER ROGERS: Okay. 5 DR. SPEIS: For your information, we had 29 USIs 6 on the books. and now we have,. as.I say here. three once in a while 7 remaining. Okay. Last time 'not-8 once in a while -- we go through the process of distilling 9 important ' issues that rise above the thresholds of highs 10 and. mediums, and put them into-the category of the.USIs. 11 The last time we did that was, I guess, a few years ago. 112 but as far as we are concerned, the. issues that.are = 13 designated high, they received the same ef fort as USIs. 14 you know, except 'for these mandated -- congressional 15 mandate to report. 16 Our schedule calls for resolving 80 percent of-17 the remaining highs by the end of next year, and the 18 remaining tha following year. There is a number here 19 which is said to be prioritized you see at the last 20 column, right at the bottom of the last column, which says 21 36 issues to be prioritized. 22 Now, because of our concern that maybe among 23 those issues there could be some very important ones, we-24 don't wait for the full process to reach its conclusion. .p' '25 .We~go through'a screening process to make sure that there i (202)234-4433 NEAL R. GROSS & COMPANY. INC. (202)232-6600 1323 RHODE ISLAND AVENUE. N.W., WASHINGTON, D.C. 20005

12 L 1 are no'irpertant safety issues hiding in this column of To Be Frioritized and. f or exa:aple, we have done that, and we have found cut that we didn't identify any high issues. 4 We identified nine medium, and the remaining 27 were l-5 either low or subsumed or in the other categories. l 6 So. even though. you know, it's still on the 7 bnnks. you knnw, a( far as we, the staff, are concerned. 8 as far as assessing the safety significance of issues that 9 come in front of us. you know, we pursue an expedited 10 process and, unfortunately, sometimes, the numbers don't 13 tell the gain. don't tell the 12 COMMISSIONER CURTISS: Does that mean you have 13 taken what amounts to a rough cut at priority? r~] g R._J 14 DR. SPEIS: Yes, sir. Yes, sir. 15 MR., TAYLOR: Yes. that's what it does. 16 DR. SPEIS: Yes, sir. Yes. And most of the -- 17 COMMISSIONER CURTISS: You further refine them. 18 DR. STEIS: We further refine, but so far, most I don't think we have 19 of the times, we have been 20 changed any. Maybe one -- once a rough cut was changed. 21 you know. from the more erudite process itself, you know. 22 COMMISSIONER CURTISS: And the purpose of that 23 is to ensure that we don't have any high priority issues 24 that have to be prioritized. 25 DR. SPEIS: Yes, sir, that's right. Yes. Yes. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON. D.C. 20005 I

l 5 t.- W-13 h1 1 Yes. Yes. That's very important to.us. [ 2 So. since the October '87 briefing. we have c 3 'conpleted the. resolution of 45 issues. 4 On page 6 -- (slide) -- I have a summary. It's 5 basically the same numbers. The issues Resolved and To Be 6

Resolved, and the percentage, and you see that we have Resolved 69 percent, and To Be Resolved 11 percent and,

~ 8 again as'I mentioned, that 11 percent. includes the issues 4 that we already have taken through a preliminary risk 10 evaluation. "1 I would like to focus on'the remaining USIs now. 12 (Slide) On page'7. we have three USIs remaining -- the 13 A-17, Systems Interaction in Nuclear Power Plants; A-40, 14 Seismic Design Criteria; and A-47, Safety Implications of 15 Control Systems. and I will discuss the status of each USI 16 s e p a r a t e l y.. (slide) - I will start with the 17 On page 8 18 USI A-17 We have completed the technical work on this 19 USI and have developed a proposed resolution. If you 20 recall.. the purpose of this USI was to investigate the 21 potential that there could be some unrecognized subtle 22 dependencies among structural systems and components that 23 could have remained hidden, and that could lead to safety 24 significant events. {" 25 In fact. in the past, we have noticed from our .(202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 u. 1323 RHODE. ISLAND' AVENUE. N.W., WASHINGTON, D.C. 20005

i p 14 i sceutiny cf the LERs. a number of events that have k_ 2 invrived unintended or unrecognized dependence among the i 3 systems that I mentioned earlier. 4 As I said, we have concluded that certain 5 actions should be taken by NRC and licensees, and we have the issue has been reviewed by CRGR, the ACRS, and 6 7 we're in the final process of putting the issue resolution i 8 together. 9 The most important thing that has come out of it 10 is the issue of flooding. to make sure that at least some 11 older plants have examined their plant for some flooding 12 vulnerabilities. And because the IPE process involves 13 explicitly an examination of flooding. we are going in the l .J the resolution of this 14 direction of including this 15 issue in the IPE system. in the IPE process. 16 A number of other things have come out, mostly 17 for information. which we'll be providing to the utilities 18 for their information, via generic letter. 19 The next issue, number 9 -- (slide) -- USI A-40, 20 Seismic Design Criteria. It basically involves future 21 plants. It involves only four existing facilities, and it 22 has to do with taking another look at some tanks above 23 ground, where we have revised the standard review plan to 24 provide guidance for future plants, and the specific 25 issues deal with seismic design parameters, seismic system (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202i232-6600 1323 RHODE ISLAUD AVENUE, N.W., WASHINGTON. D.C. 20005

l ,e i L 1 s 1 analysis, and vibratory ground section. j -(. i So, we will be finishing this issue in the next 3 few months, as is indicated on this slide here. l. 4 The last, remaining USI A-47 (slide) 1 5 Safety Implications of Control Systems. The i s s u e -- - 6 again, this concerns -- there may be failures initiated or 7 aggravated by non-safety systems, and we want to make sure B that the design basis events that have been analyzed don't 9 lead to significant -- don't change the evaluation as a 1C 1esult of these failures initiated by the non-safety 11 systems. 12 We have completed, again, the technical work to h 13 resc1ve this issue. A small number of limited 14 requirements have come out of it. For your information, 15 because of the variety of plants, the resolution has 16 varied considerably. 17 For example, we will be recommending over-fill 18 protection for over plants -- for s11 plants, steam 19 generator over-fill. For some plants like Oconee, we're 20 talking about providing diverse automatic initiation of 21 emergency feedwater. For some other plants involving 22 combustion engineering design plants, which have low head 23

pumps, we're talking about improving the emergency 24 procedures involving low break -- small break lock 25 accidents.

(202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 -o m a swew o m n wa n umame w* ma arwmamm a e saaaa

w 16' l' . COMMISSIONER ROGERS: Are those reinted~to.this (- 2 control systems. or to ' the other ' - - 3 DR. SPEIS: Yes, to the control systems -- A-47. 4 Safety Implications of Control 5ystems. So, the reason I 5 we r._:. into some detail is to show you that,'you know, we 6 come up with

a. generic resolution, but'then when we start 7

looking at' the large variety of plants, that resolution 8 has to be tailorcel very specific. So, we have-to do.the 9 work ahead of time to make sure that-some safety 10 enhancements can be justified on a plant-spe:..fic basis or-11 on a class of plants. And here is an example where-this 12 issue had to be tailored to the specifics of the-plants or-1.3 to the class of plants. g E-. 34 CHAIRMP4 ZECH: What's-your confidence'in your 25 abi3ity to meet the schedules that you've-given us for 16 these unresolved safety issues? l 17 DP; SPEIS: Oh, it's 99.9 on these three issues. l-18 There's ne question about it that we're going to meet them. 19 the next time. 20 C51 AIRMAN ZECH: Can you predict how long; it 21 might be required to implement and verify the actions on 22 these rema2ning USIs? In other words, does the resolve 23 mean that you've finished your work, or does the resolve L 24 mean they are implemented? 25 DR. SPEIS: No. it means that we have' finished L (2021234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600-1323 RHODE.ISLAUD AVENUE, N.W.. WASHINGTON, D.C. 20005 = - -

1 17 l i i 'a our work, and then the next stage involves notifying the j -( 2 licensees of actions that they have to take. 3 CHAIRMAN ZECH: Well, when are they going to 4 finish implementation? 5 MR. TAYLOR: He's not 99.9 percent 1 6 DR. SPEIS: I'm talking about resolution. I'm 7 scrry. Mr. Chairman. I withdraw the 99. It's only for 8 the reeclution part. 9 MR. GILLESPIE: It depends on what we're asking 10 a 1icer.see to do. A typical time would be two outage 11 periods. tn give them encugh time to plan and do any 12 engineering that might be required, if engineering is 13 requirad. Two outage periods can approximate about three 7 14 years. 15 CHAIRMAN ZECH: Well, if they are really safety 16 issues. it seems to ne that's a long time. First of all, 17 we're taking a long time to address them. I recognize 18 that if tnere are urgent safety issues, that you act on 19 them more promptly, but it still seems to me that when 20 you've finished your work. that when -- and you call them 21 resolved -- I appreciate the fact that means you've 22 resolved them. but that doesn't mean they're implemented 23 by the piart. And maybe two outages is reasonable. I 24 suppose it would depend on the -- ($ 25 MR. TAYLOR: What the fix is; what procurement, (2021234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAUD AVENUE, N.W., WASHINGTON, D.C. 20005

.y 18. l,1 1 5f~ procurement is involved. [ ~2 CHAIRMAU ZECH: Certainly. But'it seems to me 3 thet.if we really do e~nelude that there are unresolved L 4 safety issues. that we.hould put some fair amount of: good r 1. I 5 judgment into "aling their implementation because 6 tha't's really what we are. talking about. 7 So I hope you'll take a good hard lonk at that. 8 It does seom. to me that perhaps - two outages might be 9 reasonable, but it_may not be either. That's a very 10 important call. and NRR makes that, is that right? 31 DR. SPEIS: Yes, sir. 12 MR. GILLESPIE: .Yes. sir. 13 CHAIRMAN ZECH: After Research has' completed 14 their part of the program. So, we're hearing.-- 15 MR. TAYLOR: That agency interacts. 16 CHAIRMAN ZECH: Yes, NRR is going to tell us a. s 17 little bit about this. When you come on the program, will - 18 you elaborate on this point a little bit,.please? 19 MR. GILLESPIE: We will. 20-CHAIRMAN ZECH: All right. Fine. Let's 1 21 proceed. 22 DR. SPEIS: The next Vu-Graph, please? (Slide) 23 At the last briefing we mentioned some important generic 24 issues that we were in the process of resolving, and I L(- 25 thought I'll bring you up-to-date, Mr. Chairman. In fact, .(202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C.-20005 J-1 ___..___..____.__.-__-.___.______________________.__________.___m_.___.___._

19 1- .this. specific issue and-Mr. Commissioners - this issue { 2 here'on page-11, which discusses the Loss of RHR 3 Capability in PWRs -- in fact, the letter. has gone out 4 from-MRR, and the implementation process' -is underway 5 'because we consider this to be an important' issue. 6 This issue involves, broadly speaking, the loss 7 of core - cooling during cold shutdown, but the most 8 significant part of the issue involves the air binding.of 9 RHE pumps during mid-loop operation. This is the time 10 where the containment could be open and you are in the 13 process of performing operations in the steam. generator - 12 itself. 13 So, in fact, when. we started this issue, we . g.. 14 focused early on the.second part of the item shown on the 15 Vu-Graph. her e, the loss of RHR pump suction due to but

then, from 16 autoclosure interlock-related 17 operational experience, we-found out. that the most 18 important part of this issue had to do with the operations 19 during mid-loop -- during mid-loop operations, and we 20 focused on this issue, and we have completed the work on

.21 this issue. 22 In fact. I. understand - that Tom Murley, of NRR, l' 23 felt so strongly about this issue that he personally sent 24 a letter to every CEO and operator of the plant, and the '25 type of actions that have taken place are on page 12, the (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 ______________j

20-1 next Vu-Graph. { 2 CHAIRMAf! ZECH: Well, before you go off that one-l 1 '3-l 4 DR. SPEIS: Yes. 5 CHAIRMAN ZECH: I understand ' that the ACRS 6 essentially agreed with the position ~ that staf f 'took in 7 that regard. is that right? 8 DR. SPEIS: Yes. They had some questions about 9 the -- they want to review the procedures for containment 1D closure, you know, if you have.one of those events -- 11 CHAIRMAN ZECH: Yes, and it seems like -- 12 DR. SPEIS: -- plus the resolution. 13 CHAIRMAN ZECH: But t h e ** made a broader where they' tate'd that they. .j -14 statement. I think, that 15 didn't believe there's any well-defined policy direction 16 'f rom. the Commission concerning the. regulatory approach 17 that should be'taken. 38 If the staff feels that way, then the Commission 19 needs to consider such guidance. So, I believe the ACRS 20 had such a comment. Would you check on that -- 21 DR. SPEIS: Yes. and, if so, we need to hear 22 CHAIRMAN ZECH: 23 from the staff as to whether you agree and, if you need i I 24 any guidance from the Commission, please let the y[,- 25 Commission be informed by some kind of a written response. R (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 l __-____________-___-_________a

i 1 2; 1 IIF. MINNERS-Are you talking about their recent 2 lutter about the integration of issues? 3 CHAIRMAN ZECH: Yes, right. I 4 MR. MINNERS: Uh-huh. E DR. SPEIS: Okay. Yes, Mr. Chairman. So, o, 6 the -- '? CHAIRMAN ZECH: But there might have been an S earlier comment, too, on this specific issue. I recognize 9 there is a very recent letter on integration, but I think 10 there might have been one earlier on this particular 11 issue, too. 12 DR. SPEIS: When we discussed farther with the ( 13 ACES, one of the concerns was the procedures for closing i 14 the containment during the degradation in decay heat 15 removal. So, that was the specific -- but we will check 16 farther, Mr. Chairman. 17 CHAIRMAN ZECH: Okay. If I recall, I was 18 informed that the staff was going to respond to that ACR 19 comment here in the next month or so and, of course, the 20 ACRS is going come before the Commission here in early May 21 and, at that time, we will discuss that with them, as well 22 as their latest letter, but it is an important area. The 23 " integration of all of these major issues involving severe 24 accidents, the safety goal, MARE I containment, and all 25 the rest of it, but this particular one, I agree with Tom (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

u- ' :'.I.- 22 l -. 1 Hurley's approach to it. I-think he.dideexactly the right {I -2 thing. And1as I' recall. you certainly acted responsibly. 3 but N do"think the-ACRS comment, kind of implying on this '4 particular issue that you may need more direction from'the 5 Comrni s s ion, I'd ask you to look specifically at-that. 6 It inay be.that it is, indeed, part of the,more 7 recent 3etter. but I'd ask the staff to look and give us; 8 your cornine n t s. if you would. 9 DP. SPEIS:.Okay. We will. -10 MR. TAYLOR:. T might say,'on this one, sir, that 11 the action of the staff came by virtue of the occurrence 12 of~ loss cf RHR and, in all cases. recovery took place, but 13 it was -just happening. and because of the conditions. 14 usually being - in the service condition and so on, this 15 clearlyineeded attention, and that's why staff proceeded 16 to point that out. '7 CHAIRMAN ZECH: All right. Thank you. You may 1 18 p r o r.e e d. 19 DR. SPEIS: The next slide, please. (Slide) As 20 vs said. we have issued the generic letter back in October. 21 of 'ER. Tt was issued to all PWRs because this involves. 22 of course, only PWRs. and the staff's guidance focused on 23 actions to reduce the likelihood and consequences of the '24 ioss of decay heat removal. It addressed improvement in 25 procedures and instrumentation to help operator prevent (202)234-4433 NEAL R. GROSS & COMPANY, INC. (2021232-6600 1323 RHODE ISLAND AVENUE. N.W., WASHINGTON, D.C. 20005 'l 1

-i-c ^ 23 -1 and nitigate'. loss'of decay' heat removal. 2 On~ the' next -Vu-Graph, page 13 -- (slide)-- {; 3 development of. procedures that will permit timely closing. 4 .of. containment..during a degra'dation in decay heat removal. l' 'F CHAIRMAN ZECH: I understand'that the - staf f is 6 planning to : condur~t inspections on this particular item-- 7 DR. SPEIS: Yes. and on the effectiveness of' 8 CHAIRMAN ZECH: 9 the proposed containment closure procedures. When are you 10 going to do this? 'When is the inspection scheduled to il take place? 12 MR. GILLESPIE: We'11'be starting in about two some of these have actually already 13 months. and then (.h 14 been done in developing the inspection procedure itself. temporary instruction like 15 And, norma 31y. when we issue a 16 that. inspection procedure, it normally spans about two 17 years because you're going to be hitting -- trying to hit 18 these facilities during shutdown periods. So, we'd 19 anticipate that we would be completed inspections at all 20 facilities within two years. 21 Now, the exception will be that facility which, 22 for some reason, has been shutdown and not started up and 23 not gone into this condition, but that would be the rare 24 exception. ./ 25 CHAIRMAN ZECH: All right. Let's proceed. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE. N.W., WASHINGTON, D.C. 20005 y a

.'24 J i l DR. SPEIS: -The next slide., please. (Slide) .}. _. 2 The next issue that I would like to.say=a few things is i

3 the'B-56, which involves the Diesel Generator Reliability.

4 Ttis is an issue that has been.--

as coupled with the 5

station blackout rule. 6 If you recall, the station blackout set 'some 7 goals for reliability of the systems and, for example, for 8 the diesel, it set a goal of somewhere between.95 and-9 .97 and the effort here involves defining a -- developing 10 and defining a program thet addresses the principal 11 elements of a good reliability program,. to make sure'that ,12 the -- indeed, the diesels perform well. 13 We're working with industry on this issue here, '{ 14 with NUMARC. and we hope to adopt the. reliability program 15 into one of our reg guides and, as you see here, we hope 16 to finalize this issue this September. (slide) - which, basically, I. 17 On page 15-18 have said that-already. It's the coupling of this issue 19 to the station blackout issue, A-44, 20 And on page 16. the next Vu-Graph -- (slide)-- 21 again, our efforts are directed at defining the principal 22 elements of a good emergency diesel generator reliability 23 program and technical guidelines for use in revising a '24 number of reg guides that deal with diesels as well as'in 25 revising the standard review plan and developing (202)234-4433 NEAL R. GROSS & COMPANY, INC. (2021232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 i ..____.______._u.____.m_ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _. _ _ _ _ _ _ _ _ _

\\ .e* g. .I 25. +- .i appropriate inspecti r -, nodules. ) 1 { 2-So, as said, we are working with NUMARC to' 3 develop. these and. hopefully. we 'll - reach agreement that i ~4 we'31 be able to use the information that is developed and. 1g 5 adopt it into one of our reg guides. I (slide) I want to say a few 6 On page 17 7 things about review of low priority issues. The 8 Commission mentioned that at the last briefing.. It's part 9 of the process. In addition to ha.ving a -- I think we 10 have-said many times in the past that wh'en information. 11 comes that is relevant to an issue that has been 12 .'prioritized low in the past, then we revisit the issue and-13' we po through the process again, and we have done it on ' (. 14 the issue involving reactor vessel supports, which could that's the issue 15-degrade as a result of embrittlement 16 GSI 15 -- we worked on this issue a long time'ago and. at 17 that time, we gave it a category of low priority, but 18 then, as a result of research information that has.come to 19 our attention from programs that we conduct at Oak Ridge 20 involving radiation, then we find out that tho information 21 was very important, and when we utilized it in the E 1 -22 reprioritization. we found out that this issue is, indeed, 23 important. so we have to work on it. 24 COMMISSIONER ROGERS: Have you got a tentative 25 . schedule for closing? (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON. D.C. 20005

26 1 DR. SPEI5: Do we have one? 2 MR. M I N !! E R S : 11 o. We're work: ng on a task 3 action plan, but there is ongoing work at tne moment, it's 4 not just sitting there. We just have not fleshed out 5 everything to ecmplete the issues. 6 CHAIRMAli ZECH: Let me just commend the staff 7 fcr the action you took to raise the priority on this. I 8 think you did the right thing. 9 could you tell us very simply about the 10 significance of GSI 15, with respect to the safety of 11 nuclear power plants? Could you just briefly describe it 12 because I think I understand it, but I think it's a very h 13 important

issue, and it certainly deserves a high 14 priority, in my judgment.

15 DR. SPEIS: The information came to us from 16 experiments done at one of the experimental reactors at 17 Oak Ridge. We saw that there was a large amount of 18 embrittlement at low flux and low temperatures, and it 19 wasn't -- it was a little bit unexpected. 20 So, then the issue itself involves the potential 21 failure of the supports. If you have a flow to start 22 with, then if you have an earthquake or son.e other f orces 23 applied to it, then this flow could propagate as a result 24 of the material having been embrittled as a result of the l 25 radiation. ( (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600

.y '.,g 27 = < ~ 1 In; fact. 'even though we haven't developed a firn 2 schedule, were already looking at potential: solutions to .3 . thi s~ issue. For example. we can heat the supports. n: 4 application of l'ocal heaters and-insulation to maintain-5 ten peratures above the so-called nil ductility' transition 6 temperature. So. we have an intensive ef f ort. underway, 7 right now, that involves both'the' Office of Research and 8 the NRR. 9 CHAIRMAN ZECH: Let me just-say, in your best 10 judgment. is there any safety concern in this-regard, on 11 this issue. as far as any' current operating plants. are 32 concerned? 13 DR. SPEIS: There is no immediate safety.. ' k. 14 .. c o n c e r n. 15. CHAIRMAN ZECH: Well,- if there's no immediate 16 safety concern. that's very important. It seems to me. 17

thnugh, that there certainly' might be' concern on this

' 18 issue'as far as plant life extension and license' renewal 19 is concerned. 20 DR. SPEIS: That's an important point, and no 21 question about it, and that's the part that we're l 22 Addressing very carefully. 1 23 CHAIRMAN ZECH: Have the ACRS been involved in L 24 this particular issue yet, do you know? l h 25 DR. SPEIS: Yes. the ACRS has been involved'. In (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE. N.W., WASHINGTON, D.C. 20005 =:_.

f .s 28-i fact 1 if you recall

a. year and a' half ago, they had some

~ * ' 2 concerns, and.they were not in: total agreement with the. 3 staff, but subsecuent to that the actions that 'we have. 4 taken.'we have worked the program together with ACRS, and B the last letter we'got from the ACRS on this subject, they y ) 6 are in total agreement with us on the course and direction 7 .that we're taking. 'E MR. MINNERS: They were just briefed on this 9 issue last month. 10 CHAIRMA!! ZECH: All right. Fine. And they are l 'a in total agreement. now, with the approach that's being: 12 taken? 13 DR. SPEIS: Yes, they are in total agreement. 14 yes. 15 CHAIRMAN ZECH: All right. Commissioner Rogers . 16-asked you. about, you know, you're working on ' a current 17 schedule, I guess, and you're trying to do that now. Is-18 there anything a little more specific you can give us in 19 that regard? 20 MR. MINNERS: Well, we're supposed to have a 21 final test action plan approved by the Division of Safety 22 Issue Resolution in August of this year, and that's the 23 schedule. . 24 CHAIRMAU _ ZECH: In August of this year to do 25 what? (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 ~1323 RHODE ISLAND AVENUE, N.W.,' WASHINGTON, D.C. 20005 a -m

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- w - 29 i MR. MINNERS: To have a approved task action-1 plan. which would set out what work would be:done, and the 3-schedul.e.and the. final completion dates. 4 CHAIRMAN ZECH: So, you'll have. the plan laid 5 out in August of this year? 6 MR. MINNERS: Correct. ~7 DR. SPEIS: But at the same time,- in parallel. our Division of - Engineering. 8 our Office of Engineering 9 is looking at potential solutions, as well as categorizing 10 plants because, as all plants don't 'have the same 11

supports, and even if there is a failure or partial 12 failure, it doesn't mean that as a consequence this would 13 be severe. so ~it depends on the types of plants and the 14 types of other supports that exist.

So, we -- in 15 parallel, we are looking at all these things, and we'll 16 have-all these things together in August. .17 CHAIRMAN ZECH: Okay. Well, it seems-to me, if 18 I understand what you're saying, that's extremely 19 important because it could well be that even though you've 20 determined that there are no immediate safety concerns, 21 that between now and the time that perhaps certain plants u 22 that might have this concern and not all plants have 23 it. as I understand. 24 DR. SPEIS: That's right. . h 25 CHAIRMAN ZECH: How many have it, do you know? I (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE. N.W., WASHINGTON, D.C. 20005 l

30 ) i l 1 DR. FPEIS: I'm sorry, Mr. Chairman. I cannot l .y j 2 give you that information. We will provide that. ] l i. J 3 CHAIRMAN ZECH: It's not all; it's a certain 4 design as I understand, that has it. 5 DR. SPEIS: Yes. 6 CHAIRMAN ZECH: Well, in any case, I hope you'll look at every plant that does have this particular design 8 and miaht have this concern, and recognize that if there's 9 no immediate safety concern, that's very important, but 10 between now and the time you might be looking at it for 33 p3 ant life extension or for license renewal. it seems to 12 me that that could be a considerable period of time. and 'i 3 you need to make a judgment as to whether there's anything 14 that should be looked into more carefully, at any one of i 15 the plants that has this particular design, between now 16 and that time. 17 So we shouldn't wait, in my judgment, until too 18 far into the future, to make a confident determination 19 that it's not only safe at this time, but it will be safe 20 for a period of time. So, Research will be involved in 21 that kind of a decision, to assist the NRR, but I think 22 that's a very important issue, r.nd I hope you're looking 23 at that. 24 DR. SPEIS: We are looking into, each one of us. f, 25 highest priority. In fact. I see here I have some notes (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 i 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON. D.C. 20005

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1 that.we already-have categorized the type of supports that- ,( 2 exist'. I understand that we-have put them-.into five. '3 ' categories,. and' the thing that we're looking very 4 -carefully is that each one of these -- t'e susceptibility i ~ 5 -of each one of these varies because of its location and i 6 because' of distance 'from the core and other things like i 7 that. 8 CHAIRMAli ZECH: Yes. 9 DR. SPEIS: But the work is Progressing. It is i 10 underway =and -- l 11 CHAIRMA11 CECH: Are we involving.the utilities 12 themselves in this issue? Are they aware of our concern 13 that the plants effect that? y 14 DR. SPEIS: They are aware, and I think when we l 15 . define more what has to be done, we're going to get them i i 16 more involved in that. I 17 CHAIRMAN ZECH: Yes. It seems to me we should 18 at least alert them to this issue because it's something 19 that they may be able to contribute-to. 20 DR. SPEIS: Yes. I'm sorry I don't have the-- 21 Serpin,-who is the branch chief, who is the real expert in 22 this area, to address some additional information. J 23 CHAIRMAN ZECH: Perhaps when you get that, you 24 .might send. the Commission a paper. This, to me, is an 25 extremely important matter, and I know you're working on i 26 it, it's a high priority, I appreciate that. (202)234-4433 NEAL R. GROSS & COMPA17Y, INC. (202)232-6600 j

y; s 37 y'M li' HR. TAYLOR: We can update you on that. 2 DR. SPEIS: Yes, we can update you. We can send it: .s l p. :- lj 3 youL all' the. inf ormation that we have. developed -- 1 l. - 4 CHAIRMAN ZECH: That would be helpful. - 5 DR. SPEIS: we~ can relay it to you so that "g 6 ,you will have it. 1 7 MR. TAYLOR: We'll do that. q) 8 . CHAIRMAN ZECH: .Thank you very much. You may 9 pr.oceed. '1 0 DR. SPEIS: My 'last Vu-Graph (slide)-- 13 sumarizes'some occasional problems that we encounter, and 12 .I don't want to. you know, give excuses for them, but the 13 type.of things that appear once in a while when we go L 14 -through t@ process of-resolving -issues I have listed .35 .two things. one of them having to do with some delays from 16 a cooperative effort with industry; the other one involves 17 resting that has to be done to different valve materials 18 and before that testing is -- that testing has to be 19 complete before we decide that, you know, the proper 20 material has been selected. So, I don't want to say 21 anymore on that, basically, but, again, I don't want to 22 use this as excuses, you know. 23 COMMISSIONER CURTISS: On GSI-29, the first one, 24 that says "the resolution of this issue is dependent upon { 25 certain industry actions. (202) 234-4433 UEAT. R. GROSS & COMPANY. INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.. WASHINGTON. D.C. 20005 _a _.

4 33 1 DR. SPEIS: Yes. ? COMMISSIONER CURTISS: What is it that we're wa s t:i ng for there? 4 DR. SPEIS: Well, they have -- basically, we had 5 work underway contractual work, and then we stopped it 6 because the industry told us that they would assume the 7 effort and than it just took them longer, you know, two-8 rwo and a half years or so, than anticipated in the 9 criginai scheduiu. 10 TJow. we have gotten their technical information. 11 and we are in the process of integrating into the 12 resolution, okay? So, that's what that issue is. 13 COMMISSIONER CURTISS: You do have the 14 information? 15 DR. SPEIS: Now we have the information, yes. 16 COMMISSIONER CURTISS: And we're in the process 17 of integrating that. 18 DR. SPEIS: Yes, we got it from EPR, yes, sir, 19 COMMISSIONER CURTISS: Okay. I 20 DR. SPEIS: The second issue involves -- 21 COMMISSIONER ROGERS: Excuse me -- but just as 22 an example of how this whole schedule works -- 23 DR. SPEIS: Yes. 24 ' COMMISSIONER ROGERS: Even when that is done, ( 25 this so-called resolution still is not implementation. (202)234-4433 UEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE. N.W.. WASHINGTON, D.C. 20005 L__-____-_

's 34 8 ~ DF. SPEIS: No. it's not implementation, sir, y.; ? no. L.J 3 Tha second

ssue, we are getting good 4

cooperation f ro r" industry. It involves testing -- weli, the issue arose as a result of pilot valves sticking, you 6 know. if I want to use that word. and we're testing new 7 materials to make sure that the valves don't stick, okay? E And those have to be done in plants themselves, and we 9 expect that information to be developed in about another 10 yee. and then we'll make a decision at that tirne, if. 11 indud, you know. this is the appropriate material for 12 future usage in these valves. basically. 13 So, with that. Mr. Chairman, I complete my part 14 of the presentation, and NRR can discuss now the 15 implementation of the -- some of these issues. 36 CHAIRMAN ZECH: Thank you very much. 17 You may proceed. 18 MR. GILLESPIE: Let me sketch out the process of 19 the pathing of the work that comes from Research to NRR, 20 se you can see how it gets in our chain because this 21 becomes a part of our MPA program and, in fact, this tends 22 to be a smaller part of the overall multi-plan action 23 procram itself. 24 Generally, a package gets prepared. The ( 25 technical resolution then goes to CRGR. One of the pieces (20?)?34-443; NEAL R. GROSS & COMPANY, INC. (202)232-6600 13 ? 3 RHODE T SI.AUD AVENUE. N.W., WASHINGTON, D.C. 20005

4 8 35 i 3 that goes to CRGR is normally the technical resolution in i 2 rhe implementation vehicle. In the majority of cases. the imp 3enentation vehicle is a generic letter, be that l 4 genuric letter for information purposes -- and I'll give l sor+. examples of the different kinds or a request for 6 iofrrmation, or something that's telling someone to do 7 something. A Ue work very closely in the formulation of the-9 our-ric letter and, in fact, the process has changed in 10 about the last 1E months. In the past, a generic letter 11 would he cent out. might request some action. and it would 32 nor always require or ask the licensee to respond back to 13 us when he was complete in his action. 14 For about the last 18 months, we've been very, 15 very careful with generic letters. Anytime we ask someone 16 to do s ons thing. we're asking them to write back and tell 17 us when they've completed it. This has become a very, 18 very important step and, you know, it was a very 39 significant change. 20 From the CRGR package, we then have a generic 21 letter which is agreed upon and consistent with the 22 technical resolution. That will get then sent out to the 23 applicable licensees. At the same time it's sent out, a 24 decision is made internally as to whether it needs to be ( 25 verified or not, by the inspection group. (202)234-4433 IJEAL R. GROSS & COMPAliY, I!1C. (202)232-6600 1323 RHODE ISLAIJD AVEIJUE, IJ.W.. WASHI!JGTOlJ, D.C. 20005

i \\ ) 26 i 1 Every generic letter and every requirement is 2 not necessarily verified. Conscious decisions are 3 scretimes made net to, and many of them are not conducive 4 to verification. 5 At that point, let me give some examples which 6 go either way, and also some examples of some parallel 7 programs. We in NRR react to operational events, such as 8 nid-loop operations. In fact, in the past several years, 9 going back before the reorganization, there were bulletins 10 put out by the Office of Inspection and Enforcement on 11 -id-loop operations. This has been kind of a continuing 12 concern. It also happens to be a generic safety issue. { 13 So, we've got two processes that are coordinated 14 as they're going down, and Tom Murley's reaction was 15 partially a frustration to continued problems coming up 16 over the years in this area, which caused him to write to 17 the CEOs and all the operators. 18 In some cases -- we have a second case very 19 similar to in us reacting to operating events, we are 20 doing something that actually can produce the resolution 21 of an ongoing GSI. In another case that we have one which 22 has an inspection procedure code on it, dealing with 23 flooding of equipment. So, flooding of equipment while 24 also being addressed by A-17, is something, in fact, that 25 the regulatory arm has also been concerned about as an (20 1234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

operating e v e n t.. -i sn. indeed. all of the USIs and GSIs that you're 3

seeina, just because they have not been resolved in a 4

broader context doesn't mean the narrower, immediate 5 safety problem is not being addressed. And, in fact. in 6 sevarmi cases. we have examples where we are addressing it in parallel so that the long-term safety action is a somewhat separable from the short-term. So, it's not a 9 three-year or t wo-y e a: 3hutdown wait. 10 On the point of issuing a generic letter und 13 then making a decision on whether it's suitable for 12 inspection and whether it's of a level that needs to be 13 inspected. the inspection is then kept track of in two 14 parallel systems., which allows us to check back and forth. 15 It's kept track of in the 766 and now the master 16 inspection system. and it's also kept track of in SIMS 17 and. in fact, we bounce those against each other on about 18 an annual basis. and then we call up the regions and we 19 resolve any differences to ensure that what we thought we 20 looked at and eyeballed, we can go to inspection report 21 and see that it was satisfactorily resolved and there were 22 no outstanding items on it. And that's where it comes 23 together: at the end it's complete. 24

Now, let me go back and give some examples

{ 25 because we have different perturbations that seem to occur (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

c 38 + 1 6epending on what the requirements are coming out of the 2 17 5 I or GST. 3 Information only. We have information only 4 gunsric issues -- that is, the resolution ends up being-5 forward looking, so it is a change to the standard review 6 plan. and we send it out for information to licensees. An 7 e xampl e would be maximum permissible precipitation. This 8 affects flooding. people with dams upstream. We sent out 9 for information a new NOAA publication that said you need 10 to be aware of this, although we see no immediate problem 11 to it and, indeed, in future plants, the standard review 12 plan ther was updated so that any future plants that came 13 in would be cognizant of the current information. That 14 was generally sent out information vnly, we saw no 15 inmediate problem. 16 SPDS. SPDS -- and I might throw in a little 17 plug for our office. When the reorganization occurred, 18 SPDS was one of 11 items that NRR had cognizance of 19 because of a long history and the staff that was solving 20 it was still there. We have, in fact, as of Friday, sent 21 our last two letters to Mr. Stello, saying that we've 22 finished our mortgage. So, NRR has now completed all of 23 its assigned USIs and GSIs since the reorganization, and 24 that was a push over the last year, to get those E 25 resolutions out and complete. a. (202)234-4433 NEAL P. GROSS & COMPANY. INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

39 1 SPDA is a program where resolution has just been 2 achieved. resolution in the sense of what Themis is saying 3 is rechnical resolution. but technical resolution has 4 fundamentally also been achieved verse to implementation. 5 There we have a long-standing program where it 6 was intended to be a post-implementation review, after ~7 TMT. Utilities went forward, put in systems, the best 8 systems that they thought completed with the requirements, 9 and we never basically caught up with the paper. 10 We did do several reviews. We did almost 50 11

reviews, found certain deficiencies in certain systems 12 accuprahle. in which case, the resolution now is -- and 13 we've issued the generic letter.

We've got a NUREG 14 report but also basically a -- I'll call it -- it's a 15 checklist. but a list of attributes of what an acceptable 16 system has been found by the staff. 17 The industry is therefor now being requested to 18 look at those attributes and come back and tell us whether 19 their system fits those attributes and, if not, what are 20 the exceptions to it. This is in lieu of going out and 21 doing some very manpower-intensive efforts to review 22 systems that we basically know are in place, and in place 23 adequately. we believe. in most places. 24 So, what we've got is a cleanup job on that l l f 25 that's going on right now. and we believe that's well on { 1 (202)234-4433 NEAI. R. GROSS & COMPANY, INC. (202)232-6600 3323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 )

40 ~* ] irm way to actually being closed off and completely off 2 tDF hOo'K R. k.J - I E 1 COMMISSIONER ROGERS: Excuse me -- just on the 4 SPDR. how plant-specific are the SPDS systems? Is there a 5 big difference between SPDS systems and different combined 6 plants? 7 MR. GIL1,ESPIE: I don't want to say that because 8 I haven't. eyeballed enough of them myself to say that 9 they're -- the attributes are generally the same. Now. 10 whar -- where the wiring goes -- 11 COMMISSIONER ROGERS: Oh, yes. 12 MR. GILLESPIE: That's plant-specific. 13 COMMISSIONER ROGERS: Of course, ij j ... _J 34 MR. GILLESPIE: But the attributes -- and what 15 we're doing now really recognizes that the attributes of a 16 good system and the parameters you need to control or i 17 understand what's going on in the course of an accident, l 18 are fairly consistent from plant-to-plant. 19 How, a plant may choose to put more parameters 20 in or upgrade the system more than we even desired, and 21 that's fine, but the general basic requirements are the 22 se-e plant-to-plant -- the types of parameters we want to l 23 see, the pressures, the temperatures, the power supplies i 24 for it. 25 COMMISSIONER P,0 G E R S : So, your work now has (l _ (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 i i E._________..___

41 I raaily just been to clean up the attributes definitions? ? MP, GILIFSPTE: Yes. 3 CHAIRMATI ZECH: Well, what do you mean by the a SFiw status report then? How does it stand? 5 MR. GILLESPIE: The generic letter -- 6 CHAIRMAN ZECH: Is it in all the plants that you 7 think it's in? Can you say that for sure? Has it been 8 implemented in all the plants? C MR. GILLESPIE: It has not been implemented in 10 s11 the plants, we know -- 11 CHAIRMAN ZECH: But your work is finished, is 12 what you're telling us. In other words, as far as the '3I attributes or the requirements for the SPDS -- 34 MP. GTI,I ESPIE: Yes. 15 CHATRMAN ZECH: But you don't know are you 16 saying that you do know that it is not fully implemented 17 in all the plants? 18 MR. GILLESPIE: We do know some plants that do 19 not have it fully implemented. yes. 20 CHAIRMAN ZECH: Do all plants have it partially 21 implemented? 22 MP. GILLESPIE: I believe there's one plant that 23 does not. 24 COMMISSIONER ROGERS: Well. let's see, you had a 25 -- didn't you have a kind of tentative approval status for {. (202)234-4433 UEAI,R. GROSS & COMPANY. INC. (202)232-6600 1323 FHODE ISLAND AVENUE. N.W., WASHINGTON, D.C. 20005

I 42 1 SPDS systems? 2 MP. GILI,E S P Y E : Yes. a COMMISSIONER ROGERS: I think maybe the question 4 i s ar-all the plants except one operating under that, 5 with that kind of equipmant set? 6 MR. GILLESPIE: Yes. What we are doing now is. 7 we're really evaluating consistency with the general 8 pr-repts of what it's supposed to be. 9 CHATRMAN ZECH: If I recall, a number of plants 10 r h a t-T've visited have the SPDS system installed, and they 31 have had for sometime. 12 MR. GILLESPIE: Yes. 13 CHAIRMAN ZECH: But if we're just getting out 14 the specific attributes we want of the system, you know, 15 now. I can understand that there could be some plants out 16 there that, for some reason or other, don't have or don't 37 meet all our final requirements but, in any case, 18 certainly most all the plants I visited, I can recall, do 19 have some kind of SPDS system installed. 20 Many of them apparently have it installed it for 21 sometime, and they've used it. 22 MP. GILLESPIE: Yes. 23 CHAIRMAN ZECH: But whether or not it meets the 24 specific requirements or not that you've just released, I { 25 guess, is what you're telling us now, how are you going to (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 3323 RHODE ISLAND AVENUE. N.W., WASHINGTON, D.C. 20005

l' l t 43 1 check to make sure? Are you going to ask the utilities if ? they do -- if their SPDS is installed and has been ( 3 insta13ed for -- ria ybe for many years, does meet those 4 requirements, how are you going to find out about 5 imp 3ementation? 1 6 MR. GTLLESPIF: We've asked that question. That's the specific question that's asked in the generic ~ 8 letter. so that we will have a definitive answer which we 9 can then go out and choose to verify either completely or 10 on an audit basis, and that's a definitive answer we've i, 11 been lacking. lacking for -- 12 CHAIRMAN ZECH: But this is just kind of a 33 question of general interest. Do you have different 34 requirements, for example, for a BWR plant as opposed to a 15 PWF plant? 16 MF. GILLESPIE: Yes. I '7 CHAIRMAN ZECH: You do have? 38 MR. GILLESPIE: Yes. The parameters are going 19 to be different. 20 CHAIRMAN ZECH: Do you have different parameters 21 for each particular design plant? 22 MR. GILLESPIE: Not in general, no. I 23 CHAIRMAN ZECH: But it's generally broken down 24 into boiling water reactor and pressurized water? 25 MR. GILLESPIE: Because you're going to have (2021234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 3323 PHODE ISLAND AVENUE. N.W., WASHINGTON, D.C. 20005 l

44 I different parameters you're monitoring. 2 CHAIPMAN ZECH: I understand that. We have some 3 cider plants and some new plants, too. Some of them are 4 quite -- you know. the designs are different. That's part 5 of our regulatory challenge, is to regulate all these 6 custom-built plants. 7 MR. GILLESPIE: Right. 8 CHAIRMAN ZECH: I guess I'm trying to figure out 9 when you put out attributes for a SPDS system, it might be 10 quite di f f erent. for one of our earlier plants than one of il our later plants. even though they're both PWR or both 12 BWP 13 MP. GILLESPIE: Yes. I think you'll find the b 14 report we compiled was based on a review of 50 different 15 plants. 16 CHAIRM*iN ZECH: Yes. 17 MR. GILLESPIE: And what we've done is taking 18 the acceptable attributes across that sample of plants. 19 We firmly believe that we've covered the broad range of 20 what would be expected at any particular plant that wasn't 21 one of those 50. 22 CHAIRMAN ZECH: Have you involved the utilities 23 in any of the review process? 24 MP. GILLESPIE: No, they were not involved in 25 the review process. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

l e . =. 45 l 1 C H A I R!! AN CECH: Dr.

Speis, have you got yl 1J 2

conething you want to tell me? 3 DR. SFEIS; No, I just -- basically, the 4 information is generally the same because, you know, .s on the key parameters and information that l 5 you're focus 4 1 6 you need to -- 7 CHAIRliAN ZECH: Yes. No, I understand that, I E just wanted to know if you'd made any provision for 9 differences. 1C DF. STEIS: So, even between BWRs and PWRs, 11 it's mostly the same. There are some differences, but 12 they are essentially are the same. { 13 CHAIR 11AN ZECH: So, the utilities shouldn't be 14 surpri # -- 15 MR. GILLESPIE: Oh, no, no. 16 CHAIR 11AN ZECH: -- by the attributes that you're 17 requiring them to have. i 18 MR. GILLESPIE: No. This was very -- this was l l 19 very well worked within the staff document, to ensure that 20 we were not putting any new requirements on anybody, and 21 it's a final step in, actually, the requirements that were j 22 put out for post-implementation review in 0737 Supplement 23 1 many years ago, and this is promulgating from those 24 broad requirements, which systems that we reviewed that 25 looked very, very acceptable to the staff, what were the f (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 f 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

46 1 attributes of ' those systems. for other people to compare x2 themselves against,- and then let us.know what-are the 3 .results of their comparison, and then we can deal only by 4 exception. 5 So, it is not promulgating any new' requirements. 6 .It is trying to give examples of what we generally found 7 acceptable for requirements that have been long-standing. E CHAIRMAN ZECH: All right. Fine. Thank you. .9 Let's proceed. 10 COMMISSIONER CURTISS: On that point, do the 11 attributes that you've recently identified differ in any 12 significant way from the system that was ~ envisioned'right ( 13 after TMI in 07377 Have we focused on the bells and 14 whistles problem? 15 MR. GILLESPIE: No, we don't believe we do. If 16 anything, we've taken a step back and taken the more 17-global look, and many, many of the same people involved 18 then, were actually involved with CRGR at this time. 19 COMMISSIONER CURTISS: So, would it be fair to 20 say that on SPDS, the only real change in direction here 21 is that the -- sort of the burden of proof, if you will, 22 on demonstrating that your system complies with these 23 requirements that have been in place since TMI and that 24 have been expanded upon in this recent attributes document 25 (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 ~_

47 1 MR. GILLESPIE: Yes. is to say to the 2 COMMISSIONER CURTISS: i 3 utilir s, examine your system against this list of 4 attributes, and tell us whether you think your system 5 meets all of these attributes, identify areas where you l 6 think there are exceptions to your system -- in other 7 words, where you don't comply -- a r. then based upon that i 8 submittal, with the burden being on the utility, we will 9 then evaluate the submittal for purposes of determining l 10 whether to conduct selective audits. 11 MR. GILLESPIE: Yes. 12 COMMISSIONER CURTISS: Okay. 13 CHAIRMAN ZECH: All right. Let's proceed. l 14 MR. GILLESPIE: Proceeding down, let me give an i 15 example of one that was resolved with no new requirements 16 -- and this was on steam generators -- three long, long-17 standing issues which were finally brought to conclusion 18 this last year. 19 USIs A-3, 4 and 5 and, in fact, in this case, we 20 have the technical resolution. The basic finding was that 21 we had -- in the course of our day-to-day business of 22 operational safety, we had overcome the problem that was 23 originally formulated. 24 We did issue a generic letter, for information p.

a. -

{ 25 only and we issued it with a closeout report on what the l (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600

1 '48-o' 5 . speci fics' were. This is an older issue, again, that has 2 been now cleaned up and. documented, so if questions ever- ~- 3; con up in the future we can go back and reference it. 4 Let me give one last -- maybe one last example, 5 and that's GSI-86. It was issued by generic letter in 6 '88. and it was a long-range plan for dealing with stress 7 corrosion. cracking in BWR piping and, in fact, in that 8 case, we are going out and we are observing some of the 9 testing and inspections going on, of stainless steel 10 piping in BWRs during shutdowns. l 11

And, again, that is generally a two-year 12 envelope, and we try to get it all done within two years

!( ~ 13 because many of these tend to be event-oriented, and it 14 'just. takes that long before. you get the opportunity to 15 observe it at a plant. l. 16 That takes me through to inspection closeout. 17 It

also, I

think, demonstrates certain ones are 18 information only, certain ones are licensee response 19 without an inspection, and that covers -- those are really 20 the three alternative approaches we have.

21 Oh, I didn't focus on the chart. There is a 22 chart with some numbers, which is the status. It's page 23 19 in the handout. (Slide) We are focusing only now on 24 the high priority GSIs for inspection purposes, and we 25 totally agree and support Research, and we just focus our (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

49 I resources generally in the high area. k-- 2 CHAIRMAN ZECH: Well, let me just ask you, if 3 you didn't have any new safety issues coming up, when 4 would all the safety issues that you have identified now, 5 be resolved through implementation and verification, the 6 whole way? 7 MR. TAYLOR: I think -- 8 MR. GILLESPIE: Yes, let me give you -- I would 9 like to -- 10 CHAIRMAN ZECH: If no new ones came up. 11 MR. GILLESPIE: If no new ones came up -- 12 CHAI.RMAN ZECH: Just what we're looking at here. ( 13 MR. GILLESPIE: -- I would like to be able to 14 say within two outages from right now -- 15 CHAIRMAN ZECH: Why don't we say it. 16 MR. GILLESPIE: -- or from when the last 17 resolution that we're currently working on is out but, 18 inevitably, there is the exception, and I can give you-- 19 I've got an exception in front of me, which is reactor 20 vessel overpressurization. The last plant to be -- have 21 that implemented in it will se Comanche Peak, and it's 22 actually waiting for down the road, for after it's 23 licensed, and some things that need to go on then. l 24 So, there's always going to be that one on 25 sorae one that has an operational reason for being -- (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 l

50 1 CHAIRMAN ZECH: No, I agree. Certainly, we k 2 understand that there could be exceptions, and for valid i 3 reasons. but I guess it would be good to know that we're 4 making significant progress on these generic issues, as it 5 would appear to me we're making on the USIs. Are we? 6 MR. GILLESPIE: Yes. We generally have a two-7 outage envelope that we've been looking at when we 8 promulgate a generic letter. 9 CHAIRMAN ZECH: Well, let me just ask you this .u think the utilities themselves, the 10 then. Do 11 licensees. are making reasonable progress towards 12 implementation and resolution both, of these safety (i 13 issues? 14 MR. GILLESPIE: Yes. 15 CHAIRMAN ZECH: You think they are. And I 16 think that's very important. I recognize that, you know, 17 you have a part of the work to put out what's required, 18 but it simply doesn't solve the problem until they're 19 implemented and, as long as you feel that they are 20 responsible and responding to your direction, that's very 1 21 important, so they are making progress and you believe it 22 is reasonable progress. 23 MR. GILLESPIE: Oh, yes. I might give an l 24 example where follow-up has caused more work for us, and 25 that was emergency operating procedure inspections which (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600

i 51 I we started about a year and a half age, which actually 2 involved -- it touches upon three different resolutions 3 for three different generic issues, and we are going to 4 continue those, and we have a NUREG report being put 5 together right now to give some lessons learned from the 6 initial group of those types of inspections. We will 7 continue those inspections because we were not necessarily 8 entirely happy with the way it had been resolved and 9 irplerented in the plants, how the procedures were being 10 put in place. so we aggressively pursue -- when we do go 11 out and check on the important ones, we aggressively i 12 pursue getting adequate implementation in all facilities. { 13 CHAIRMAN ZECH: Do you make any requirements on 14 the licensees, to complete it after one outage or two 15 outage, or whatever might be reasonable? 16 MR. GILLESPIE: Yes. The way we have been 17 approaching for somewhat over a year now, when we put out 18 a generic letter, we will normally put "Please submit us a 19 schedule not to exceed two outages" right in it, so we 20 know up front what we're dealing with, and that's 1 21 CHAIRMAN ZECH: And you can keep track of that 22 and that's a commitment on their part. j 23 MR. GILLESPIE: -- and that's a commitment on 24 their part and, if there is an exception, we know about 25 the exception up front. So, our approach to the (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 eeee - mm e m c am c uan-a m o o n -ecos aam a e eaaas

52 ~ 1 proTuigation of the requirements has been very, very much ( 2 refined over about the last year and a half. 3 CHAIRMAN ZECH: Yes. Good. Excellent. 4 COMMISSIONER ROGERS: I wonder if there is any 5 kind of a little report that you could give us that 6 doesn't take an enormous amount of effort to prepare, that 7 documents in some way the kind of qualitative answer that 8 you just gave to the Chairman's question of how do you 9 fee: that industry is implementing this on a -- I take it, 10 on a rolling basis, that once they get something from us 11 and they have two outages to do it, then there's a firm 12

time, but I take it there's activity going on all the l

l 13 tire to implement these things, even if we haven't quite 14 completed our work because we have enough dialogue with 15 people that they understand that we're about ready to come 16 out with a something. I mean, is there some kind of a 17 report that you could give us, that in some way gives us 18 some picture of how this process is taking place, that 19 indicates what work is already going on in industry, that 20 isn't just waiting for the bell to rir g with a generic 21 letter coming out from NRC. Is that poss ible to do, or is 22 that too difficult to do? 23 MR. GILLESPIE: Well, I'm trying to make sure I 24 understand your question. 25 MR. TAYLOR: You'd like to have a periodic (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

I 1 53 1 \\ ~ 1 report potentially of a sample acrot.s some of the outlying { 2 1ssues that have either been delayed, or are being 1 3 accomplished. is that j 4 COMMISSIONER ROGERS: Well, I take it that what 5 we're hearing from you is that there's an NRC procedure 6 that's being followed in looking at all these things, that '7 at some point has an end, an end date, and it may be quite ( 8 far out if it depends on some operational requirement of a 9 particular plant. 10 So, if we look at that as an isolated process, 11 it doesn't give us a true picture of, in fact, what is 12 happening with implementation across the broad industry 13 picture. It may be distorted somewhat just because of O.-, 14 maybe one or two outlying plants that something is waiting 15 for that they have to operate to finally close out 16 something. 17 In other words, I think that what I'm a little 18 uncomfortable about here is that we don't really have a 4 19 sense of what the impact of the NRC activity is on what is 20 happening in industry, or already has happened in 21 industry, as a result of this. j 22 It looks like we're breaking this into an NRC I 23 generic issue resolution program and then industry 24 implementation program, that one follows the other but, in 25 fact. they overlap, is what I see you're saying. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

54 l 1 MR. GILLESPIE: Yes. Okay. ) ( 2 COMMISSIONER ROGERS:

And, so, what are the l

3-benefits that already have taken place f ro.n what we've 4 done in the way of industry implementation, that won't be 5 complete until some later date when the whole, entire 6 program resolution and implementation has been completed, 'T which may be some tine. 8 MR. GILLESPIE: Yes. We have -- at least right 9 now within the system. we have a list of items that, in in fact. have been completed or implemented before the plant-il specific SEES have been issued and they've been imposed. 12 The majority of those tend to have been TMI items, where 13 the industry had the broad direction, went out and they 14 did it, and specific SERs, or safety evaluation reports, i 15 were issued after the fact. I 16 That tends not to be the case on most issues 17 that we're dealing with today. So, yes, we -- 18 COMMISSIONER ROGERS: I'm just trying to get a 19 little more quantitative feeling about a qualitative 20 statement that you made that says, well, you feel good ) j 21 about what industry is doing here. l l 22 Now, I don't want to seem nitpicking about it, l 23 but I'd like to feel that I had a little better handle on 24 what the basis is for your judgment there. = 25 MR. TAYLOR: Why don't we make a commitment to (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

4 55 i tah a look at a potential report of some type, and we'll 2 come back to the Commission -- 3 COMMISSIONER ROGERS: I don't think we want to 4 -- I'm not asking for a major effort, but I need something 5 that -- 6 MP. TAYLOR: No, I understand, and this is a big 7 program with lots of issues across lots of plants. Why 8 don't we take a commitment from this meeting, to take a 9 look at a type of periodic report, and we'll recommend to 10 the Commission at what periodicity to provide it, 11 depending upon what -- 12' COMMISSIONER ROGERS: I think that would be 13 coad. 14 CHAIRMAN ZECH: Very useful. let us get a look at that as 15 MR. TAYLOR: 16 part of what we cake from this meeting, so that you will 17 feel more informed not only that the technical process has 18 gone on, but progress is being made, and at what degree j 19 because this is negotiated through outages, through-- 20 actually, some of these take procurement, and the planned l 21 outage work, and outages grow, and people we, of l 1 22 course, put the highest priority on the highest priority 23 generic issues, and that is from a safety standpoint, and 24 that's what we always press on, that some of the other 25 mediums may slip, (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 i 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

1 56 1 So. ier us take a commitment to try to formulate j l ( 2 some type of periodic report and come back to the 3 Comtission and at least try at giving you some periodic 4 staff report. 5 CHAIRMAN ZECH: All right. Fine. Thank you. 6 COMMISSIONER ROGERS: Good. 7 CHAIRMAN ZECH: Does that conclude your 8 presentation? 9 MR. GILLESPIE: Yes, it does. 10 CHAIRMAN ZECH: All right. Questions from my 11 fellow Commissioners? Commissioner Roberts? 12 COMMISSIONER ROBERTS: I understand we're joing 13 to hear from the ACRS next week? b. 14 CHAIRMAN ZECH: I think it's May 3rd. 15 COMMISSIONER ROBERTS: I'm not asking for your 16 response now, but will we get a response from the staff on ~ 17 the ACRS questions because they had some disagreements 18 with you. 19 DR. SPEIS: On the mid-loop operation? 20 COMMISSIONER ROBERTS: USI A-45 and generic 21 issue 99, RHR Reliability in Decay Heat. 22 MR. MINNERS: We have replied to ACRS on A-45, 23 and I wouldn't characterize that as a disagreement. 24 DR. SPEIS: We will get the information to the 25 Commission before you meet with the ACRS. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

57 3 CHAIRMAN ZECH: All rignt. Fine. Thank you. 2 DR. SFEIS: We'll do that 3 COMMISSIONER ROBERTS: That's all I have. 4 CHAIRMAN ZECH: Commissioner Rogers? 5 COMMISSIONER ROGERS: I don't think so, no. 6 CHAIRMAN ZECH: Commissioner Curtiss? 7 COMMISSIONER CURTISS: Just a couple of thi r,s. 8 Going to that last chart. to make sure I understand what 9 those numbers are there. It's labeled Summary of Generic 30 Issue Resolution Status. This really this focuses on 11 the number of actions required to implement the issues 12 that have been resolved? 13 MR. GILLESPIE: Yes. 14 COMMISSIONER CURTISS: So that the 735 issues, 15 655 have been resolved, 80 remain that we talked about in 16 the Research presentation. This is actually the 17 translation of the implementation of those resolved 18 issues? Do I read that correctly? 19 MR. GILLESPIE: Yes. 20 COMMISSIONER CURTISS: Let me go back to the j 21 schedule for a minute and ask a couple of questions. If I 22 understood what you've said, all of the three remaining 23 USIs will be resolved by the end of 1989, and 80 percent 24 of the high priority issues will be resolved by the end of 25 next year. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

58 d 1 DR. SPEIS: Yes. ( 2 COMMISSIONER CURTISS: Calendar year? 3 DR. SPEIS: Yes. 4 COMMISSIONER CURTISS: So, 16 of those have been 1 5 resolved, four remain. At the end of 1990, if we have no 6 new issues, we'd have four high priorities. Do we have a 7 schedule for the 13 medium priorities? 8 DR. SPEIS: We have a schedule for all of them. 9 COMMISSIONER CURTISS: Do you have an idea, say, 10 at the end of 1990, where we will be on the medium 11 priorities? 12 DR. SPEIS: On the medium -- I have some of my 13 notes here -- 70 percent next year. 14 COMMISSIONER CURTISS: By the end of '907 15 DR. SPEIS: By the end of '90, yes. That's an 16 approximate -- 17 COMMISSIONER CURTISS: The question I'm really 18 driving at is, under the Part 52 regulations that we put i 19 out. where the applicant for a design, certification has to 20 propose a solution to, what: the medium and the high 21 priority issues? 22 DR. SPEIS: Yes. Yes. Yes. ) 23 COMMISSIONER CURTISS: At the end of 1990, those 24 will be roughly four high priority and whatever 30 percent 25 of 13 iu, that will still be unresolved, that will be the l (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

59 I poo? of issues that would be unresolved that, for the ( 2 purposes of a design certification, the applicant would 3 have to address? 4 DR. SPEIS: Yes, that's true, but you have to 5 realize that the resolution of most of these issues is 6 clear -- you know, because we are talking about potential 7 enhancements to existing plants, we have to go through the 8 backfit rule, okar, so this is a very easy problen to 9 resolve for future plants, where you are starting from 10 scratch, from -- you know -- and the improvements that are 11 called in these issues, it's very easy to accommodate. 12 So, industry has told us that 99 percent of the times 13 there's no problem, they know how to resolve, and we agree 14 with them, okay. So, in most instances, again, you know, 15 the difficulty we're having is not a difficulty, the time 16 that it takes us to complete a resolution for existing 17 plants is that we'll have a number of options, okay, and 18 we have to go through the backfit and the regulatory 19 analysis for that. 20 COMMISSIONER CURTISS: You see a fairly clean 1 21 process for the new plants. 22 DR. SPEIS: Much more clean, yes, much more 23 clean, and we have discussed this. In fact, when we n p. 24 started the process of reviewing the EPRI requirements /_ 25 document, okay -- and we worked through every issue, and (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON. D.C. 20005

3 = l 60 1 it was clear from those discussions that there was no l [ 2 problem resolving most of these issues, okay, for future j 3 plants it's much easier. You know, most of them involve, l l 4 for example, a material that we know works versus 5 something that was put into a plant 15 years ago, you 6 know. It's not very easy to go in and break something l 7 down, but for a future plant, it's no problem. 8 COMMISSIONER CURTISS: That's all I have. 9 CHAIRMAN ZECH: Well, thank you very much for a 10 very useful. discussion of the results of your efforts to 11 improve the processing of these generic safety issues. 12 The progress, as far as I'm concerned, that's been made 13 since our last meeting is very encouraging, and I'm 14 pleased that all unresolved safety is_ sues are scheduled to 15 be resolved by the end of this year. 16 I commend the staff for this very aggressive 17 effort. You 've heard f rom the Comtaission, I know at least 18 the years that I've been on the Commission, about trying 19 to do a better job in resolving these generic issues and 20 unresolved safety issues, and I feel that you have made 21 real progress, significant progress, and I think that we 22 can all be encouraged by the progress you've made, and I 23 certainly commend you for the efforts, and ask you to 24 continue the momentum you've got going and to keep it up. 25 You did describe the rigorous process that (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

j 61 ~ 1 requires a coordination among ycur own technical {j 2 organizations as well as those outside the NRC, and I 3 recognize that that coordination process is a challenge, 4 but I think the significant efforts you've made to 5 complete resolution of these

issues, and the 6

implementation, too, and the follow-through to make sure 7 that they do get implemented and verified, really, I feel 8 that we do have a good handle on this program now, 9 certainly much better than we had a few years ago and, 10 again, I commend you for the progress that you've made, 11 all of you, Research as well as NRR. However, there 12 really does appear to be a '. o t more work to be done, and 13 the remaining issues are not insignificant, as we know, E 14 and as time goes on and we learn more, we may add to the 15 list. 16 So, I would certainly encourage you to press 17 forward and complete the work as efficiently and timely as 18 you can, while at the same time maintaining a very high 19 quality of your technical efforts. Safety is our business i 20 and that's what it's all about, so we do care about 21 schedules, and we do like to see progress but, again, we l 22 count on you mainly to resolve them technically and de the 23 right thing and, certainly, my observation of your efforts 24 in that regard is that's exactly what you're doing, but 25 please keep in mind that quality of the work is awfully l l (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

62 l l 1 important and we appreciate that. \\ l 2

And, so, as far as I'm concerned, I'd rather

( 3 have you take the time you need to do it right, than to 4 hurry up with a schedule, but it is important we make 5 progress here. and I think we are making progress, and I'm 6 pleased to see that. 7 The Commission will want to continue to monitor 8 the progress that you are making, and I believe it would 9 be helpful for at least another progress report on this 10 matter. perhaps sometime not too long after the first of 11 the year. when you expect to finish your unresolved safety 12 issues, it might be appropriate to come to the Commission 13 at that time and give us another report on this whole 14 issue. 15 So. again, I commend the staff for the progress l 16 you're making. It's very encouraging. 17 Any other comments from my fellow Commissioners? i 18 (No response.) 1 19 If

not, thank you very much.

We stand 20 adjourned. 21 (Whereupon, at 11:23 a.m., the meeting was l 22 adjourned.) l 23 24 25 (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005

o.. se CERTIFICATE OF TRANSCRI'BER This is to certify that the attached events of a meeting of the United States Nuclear Regulatory. Commission entitled: TITLE OF MEETING: BRIEFING ON THE STATUS OF GENERIC ISSUES PLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING: APRIL 25, 1989 were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the feregoing events. 0 mm O U (; Reporter's name: Phyllis Young l l 4 NEAL R. GROSS COUNT Rf*0 tift $ AND TRANSCRIBERS 1323 RHOOf IShANO AVENUE, N.W, (202) 234-4433 WASHMGTON, D.C. 20005 (202) 232 6

t: j ' l ConMISSION BRIEFING CN THE STATUS OF THE GENERIC ISSUES PROGRAM T. P. SPEIS RES, X23710 APRIL 25, 1989

CONTENTS PAGE IDENTIFICATION, PRIORITIZATION, RESOLUTION (RES) e HISTORY PR0 CESS....................................... 1 RECAP......................................... 2 PROGRESS SINCE 10/21/87 BRIEFING.............. 4 e STATUS OF ISSUES REMAINING USlS................................ 7 SELECTED GSIS CSI 99................................... Il GSI B-56................................. 14 e OTHER ACTIvlTIES REVIEW OF LOW PRIORITY ISSUES................. 17 e SOME REASONS FOR SCHEDULE SLIPPAGE DELAYS........... 18 IMPOSITION, IMPLEMENTATION, VERIFICATION (NRR) e

SUMMARY

OF GENERIC ISSUE RESOLUTION STATUS......... 19

GENERIC ISSUE PROCESS-IDENTIFICATION [tt l l V FRIORITIZATION RES V RESOLUTION u d i V IMPOSITION NRR v IMPLEMENTATION l I V VERIFICATION NRR & REGIONS v 1

RECAP 8 PROGPAM STARTED If4 1981 WITH 511 ISSUES IDENTIFIED TO BE PRIORITIZED: TMI ITEtiS (NUREG 0660 - 369 8 0737) ~ NUREGS 0371 E 0471 - 142 511 2 1

8 ADDITIONAL 224 ISSUES (INCLUDING HUMAN FACTORS ISSUES) IDENTIFIED IN THE PAST 8 YEARS S TOTAL ISSUES IDENTIFIED AS OF 04/25/89 = 735 l l l L___------

4 1 l PROGRESS SINCE 10/21/87 BRIEFING RESOLVED 10/21/87 5/12/88 4/25/89 PRIORITIZED LOW 25 24 24 PRIORITIZED DROP 62 66 73 INTEGRATED w/oTHER ISSUES 119 121 122 RESOLUTION ~ DEFINED IN NUREG-0737 88 88 88 RESOLVED 275 285 303 NON-SAFETY (LI, RI, EE) 41 44 45 SUB-TOTAL: 610(+18) 628(+27) 655 4

= ISSUES STILL To BE RESOLVED 10/21/87 5/12/88 04/25/89 USIs 9 9 3 HIGH 32 28 20 MEDIUM 16 12 13 NEARLY RESOLVED 12 11 ~ 8 TO BE

PRIORI, M

45 36 SUB-TOTAL: 121 105 80 5 l

1

SUMMARY

10/21/87 5/12/88 04/25/89 RESOLVED 610 (83%) 628 (86%) 655 (89%) TO BE RESOLVED 12_1 (17%) 105 (14%) 80 (11%) TOTAL: 731 733 735 6 1

j + l REMAINING USIS A-17 A-40 A-47 7 )

USI A-17: SYSTEMS INTERACTIONS 5-YR. PLAN RESOLUTION DATE: 12/89 CURRENT RESOLUTION DATE: 12/89 STATUS: CRGR REVIEW OF DTR 10/88C ACRS REVIEW OF DTR 08/88C CRGR REVIEW OF FTR 09/89 ACRS REVIEW OF FTR 09/89 FRN 12/89 j l 8 i i i J

i i USl A-40: SEISMIC DESIGN CRITERIA 5-YR. PLAN RESOLUTION DATE: 06/89 CUFP.ENT RESOLUTION DATE: 06/89 STATUS: CRGR REVIEW OF DTR 03/88C ACRS REVIEW OF DTR DECLINED CRGR REVIEW OF FTR 04/89 ACRS REVIEW OF FTR 04/89 FRN 06'/89 l 9

i l l USI A-47: SAFETY IMPLICATIONS OF CONTROL SYSTEMS 5-YR. PLAN RESOLUTION DATE: 06/89 CURRENT RESOLUTION DATE: 08/89 STATUS: CRGR REVIEW OF DTR 12/87C ACRS REVIEW OF DTR 11/87C CRGR REVIEW OF FTR 03/89 ACRS REVIEW OF FTR d4/89 FRN 08/89 l l 10 w-_-

{ GSI-99, " LOSS OF RHR CAPABILITY IN PWRS" (HIGH PRIORITY) 8 FOCUSED ON 2 MODES OF CCF OF RHR C00L i fig : AIR BINDING OF RHR PUMPS DURING MID-LOOP OPERATIONS LOSS OF RHR PUMP SUCTION DUE TO AUTOCLOSURE INTERLOCK-RELATED SPURIOUS CLOSURES OF THE RHR SUCTION / ISOLATION VALVES l1

1 GSI-99 CONT'D.) ISSUE RESOLVED IN 10/88. GL 88-17 ISSUED TO PWR OLS 8 CPS WITH GUIDANCE AND RECOMMENDATIONS TO REDUCE THE LIKEllH00D AND CONSEQUEllCES OF A LOSS OF DECAY HEAT REMOVAL: IMPROVE PROCEDURES AND INSTRUMENTATION TO HELP OPERATOR PREVENT AND MITIGATE LOSS OF DECAY HEAT REMOVAL l i o

GSI-99 (CONT'D) DEVELOP PROCEDURES THAT WILL PERMIT TIMELY CLOSING OF CONTAINMENT OPENINGS DURING A DEGRADATION IN DECAY HEAT REMOVAL. I 13 l 1

B-56, " DIESEL GENERATOR RELIABILITY" (HIGH PRIORITY) 5-YR, PLAN RESOLUTION DATE: 09/89 CURRENT RESOLUTION DATE: 09/89 STATUS: CRGR REVIEW OF DTR 09/88C ACRS REVIEW OF DTR 11/88C ISSUE REG. GUIDE FOR COMMENT ll/88C CRGR REVIEW OF FTR 07/89 ACRS REVIEW OF FTR 07/89 ISSUE FINAL REG, GUIDE 09/89 l I 14

B-56 (CONT'D.) RESOLUTION OF USI A-44 INCLUDED THE NEED FOR A DIESEL RELIABILITY PROGRAM TO MAINTAIN THE RELIABILITY LEVEL OF EDGS AT OR ABOVE LEVELS SELECTED FOR RESPONSE TO THE SB0 RULE (10CFR50.63) I5

d B-56 (Cor T'D) e CONCLUDING STAFF EFFORTS DIRECTED AT DEFINING THE PRINCIPAL ELEMENTS OF AN EDG RELIABILITY PROGRAM AND TECHNICAL GUIDELINES FOR NRC USE IN REVISION OF REG. GUIDES, SRP, AND IfJSPECTION MODULES. 8 COORDINATING WITH NUMARC TO DEVELOP A RELIABILITY PROGRAM CONSISTENT WITH INDUSTRY PRACTICES AND COMMISSION DESIRE TO MINIMlZE UNNECESSARY TESTING. I6

I i 1 i REVIEW OF LOW PRIORITY ISSUES IN ACCORDANCE WITH COMMISSION REQUEST, EXTENSIVE STAFF REVIEW OF 25 LOW PRIORITY ISSUES RESULTED IN 1 ELEVATED TO HIGH: GSI 15, " RADIATION EFFECTS ON REACTOR VESSEL SUPPORTS." TASK ACTION PLAN FOR RESOLUTION BEING DEVELdPED BY STAFF. l l7 t Iw_

l DELAYS S DEPENDENT ON IhDUSTRY ACTIONS FOR RESOLUTION E.G., GSI-29, " BOLTING DEGRADATION OR FAILURE IN NUCLEAR POWER PLANTS." 8 DEPENDENT ON PLANT EXPERIENCE TO DEMONSTRATE EFFECTIVENESS OF RESOLUTION, E.G., GSI B-55, " IMPROVE RELIABILITY OF TARGET ROCK SAFETY RELIEF VALVES." 18

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