ML20247D764
| ML20247D764 | |
| Person / Time | |
|---|---|
| Issue date: | 09/07/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1754, NUDOCS 8909150066 | |
| Download: ML20247D764 (250) | |
Text
lCl&P /75'qL ^
/ m J\ ,J . ,M Q - l UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS ,
In the Matter of: )
)
353rd GENEPAL MEETING )
O Pages: 1 through 189 Place: Bethesda, Maryland
~~
Date: September 7' 19 -
u Ic'e
- v. ,cpy - R" eta *m-70r the Ufe of tiio Commide O HERITAGE REPORTING CORPORATION OglainfReporter 1229 L Stroei, N.W., Suke 648 g.y1;. .s s=0;c7 Washington, D.C. 20005 T-1754 n . ,- (202) 626 4884
r~
~
1 PUBLIC NOTICE BY THE 2 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4' September 7, 1989 5
6 7 The contents of this stenographic transcript of 8 the proceedings of the United States Nuclear Regulatory _
9 Commission's Advisory Committee on Reactor Safeguards 10 (ACRS), as reported herein, is an uncorrected record of the 11 discussions recorded at the meeting held on the above date.
12 No member of the ACRS staff and no participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statement or data contained in this h 15 transcript.
16 17 18 19 20 21 22 23 24 25 f}
Heritage Reporting Corporation (202) 628-4888 1
E_ _ - -
p; l
. /~}
\_]
UNITED STA'1ES NUCLEAR REGULATORY COMMISSION
~
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS In the Matter of: )
)
353rd GENERAL MEETING )
Thursday, September 7, 1989 Room P-110, Phillips Building.
7920 Norfolk Avenue Bethesda, Maryland The meeting convened, pursuant to notice, at 8:30 a.m.
BEFORE: DR. FORREST J. REMICK Chairman, ACRS Associate Vice-President for Research Professor of Nuclear Engineering The Pennsylvania State University University Park, Pennsylvania
.O- ACRS COMMITTEE MEMBERS PRESENT:
MR. CARLYLE MICHELSON, Vice Chairman Retired Principal Nuclear Engineer Tennessee Valley Authority Knoxville, Tennessee, and Retired Director, Office for Analysis and Evaluation of Operational Data U.S. Nuclear Regulatory Commission Washington, D.C.
MR. JAMES CARROLL Retired Manager, Nuclear Operations Support Pacific Gas & Electric Company San Francisco, California MR. CHARLES J. WYLIE Retired Chief Engineer Electrical Division Duke Power Company Charlotte, North Carolina O Beritage Reporting Corporation (202) 628-4888
i 2
O ACRS COMMITTEE MEMBERS PRESENT:
uR. CHESTER P. SIESS Professor Emeritus of Civil Engineering University of Illinois Urbana, Illinois
~DR. PAUL G. SHENMON Professor, Mettalurgical Engineering Department' Ohio State University Columbus, Ohio DR. IVAN CATTON ACRS COGNIZANT STAFF MEMBER:
MR. HERMAN ALDERMAN DESIGNATED FEDERAL OFFICIAL Raymond.Fraley 10 l
Reporting Corporation Heritage (202) 628-4888 C_..___.____.______ . . _ _ _ _ . . _ _ _ _ _ _ . _ . _ _ _ . _ _
p p
3 O 1 EB2CEERIHGE 2 DR. REMICK: Good morning, ladies and gentlemen.
3 The meeting will now come to order.
4 This is the first day of the 353rd Meeting of the
-5 Advisory Committee on Reactor Safeguards.
6 I am Forrest Remick,. Chairman of the Committee.
1 7 During today's meeting the Committee will hear 8 about and discuss the following. Maintenance of nuclear 9 power plants, nuclear power plants license renewal, 10 individual plant examination for external events, industrial 11 sabotage, accident severity scale, and future ACRS 12 activities.
13 Topics for consideration on Friday and Saturday
() 14 are listed on the scheduled posted on the bulletin board 15 outside the meeting room.
16 The meeting is being conducted in accordance with 17 the provisions of the Federal Advisory Committee Act and the 18 Government in the Sunshine Act.
19 Raymond F. Fraley is the Designated Federal 20 Official for the initial portion of the meeting.
21 We've received no written statements or requests 22 to make oral statements from members of the public regarding 23 today's sessions.
24 A transcript of portions of the meeting is being 25 kept and it's requested that each speaker use one of the
[]
\d Heri' cage Reporting Corporation (202) 628-4888
l
- l 1 ,..\ 4
('~' )
1 microphones, identify himself or herself, and speak with 2 sufficient clarity and volume so that he or she can be 3 readily heard.
4 I have a few items of current interest. Limerick 5 2 was issued a full power license on the 25th of August.
6 The issues of severe accident mitigation design alternatives 7 have been remanded to the licensing board. But I understand 8 that Philadelphia Electric and the interveners, Limerick 9 Ecology Action, perhaps have reached a settlement on those 10 issues and apparently have petitioned the licensing board to 11 terminate those proceedings.
12 Also, Pilgrim completed 50 percent power tests and 13 has been approved to go up to 75 percent of full power.
() 14 They were fined or there's a proposed fine of $25,000 for a 15 procedure violation. Apparently they failed to properly 16 align the valves which would have isolated the RCIC system 17 and as a result experienced an interfacing LOCA. About 100 18 gallons of water was released through safety valves on the 19 RCIC system.
20 Ft. St. Vrain has been shut down permanently. I 21 think you are aware of the fact that they had planned to 22 operate until June but they discovered some cracks in their 23 steam generator header and so they decided to shut down 24 early and I guess they are planning on shipping fuel. And I 25 believe that goes to Idaho.
U Heritage Reporting Corporation (202) 628-4888
1 In talking to Chet this morning, most of the de-2 fueling will take about two and a half years. Is that what 3 you said, Chet?
4 DR. STESS: Yes.
5 DR. REMICK: Northern States Power has requested 6 permission to decontam3nate and decommission the fuel 7 handling and the reactor building of the Pathfinder reactor.
8 Of course, that's been shut down since 1967. It was an 9- Allis Chalmers BWR and it was a 59-megawatt demonstration 10 reactor. A 59-megawatt electric demonstration reactor.
11 MR. CARROLL: The Pathfinder that lost its way.
12 DR. REMICK: Yeah. I forget--that was to be a 13 super heat. Did it ever operate with super heat? I forget.
,i V 14 MR. CARROLL: Yeah.
15 DR. REMICK: It did? Okay.
16 MR. CARROLL: But they had some horrendous stress 17 corrosion cracking problems.
18 DR. REMICK: There is a distinguished university 19 somewhere north of here that has some of the unused 20 Pathfinder fuel that they would like to get rid of.
21 And item of interest. DOE recently awarded a $50 22 million contract to Westinghouse to complete the design of 23 the AP-600, and apparently EPRI and Westinghouse will 24 provide the remainder of the funds to complete the design on 25 the AP-600. So that should presumably move that design Beritage Reporting Corporation (202) 628-4888
, 6 w_
1 along.
2 Of incidental interest perhaps to the Committee, 3 the Commission has amended Part 2 of its regulations 4 refining some aspects of the hearing process to reduce 5 possible misuse of that process. It's interesting to note 6 that that began, that revision began in 1981 with the 7 Regulatory Reform Task Force. In fact, I was in one of 8 their review groups for that. If you recall, I remember 9 since I've been on the Committee Jim Turtilot came in and 10 talked to the Committee several times about that. Well, it 11 only took eight years to complete those revisions, but I 12 think they are definitely improvements from my perspective.
13 An item of a little bit of confusion, you probably n
(_) 14 read that Chairman Kerr has indicated the NRC may decide not 15 to review foreign design reacto:cs that are not likely to be 16 built in the U.S. And apparently he was referring to 17 reactors like Pious and Can Do III. He'd like to speed up 18 the review of ABWR. If I read the press properly.
19 He also indicated that they might consider 20 dropping review of the EPRI Advanced Lightwater Requirements 21 document because the staff is moving ahead on a case-by-case 22 basis and if they make all the decisions on a case-by-case 23 basis, why review the requirements documents.
24 I think this has resulted in some confusion on the 25 part of the staff and t'ae industry who have indicated that
(~%.
\~/ Heritage Reporting Corporation (202) 628-4888
l
, /~) 7 j i \-)
1 they are opposed to dropping that review, and we expect 2 there will be some further clarification on that.
3 Also you should have either received personally 4 yesterday or in your hotels two sets of documents for 5 tomorrow's review of the Seabrook license. If you have not 6 received personally or you did not find them in your hotel, 7 please let me know now, those of you who are here, because 8 we'll make sure you get copies. If you haven't read them 9 yet, you've got some reading tonight.
10 Also, another batch came in yesterday which are 11 being reproduced and they are, I'm told, about four to six 12 inches in depth also. Those will be delivered to us 13 sometime today.
(_/ 14 MR. CARROLL: Well, now, we were given at the 15 Subcommittee Meeting yesterday some documents.
16 DR. REMICK: Those were the first two, yes.
17 MR. CARROLL: Oh, okay.
18 DR. REMICK: And for those who weren't at the 19 Subcommittee, they were delivered to your hotels. You've 20 been properly served.
21 MR. CARROLL: But there's yet some to come?
22 DR. REMICK: There's another stack that arrived 23 late yesterday being reproduced and will be distributed 24 sometime today.
25 Are there any other items of interest from other O
'2 Heritage Reporting Corporation (202) 628-4888
l m
8 l ( ')
1 Committee members? y 2 If not, the first item for discussion on the 3 agenda today is the maintenance of nuclear power plants.
4 Carlyle Michelson, our Vice Chairman, is the Chairman of the 5 Subcommittee.
6 Carl, I turn the meeting over to you.
7 MR. MICHELSON: Thank you, Mr. Chairman.
8 The material for the presentation this morning is 9 in Tab 2 of your book.
10 Than main thing we'll discuss this morning is the 11 Draft Policy Statement which is one of the first documents 12 in Tab 2. You will also find there is a Draft Regulatory 13 Guide which we are not intending to discuss since it will be
() 14 considered at a later meeting.
15 The ACRS has written two letters lately on the 16 subject of maintenance. The first one was a September 13, 17 1988 letter concerning the propc .d rule making which was 18 going on at that time. In that letter we indicated that we 19 did not think the proposed rule making should proceed.
20 We subsequently on April 11, 1989 wrote another 21 letter on the maintenance rule making in which we reiterated 22 our position that the rule making should not proceed.
23 Subsequent to that time, the Commission has 24 decided not to proceed immediately with rule making, but to 25 put it in abeyance for a period of time, perhaps the order Heritage Reporting Corporation (202) 628-4888
9 i i
\
1 of eighteen months, in which to give the industry a chance 2 to see what it could do.
3 The staff is here this morning to tell us what 4 this new proposed policy will consist of. It's our intent I 5 believe to write a letter on this matter after the 6 presentations, which I understand should probably take in 7 the order of one hour.
8 I will have a draft letter prepared to entertain.
9 There was no subcommittee meeting, so it's only a one person 10 draft so far. I'd like to get enough of the work out of the 11 way though so that we can get the letter out at this meeting 12 since the Commission is anxious to hear our views on this 13 matter.
() 14 So I'd like to proceed now with the staff 15 presentation, unless there are questions.
16 DR. SHEWMON: The draft you refer to is in here, 17 or to be distributed--
18 MR. MICHELSON: No. The Draft Policy is in Tab 2.
19 DR. SHEWMCN: Oh. Your draft letter--
20 MR. MICHELSON: Oh, my draft. We can distribute 21 it now or later, as you wish. It is ready for distribution.
22 I thought I would wait until after the presentation and then 23 just put it out as one possible proposal.
24 DR. SHEWMON: If we had it before us, it might--
25 MR. MICHELSON: If you wish. I didn't know Heritage Reporting Corporation (202) 628-4888
. 10 1 whether you wanted to look at it before or after you--
2 DR. SHEWMON: I think it's a good idea to have it 3 before us.
4 MR. MICHELSON: Okay.
5 DR. SHEWMON: We might want to ask questions.
I 6 MR. MICHELSON: Herman has it. Herman has it 7 ready.
8 So with those few statements, I believe the staff 9 is prepared to proceed with their presentation.
10 I believe you have in front of you also a new 11 mark-up of the Policy Statement with I understand some very 12 minor changes. You should be aware that some minor changes 13 have come in since we received the draft that's in your
() 14 book.
15 MR. WYLIE: This is in Tab 2?
16 MR. MICHELSON: No , no. This is in a handout 17 called "Predecisional."
18 MR. WYLIE: Oh, okay.
19 MR. MICHELSON: It was just handed out a short 20 time ago.
21 MR. WYLIE: I see.
22 MR. MICHELSON: So you should be looking really at 23 that mark-up as the document to judge.
24 MR. KING: My name is Tom King. I am with the 25 Office of Research. My branch has the lead for developing Heritage Reporting Corporation (202) 628-4888 l
l l- 11
. g-]
'~
l the revised Policy Statement.
2 You were given a draft of the Policy Statement, 3 revised Policy Statement, back in early August, and as Dr.
4 Michelson said, at the time we sent you a copy of that, we 5 also sent it out for interoffice review. In the process of 6 getting concurrence from the offices, we've gotten some 7 comments. I think those are fairly minor comments, but they 8 are reflected on the draft that was handed out today. And 9 the handwritten stuff on there reflects the comments.
10 I'll touch on any of the more important ones as I 11 go through the briefing today, but most of them are just 12 editorial word engineering-type things.
13 The purpose of the briefing today is to brief you
() 14 not only on the revised Policy Statement but to give you an 15 overview of our plan, strategy and schedule for responding 16 to the SRM that came out from the Commission back in June in 17 response to the final Proposed Rule. And then we'll also 18 brief you on the content of the Policy Statement, and we are 19 asking for a letter on the Policy Statement. Not on the Reg 20 Guide or schedule or type things, but on the content of the 21 Policy Statement.
1 22 DR. REMICK: Why is that again, Tom? That only 23 the letter and not the Reg Guide?
l 24 MR. KING: The Reg Guide is out for public comment 25 now.
^
'- Heritage Reporting Corporation (202) 628-4888
a' 12 {
l(2). 1 DR. REMICK: I see.
i
. 2 MR. KING: I think our plans are to--the public l 3 _ comment period closes December 1st. We will then take those.
i 4 comments and work on another version of the Reg Guide.
5- You've already seen the Reg Guide that's'out now for 6 comment.
7 DR. REMICK: Right. Okay.
8 MR. KING: .At a later date, when we revise it 9 reflecting public comments, we'll want to come back and talk 10 about it, but not today. You've seen the version that's 11 out.
12 Scheduler of items, we are hoping to have this 13 revised Policy Statement to the Commission by the end of
() 14 this month for their consideration and hopefully approval.
15 We.have a meeting with CRGR next week on it, next Wednesday.
16 We brief the Commission next Friday on the scheduler aspects 17 of this whole response to the SRM.
18 Slide 2 is just where we talked about that our 19 final rule-making package has gone to the Commission in 20 April. They responded in June. A number of items in an SRM 21 and we'll talk about those here in a minute.
22 MR. MICHELSON: What Commission response--are you 23 .
going to tell us about the schedule later as to when you 24 expect to wrap this up, or is that--
25 HR. KING: Yes. That's coming up very shortly.
O- Heritage Reporting Corporation (202) 628-4888
13 1 ' MR. MICHELSON: Okay.
2 MR. KING: We'll do that before I get it.to the SRM 3 DR. SHEWMON: Tom.
4 MR. KING: Yes.
5 IMR. SHEWMON: Orient me a minute. Carl was-6' talking about something that the Commission was going to 7 hold off.on for eighteen months or fifteen or something.
8 That presumably was a rule.
9 You've given us a rule on the top of one of your 10 pages. I guess that one--it says "A Policy' Statement has 11 been issued." The Policy Statement was in lieu of the rule, g 12 as totally independent of the rule? Is the rule going to be
, 13 held up for fifteen months? The issuance? Is something.
14 changed from that?
15 MR. KING: Let me step back and review the bidding 16 here.
'b 17 The Commission originally issued a Policy 18 Statement back in March of '88 that stated their 19 expectations for maintenance and stated their intention to 20 pursue rule making. The staff developed a proposed rule, j 21 went out for comment in November of ' 88 and then submitted 22 the final rule in April of '89 to the Commission.
23 The Commission, in reviewing that final rule- j 24 making proposal, decided they weren't ready to issue the 25 rule at that time. That they wanted to put out a reviued Beritage Reporting Corporation (202) 628-4888
14
~0 1 Policy Statement, and sit back and reflect further on the 2- need for a rule, or a need for any additional regulatory 3 action.
~
4 What we are talking about today is that revised
.5 . Policy Statement. Now, as a part of that Commission 6 direction, they said they_would hold in abeyance for 7 eighteen months any action on the rule until they decide 8 what they want to do. At the end of that' eighteen months, 9 as I understand'it, there may be a rule. There may not be a 10 rule. There may be some other action. It's unclear at this 11 ' point what exactly will happen at the end of eighteen 12 months. But I have a schedule that will talk about what's 13 going to happen in that eighteen-month period.
(f 14 DR. SHEWMON: Thank you.
15 MR. KING: Okay. The SRM had basically five major 16 elements. We asked the staff-to go ahead and issue a 17 revised Policy Statement and it gave some direction, some 18 guidance, as to what should be in th.at Policy Statement.
19 And we'll hit that in detail later.
20 Research was assigned the responsibility to do 21 that. And also.gave us permission to go ahead and publish 22 our draft Reg Guide that was developed as part of the final.
23 rule making package. And said let's try and get that Reg 24 Guide in final form in time for issuance of the rule at the 25 end of this eighteen-month period if the Commission does Beritage Reporting Corporation (202) 628-4888
,r- 15
\'~'
)<
1 decide to go forward with the rule.
L Research has the lead to work on that Reg Guide as 3 well. Asked AEOD to go ahead and proceed with validation 4 and implementation of their maintenance effectiveness 5 indicator. And to work with the industry on the additional 6 effectiveness indicators.
7 And it asked the Office of Enforcement to 8 establish criteria to determine when an order or some other 9 enforcement action on maintenance should take place over 10 this eighteen-month period while this revised Policy 11 Statement is in effect. And the Office of Enforcement has 12 the lead on that.
13 And then finally it asked in these activities to r-(_)S 14 coordinate with ACRS.
15 Those are the major elements of the SRM.
16 Let's talk now before we get into the Policy 17 Statement, I'd like to talk about the schedule and the 18 strategy for dealing with those various items.
19 Basically the main elements of what we are trying 20 to do over the eighteen months are summarized on this slide.
21 We hope to have the revised Policy Statement published in 22 October of this year. That really starts the clock for this 23 eighteen-month period that the Commission talks about in the 24 SRM. That would mean in April of ' 91 the eighteen-month 25 period would be over.
Heritage Reporting Corporation (202) 628-4889 l
1 1
.fm 16 b 1 We plan to work on the standard using the form of 2 our draft Reg Guide and have it available prior to the end 3 of this eighteen-menth period. And we'll talk about that a 4 little more.
5 I think it's important in working on this standard 6 that the industry participate with us. We get the benefit 7 of their experience and their insight into maintenance and 8 we have been encouraging them as much as possible to help 9 comment and work with us, participate in the workshop, and 10 so forth on developing this standard.
11 We are also providing an option for the industry 12 to come in and propose their own standard if they think they 13 have something better than this draft Reg Guide. The
) 14 revised Policy Statement does allow for them to come and 15 propose it. As I said, the Policy Statement does encourage 16 voluntary industry adoption of this standard whether it's 17 our Reg Guide or whether it's one they propose. We would 18 like to see them voluntarily adopt it.
19 We plan by April of ' 91, as I said, to go to the 20 Commission with a recommendation on what additional 21 regulatory action we feel the Commission should take in the 22 maintenance area.
23 And prior to that time, we are shooting now for l 24 January of ' 91. We plan to have a proposal final rule and 25 Reg Guide developed in case the Commission does decide they 1
(' Heritage Reporting Corporation (202) 628-4888 1
17
?
J- 1 want to continue with a rule, we will have something
.2 . developed and sent to them for information. Right now we 3 are planning for January of ' 91. And have that ready.
4 But as a major elements schedule, page 5 has a 5 schedule. And I know this violates'all ACRS rules for 6 readability on the Vu-Graph machine, but maybe you can turn 7 to your handout. I wanted to put it all 'cn1 one page.
8 DR. REMICK: Believe it or not, Tom, we've seen v
9 worse.
10 MR. KING: You've seen worse? All right.
11 And it really covers all the elements that are in 12 the SRM in a-little more detail.
13 The first item is a Policy Statement. I already 14 And ta't a little about the Reg Guide.
.( ) talked about that.
15 That's the second item down.
16 As I said, we have that out now for public 17 comment. It was announced in the Federal Register on August 18 17th. The comment period closes December lat. During this 19 time period we are trying to obtain the services of some 20 outside experts in maintenance to help us work on it.
21 Review the public comments and develop the next draft. We 22 are allowing about three months from the time the public 23 comment period closes to the time we'd like to have the next 24 draft available. And that will be in time to support a 25 workshop, which right now we are hoping to schedule and hold Heritage Reporting Corporation (202) 628-4888 E_1_____ _ _ _ ___ .__ _ .f
n
/O .1 . in April of 1990.
1
-t 2 HR. MICHELSON: Let me ask, Tom. As I understand l, ~3 it, . tu intent of the Policy Statement is to say that we are 4 going to hold off and see what industry can do.. In the 5 meantime,1we are going to prepare just in the unlikely event 6 they don't come through.
7 Is that the basic plan?
8 MR.-KING: Yes. I think the Policy Statement 9 really does.a couple of things. One, it states what the 10 Commission would like to see in terms of improved 11' maintenance in.the industry in general terms. That they'd 12 like to see a standard develop. They'd like to see the 13 industry volunteer to adopt that standard. They believe
() 14 additional improvement is needed in the maintenance area.
15 It' also states the Commission's actions that they plan to 16 take over this time period. One of those is to work on the 17 standard and try to get industry to help us work on that
'18 standard.
19 MR. MICHELSON: Well, what puzzles me a little bit 20 is most of the next eighteen months is going to be taken in 21 preparing a standard and the Regulatory Guides and so forth.
1
-2 That doesn't leave much time in which the industry can 2 implement these standards and show by performance that a 24 rule isn't needed. Because you decision on proceeding with 25 rule making is roughly eighteen months off, if I understand O Heritage Reporting Corporation (202) 628-4888
i
(; ,r\ 19
' ~
1- the schedule correctly.
'2 MR. KING: . Yes, April- of ' 91 is the one we are 3 recommending.
4 MR. MICHELSON: How can you take most of that time l .
5 'to even give out your guidance on what should be in the -
6 standard and.for the industry to prepare a. standard and for 7 you to judge and so forth and also for the industry to show 8 that it can perform under that standard. It looks like the 9 time is way too'short.
-10 MR. KING: We are trying to get the standard done 11 as soon as we can.
12 MR. MICHELSON: That part is commendable. What 13 bothers me though is the time in which the industry will 14 'have to demonstrate that it can comply with that standard in 15 an effective manner.
16 How much time are they going to have to 17' demonstrate performance?
18 MR. KING: Well, essentially what we are shooting 19 for is to have the standard available approximately July-of 20 1990.
21 MR. MICHELSON: And then a rule-making decision
- 22. would be made when?
23 MR. KING: We'd have to recommend to the 24 Commission April of ' 91, whether we pursue rule making or 25 some other--
O Heritage Reporting Corporation (202) 628-4888
= _ = _ _ _ _ _ _ - _ - _ _ _ _ _ - - _ - _ _ _ _ _ _ .
20
( ,\
\"
1 MR. MICHELSON: You are saying about nine months 2 then?
3 MR. KIN 3: I think the intent there is to have 4 that thing available in time for the industry to review it 5 and make a decision as to whether they are going to adopt it 6 or not. Commit to whether they are going to adopt it or 7 not.
8 MR. MICHELSON: I sensed in reading the Policy 9 Statement that one of the things you are going to do is 10 monitor industry's performance. I assume performance is 11 some kind of a standard. And I wondered when you are going 12 to monitor to a standard since it didn't seem like it was 13 going to be on the street and an opportunity for industry to
() 14 implement it in that short a time.
15 MR. KING: We can monitor the performance now in 16 terms of trending--trends in various parameters, inspection 17 results, SALP results and so forth.
18 MR. MICHELSON: Yes, but that's not what I 19 thought--
20 MR. KING: The standard--we are looking for the 21 standard to set more of a level of performance that we've--a 22 lot more of an absolute scale, the level of performance that 23 we'd like to see.
24 MR. MICHELSON: And then you were going to judge 25 the industry's ability to reach that level of performance.
Beritage Reporting Corporation (202) 628-4888
21 1
rw] '
1 MR. KING: I think we are going to judge the 2 industry's commitment to reach that level of performance.
3 MR. MICHELSON: Oh, you are not going to look at 4 the performance itself, but just the commitment?
5 MR. KING: No. We are going to look at 6 performance. But I don't think it's essential that 7 everybody in April of ' 91 be at that level. I think it 8 would be important that people would commit to shoot for 9 that level.
10 MR. MORRIS: Tom, perhaps I can help out just a 11 bit here. This is Bill Morris of the NRC staff.
12 The considerations to be examined during this 13 eighteen-month period extend beyond just the standard and pI
(_, 14 how well they are implementing that particular standard.
15 The industry already has, I think in every case, 16 pretty good maintenance programs, put in place on paper.
17 When the maintenance team inspections were carried out, they 18 found, I believe, and I think NRR can speak more to this if 19 you wish, that the paper programs looked pretty good, but 20 there were places where the implementation wasn't as good as 21 one would like.
l 22 And the standard that we have adopted in our draft 23 Regulatory Guide conforms to what we believe most of the l 24 industry is putting down on paper as part of its program.
25 So what I think would be examined would be through l
l
[')
\' Heritage Reporting Corporation (202) 628-4888
3 O 1 the maintenance team inspections that would be carried out-2 through this eighteen-month period. The continued 3 improvement or the degree of improvement by the industry.in 4 implementing their existing programs, which really I think 5 in most cases, if they implemented the programs on paper, 6 they would be conforming pretty well to the standard that we 7 have out as a draft. And that needs refinement. There may 8 be some variations to it that we could develop, that 9 industry may develop. A standard that it prefers to that 10 one that it would prefer to have as the one that would be 11 adopted.
12 But it isn't simply a matter of conforming to our 13 standard. It's a matter of implementing their programs in a
). 14 way that will show that they are improving in maintenance, 15 Also there are other commitments that are 16 expected. There is a commitment to work with AEOD in 17 developing a maintenance effectiveness indicator. You'll 18 hear more about that later today.
19 So I think it's more.than what you are talking 20 about now, that we'll be looking at at the eighteen-month 21 period.
22 MR. CARROLL: I might comment that a number of 23 members of the committee that form the Regional Activities l 24 Subcommittee were down in Region I last week and we talked a 25 bit about this subject.
O. Heritage Reporting Corporation (202) 628-4888
l 1'
gr~x 23 l
\
l One of the things I found very disturbing was that 2 no one in Region I had ever seen or knew anything really l 3 about the INPO maintenance guidelines. Which is really the 4 basis on which I think most utilities are proceeding to l 5 improve their maintenance program.
6 That seems like a real disconnect to me, if in 7 fact Region I is out looking at people's maintenance
'8 programs and has not even looked at the basis that they are 9 developing them on.
l l 10 MR. WILLIAMS: We at Headquarters have looked at 11 that in some detail and I may be able to comment on ~'at the 12 Regions are doing on that.
j .13 MS. McKENNA: Eileen McKenna, NRR Staff.
) 14 In our development of our inspection, we did use 15 the INPO guidelines, and in our meetings with most of the 16 regions, and I'm surprised you said that because a number of 17 the regions are very familiar with the INPO guidelines and 18 the self assessments that licenses did to them. So you are 19 sort of aatching me off guard with that comment, because 20 most of them are familiar with it, the ones we've talked to.
21 MR. CARROLL: Region I was familiar with the self l 22 assessments, but the question was, have any of you guys read 23 the INFO guidelines? Because, you know, they are more than 24 just statements.
25 MS. McKENNA: Oh, yes.
, 1
( Heritage Reporting Corporation i (202) 628-4888 i
l l
1
. - - - - _ _ _ - _ _ - - - _ - _ i
j 24
-1 MR.. CARROLL: There's a lot of implication in 2 them.
3 Am I mischaracterizing what w heard, Forrest?
4 DR. REMICK: I think you are right.
5 MR. CARROLL: I guess I would like to see 6 Headquarters do a little more--or at least make sure that 7 the regions have that document to look at and are aware of 8 it.
9 VOICE: .If they read it.
10 MR. WYLIE: They made one other comment I thought 11 was right surprising too. That they had not seen the 12 _ proposed draft rule on maintenance until after it was 13 developed.
() 14 MS. McKENNA: We did have, on that subject of the 15 proposed rule, there were some discussiorts with'the regions, 16 not as much as we would have liked considering the time 17 frame that we were on to move from the proposed to the final 18 rule.
19 We have distributed the Regulatory Guide to the 20 regions for their comment in parallel with the public 21 comment period, so wa are trying to bring that perspective 22 to - trae final product.
23 MR. WILLIAMS: And also I would note, I believe, 24 Eileen, tnat there were experienced inspectors involved in 25 the development of both the rule and the Reg Guide that i
Heritage Reporting C1rporation (202) 620-1888 O _ - _ _ _ _ _
25
, 73 V.
1 participated in that. So we certainly did not ignore that 2 element. We just couldn't get.all the regions involved in 3' equal numbers, but we did have experienced inspectors 4 . involved in that.
,5 MR. KING: We had a Region I representative on our.
- 6. working group developing the Reg Guide and the final rule.
7 MR. WYLIE: That's strange from what they said.
8 DR. REMICK: At our meet 3ng in Regicn I we might 9 not have had the knowledgeable people present at the time 10 that that was discussed. That's always a possibility.
11 MR. WYLIEt We had the managers.
12 DR. REMICK: That's right.
13 MR. KING: Well, we would hope in putting together
()- 14 the working group to develop the next draft of the Reg Guide 15 to have regional participation in that working group. And 16 we haven't got individuals identified et this point, but 17 it's my intent to get them involved and be on the working 18 group. Review public comments, work with our outside 19 experts, and come up with that next draft and participate in 20 the workshop.
21 DR. SHEWMON: The only standard that I have more 22 than even a passing acquaintance with is Section 11 of the 23 ASMC boiler and pressure vessel code. And that then is 24 accepted by reference as part of the regulations. This is 25 evolved and continually worked on by groups who talk about
' Heritage Reporting Corporation (202) 628-4888 1
l l
26 L TO 1 acceptable procedures, acceptable forms, acceptable 2 practice.
3 -I am trying to grasp how the NRC would set up a 4 standard at all related to this sort of a thing and maintain 5 it. And my mind blows a fuse.
6 Could you help me state what this standard is and 7 if it bears any resemblance to, say, Section 11 which is 8 also part of the Regulations? Or will I get to that if I 9 keep my mouth shut and listen to you for ten minutes.
10 MR. KING: Well, let me try and answer it now.
11 The standard could be in the--there are several 12 options. The standard could end up being in the form of a 13 Reg Guide that would back up a rule if the Commission elects
() 14 to put out a rule eventually. In which case we would keep 15 it up to date as necessary like we do other Reg Guides.
16 If the Commission decides not to put out a rule, 17 once the industry and the industry volunteers to adopt some 18' form of standard, that standard could be something that we 19 develop. We couldn't call it a Reg Guide because if there's 20 no rule out there that it would be written against, but 21 maybe it would be in the form of a NUREG report or some 22 other vehicle. We haven't settled in yet if we don't have 23 it'in the form of a Reg Guide what the right vehicle would 24 be. Or it could be in the form of an industry standard that 25 they would submit and we would endorse and they'd say, we're f~
k Heritage Reporting Corporation (202) 628-4888
l 27 l in)
1 going to implement--and adopt and implement this industry 3 1
2 standard. ,
3 DR. SHEWMON: And the advantage of having it as a 4 standard as Section 11 is a standard is you can say that 5 that has the force of law. They must do this or they are in 6 violation? You say they have a program now, and the program 7 is satisfactory on paper. But apparently you feel that you 8 can't inspect that and hold them to it the way you want to 9 and so with a standard you would be able to do this more 10 effectively. Is that correct?
11 MR. KING: Well, I think with a standard we'd have 12 a uniform level of performance that we'd like to see in the 13 maintenance area.
/
(7.) 14 DR. SHEWMON: So everybody would have the same 15 program in those times. And so this would--
16 MR. KING: No.
17 DR. SHEWMON: --bring up the bottom core tile to 18 something closer to the mean?
19 MR. KING: It doesn't mean everybody's program is 20 going to be identical. But I think what they are trying to 21 do with maintenance in terms of improving plant performance 22 hopefully would be some uniform scale.
23 In other words, I think the standard has to allow 24 flexibility for each individual licensee to fit the 25 maintenance program within his own organization, his own m
k_) Heritage Reporting Corporation (202) 628-4888
t r 1 raeds..
2 We don't intend to have a very proscriptive 3 standard at this point in terms of "You will do maintenance 4 on this-pump every six months, and this is what that~
5 maintenance will consist of." There's nothing like that 6 that we have in mind at this point.
7 DR. SHEWMON: Let's go on.
8 MR. CARROLL: The bottom line, Paul, is they are 9 going to get everybody's maintenance program above average.
10 DR. SHEWMON: That's a worthy goal. Do we'have in 11 the room a set of these INPO standards that you referred to?
12 Or this INPO program?
13 MR. MICHELSON: Guidelines you mean?
() 14 DR. SHEWMON: Guidelines,'yes.
15 MR. MICHELSON: We don't have the book. Do we 16 have a copy of the INPO Guidelines somewhere?
17' MR. CARROLL: The staff does. Somebody can get
-18 you one.
19 MR. MICHELSON: We have copies of it.
- 2 10 DR. SHEWMON: I'd be curious. I'm not sure if 21 it's relevant. But--
22 MR. CARROLL: They are quite a bit different than 23 Section 11. I mean they are more general philosophy whereas 24 Section 11 gets pretty specific about different kinds of 25 things you do.
O Heritage Reporting Corporation i
(202) 628-4888 E____________1.____
,-. 29
)
1 DR. SEEWMON: Let me listen for ten minutes and 2 I'll ask the question again.
3 MR. KING: All right. Let me finish talking about 4 this schedule.
5 The third item down is an item dealing with the 6 option if the industry wants to propose a standard.
7 One item we've included in the draft to the 8 revised Policy Statement is a submittal date. If the 9 industry does want to propose a standard, we are asking for 10 it by March 1st of 1990. So to give us time to look at it 11 if it's going to be endorsed by a Reg Guide to go through 12 the public comment and formal process that Reg Guides go 13 through. So it's available on time to support our decision
() 14 and recommendation to the Commission at the end of the 15 eighteen-month period.
16 Granted those schedules are just speculative right 17 now and any specific industry proposal could affect that 18 schedule for the industry proposed standard option.
19 Maintenance performance indicators. There was an 20 item in the SRM on that. AEOD has developed a maintenance 21 effectiveness indicator. They intend to continue to 22 implement that. They are planning their report in October 23 on that work. And they are also working with industry to 24 share information on looking at other indicators that may be 25 of use. And they have a meeting scheduled next week to
\- Heritage Reporting Corporation (202) 628-4888
l 30
' (n
1 pursue that with a long-range schedule, and that will be--
2 it's unclear at this point, but things have started on that 3 particular item in the SRM.
4 There's an item on enforcement criteria. The 5 Office of Enforcement is working on that. They plan to have 6 something to the Commission by the end of this month on 7 that.
8 And then the recommendation to the Commission. We 9 are shooting for, as I mentioned, April of ' 91. But prior 10 to that time, in January of ' 91, to have a final draft Reg 11 Guide and Rule to the Commission for information so they'll 12 have a chance to look at it in case they do decide to put 13 forth a rule at the end of the eighteen-month period, i ) 14 MR. MICHELSON: At what point will the Rulu go out 15 for public comment? The proposed Rule, you know, that you 16 would be preparing?
17 MR. KING: Well, if it's the same as the one 18 that's already been out for public comment, it won't go out 19 again.
20 MR ., MICHELSON: Well, and it now goes out in a new 21 light, of course.
22 MR. KING: We'll have to figure out what would be 23 the right time.
24 MR. MICHELSON: But is it roughly when--roughly 25 July of next year?
)
(~J k Heritage Reporting Corporation (202) 628-4888
,, 31 l )
1 MR. KING: I think after the Reg Guide is done,.
2 we'll need to see what changes, if any, we want to make to 3 the Rule and decide whether we need to put that back out for 4 public comment or not.
5 MR. MICHELSON: Well, you might think that it 6 requires no further public comment and make it immediately 7 effective? That would be one possible option.
8 MR. KING: Well, it won't be immediately 9 effective, but if the Rule that we worked on and submitted 10 to the Commission in April still looks like a good Rule, 11 there would be no further need to go out again and ask for a 12 comment on it.
13 MR. MICHELSON: Yeah.
() 14 MR. KING: If we are going to make significant 15 changes to it, I think we probably won't know that until we 16 are done working on the Reg Guide--
17 MR. MICHELSON: But you could have a Rule by July l i
18 of 1990 if you so desired.
19 MR. KING: Well, right now we are planning to have 20 the Rule by January of ' 91.
21 MR. MICHELCON: No. I'm talking about rule in 22 place effective--is that correct 23 MR. KING: We have no plans to have a rule in 24 place in July of ' 90.
25 MR. MICHELSON: I say you could have. If you Heritage Reporting Corporation (202) 628-4888
4 32 :
1= don't go 'o:.r. for public comment again, what's left?
2 MR. KING: Oh.
b 3 DR REMICK:: The Commission would just have to 4 make that decision. But that's the decision that they 5' decid-d to defer for eighteen months.
- 6. MR. MICHELSON: That's right. So indeed they 7 could have one in place by the end of June of next year if-8 they so wished.
9 MR. KING: If that's what they wanted to do then 10 we'd have to take steps to have that ready.
11 The last thing I wanted to point out was the 12 maintenance team inspections schedule. We are hoping to 13 gain quite a bit from the maintenance team inspections in
() 14 terms of information on what would be useful to put in this 15 Reg Guide to improve maintenance.
16 And the point I' wanted to make--the two points I 17 wanted to make on that bottom line was one, right now, these 18 maintenance team inspections are scheduled to be done by the 19 time we have to go to .the Commission in April of ' 91 with 20 recommendations. So we'll have looked at all plants and 21 haw .s lot of information on what we think of licensing 22 maintenance programs.
23 MR. MICHELSON: Are you saying that every plant 24 will have received a maintenance inspection?
25 MR. KING: That's the current schedule, yes.
- .. Heritage Reporting Corporation (202) 628-4888
33 1 MR. MICHELSON: Okay.
2 MR. KING: And then the second thing is, we are 3 planning some selected re-visits to certain selected sites 4 to look at what's changed since the first inspection.
5 That's part of trying to look at the improvement that's 6 taken place over the eighteen months. The details of that 7 aren't worked out but there is a plan ~now to go out and do 8 that toward the end of this eighteen-month period.
9 MR. MICHELSON: Can you give us in a couple of 10 minutes an idea of just how these maintenance team' 11 inspections have turned out so far?
12 MR. KING: I'll ask NRR to do that.
13 MS. McKENNA: The schedule indicates we are
() 14 approximately half way through with the number of sites that 15 have been done. I think what Bill was mentioning earlier on 16 terms of the programs is you find in most cases that their 17 expectations of what they are going to do are satisfactory.
18 We have had a couple of instances where that has been very 19 informal, loosely defined, with some holes. So a couple of 20 cases where we felt that those aspects needed substantial 21 improvement, but for the majority of the cases, that was in 22 pretty good hand and it was the degree of effectiveness of 23 implementation across all the areas.
24 I think the weakest areas we have seen has been in 25 the engineering support area to deal with recurring O
Heritage Reporting Corporation (202) 628-4888 h- _ __ __ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
s 34 1 problems, things that are sort of beyond the day-to-day 2 maintenance person's ability to handle,'the trending--it-3 sort of all ties together. The trending aspects to identify 4 the recurring problems. Having the history and the data 5 collection such that you can make those kind of analyses.
6 Those kind of areas I think were seen as most 7 consistently the weaknesses. We are starting to see some 8 problems in procedural aspects to tend to fall into a couple
- 9. of areas. One is the adequacy of the procedures themselves.
10 The degree of detail that's included in them. And the other 11 is the degree of compliance and how well people follow them.
12 The strong areas I think that we see has been in 13 the training. In most cases the training problems and the
) 14 qualifications are very strong.
15 DR. REMICK: That's an area, by the way, I was 16 going to wait until later to ask you questions.
17 In the Policy Statement, other than an indication 18 that you expect that to be in the maintenance plans, there's 19 no mention of training. I'm just surprised that somewhere 20 in there you didn't emphasize the importance of training.
21 MR. KING: Training is one of the seventeen 22 elements that we--
23 DR. REMICK: That's right.
24 MR. KING: So it is listed in that respect.
25 DR. REMICK: It's listed there fortunately. But O Heritage Reporting Corporation (202) 628-4888
l h
ll L' 35 t
1 -
1 there's no mention elsewhere. Either in recognition of the 2' . tremendous effort that has gone into maintenance training n 3 for.INC, electrical maintenance, mechanical maintenance.
'4 But also how'important it'is.
5' I've often felt that one'of the most direct 6 results of the improved training out in the-industry is not 7 going to come from training of operators but training of 8 maintenance personnel and the facilities. And I just was 9 surprised that that emphasis is not in your Policy H10 Statement. The word " training" appears once I think. It's.
11 in that list of seventeen elements.
'12 MR. KING: Yes.
13 DR. REMICK: I realize you can't list them all and
() 14 others-are just as important, but I--
15 MR. KING: One thing we did try and do up front in 16 the revised Policy Statement was list five or six items, the 17 things that Eileen just mentioned that had come out of the 18 maintenance team inspections so far. .The areas of weakness.
19 To give some indication on those. areas we felt needed 20 improvement. Like engineering support, for example. One of 21 the Vu-Graphs has those things listed here. But they are 22 listed in the Policy Statement.
23 DR. REMICK: It doesn't hurt to put an "atta boy" 24 in sometimes.
25 MR. WYLIE: Let me ask a question from the Beritage Reporting Corporation (202) 628-4888
36
'TO 1 maintenance tent inspection. Have you found a utility that r,
" ~
2 had a good program?: That met your expectations?.
'3 HS. McKENNA: I think we've seen several that are p.
- 4. very close. Anytime you look, there's always something that 1 5 you feel could be stronger or different, but we have had a 6 number that--I. don't know if you are familiar with our 7 inspection' process and evaluation criteria, the tree that L '8 we've used, where we sign'a green, yellow, red type of:
9 attribute to various parts of it. Green means a good strong 10 program.
11- We had a number that have been rated as green with 12 their'overall--put.all.the pieces together--the overall 13- rating is green. So, yes, we have seen some good programs.
() 14 MR. KING: Wasn't there like 25 percent of the 15 plants that had an overall top rating, as I recall?
16 MS. McKENNA: Hold on just one second. I have my 17 data over there.
18' MR. CARROLL: Those were the charts they had up on 19 the front of the podium down in Region I, do you remember?
20 MR. WYLIE: Yeah, I remember. Yeah. I was just 21 curious though whether any program met the expectations of 22 this proposed program. But you are saying that there are 23 some then? ,
24 The reason I ask that, the Policy Statement seems 25 to imply that there are none.
O Heritage Reporting Corporation l (202) 628-4888 ]
l;
,_ 37 1 MS. McKENNA: Well, again, I think you see the 2 difference in what's laid down as to what they intend to do 3 and what they are doing. Like we've seen approximately 40 4 percent of the programs of what they plan to do that we 5 found good and only about 25 percent uhere we felt they were 6 actually living up to what they were expecting th;tmselves to 7 do.
8 MR. WYLIE: But not what the NRC expects, is that 9 right?
10 MS. McKENNA: Well, the first half of that is if 11 we felt that their program is written down met our 12 expectations, we assigned them the good category, and that 13 was the 40 percent.
c
( )y 14 MR. MICHELSON: This is percent of what?
15 MS. McKENNA: Percent of the sites that we've 16 looked at.
17 MR. MICHELSON: And that's about half of the 18 total?
19 MS. McKENNA: That's about half.
20 MR. MICHELSON: Okay, thank you.
21 MR. CARROLL: I commented the last time you were 22 all down talking about the maintenance rule, and it was very 23 early on in these maintenance team inspections that I had 24 personally reviewed two or three of the early reports and 25 found enormous inconsistencies between what different
(~
Heritage Reporting Corporation (202) 628-4888
M. s 38 II regions seem to be.doing. And these happen to be 2 maintenance programs that'I had some familiarity with, and a l
L3- couple of utilities. There was a difference between Region 4 1 and Region 5 specifically.
. 5f Do.you think that problem has been corrected? .Or
~
6 .was it a problem initially?
[ 7 MS. McKENNA: Yes, I agree'there are some h 8 differences I think. Even now if you look at them you will-
- 9. see some differences in style and the way the reports are 10 put together and things they look at in some cases.
11 One of the objectives by having the tree was to at 12 least give everybody the same guidelines of what you should 13 be looking at and what kind of results we were expecting 14 them to report back.
15 We've had some meetings among all the regions too 16 to' discuss the best way to go and learn from each other and 17 . share experiences on how to do things. You still see some 18 differences in how the regions go about them. In some cases-19 the regions will go during an outage because they want to be 20- able to see the work that's going on during the outage. In 21 other cases they schedula them when it's convenient to 22 schedule them from staff availability or they want to do it 23 before the end of a sell period, so you see different things 24 if the plant is operating in terms of what kind of work is 25 going on.
O Heritage Reporting Corporation (202) 628-4888
,f y 39
~
1 So there are variations. I don't see it so much 2 as a problem. If you are trying to match, compare, each 3 individual element across all plants, you maybe are not 4 going to be able to do that but there's enough similarity 5 that I think you can develop a sense of how well things are 6 going.
7 MR. CARROLL: Well, the kind of thing that 8 bothered me was really very basic. Plant A and Plant B on a 9 particular element. Plant A says, " Hey, we've got a program 10 here. We can show you all the details of it." And then 11 when it comes to implementation, you know, there were a 12 bunch of rocks thrown at it.
13 Plant B said, "Well, we've been thinking about t' 14 this and it's something we need to.do. And we are putting a 15 program together." And they got good marks on both.
16 MS. McKENNA: Yes, that is a problem we've had in 17 some cases where there are new programs that are about to be 18 implemented or have just been implemented within the last 19 two months so you haven't seen the results yet. And one 20 time we almost considered doing before and after kind of 21 charts about, "Well, 13st month, before we got here, when 22 you had your old program, this is what we would have said 23 about it. Now that you've made these changes, and have put 24 the commitment into it, it looks like you are going to be on 25 this end of the stick. You haven't gotten there yet because D
O Heritage Reporting Corporation (202) 628-4888
q 40 G! But you can get into those kinds of 1 you just started it."
2 situations depending on how far they've gotten and how 3 strongly_th( region feels about what they are seeing.
4 MR. CARROLL: But then you put all your statistics 5 together and, you know, I was flabbergasted a few months ago 6 when we went to see the Commission. They had your numbers 7 well in mind.
8 MS. McKENNA: Yes, well--
9 MR. CARROLL: 43 percent were this way, and--
10 MS. McKENNA: That's why when I described them I 11 tried to give them--I didn't say 42.1 percent because I 12 don't think we feel we can cut.it that finely. It's much 13 more a third or a half type of numbers. Unfortunately when 14 you make the nice graphs with the colors for the Commission, 15 the program generates you out to a 1 decimal point and 16 sometimes people take that a little too seriously.
17 MR. CARROLL: Okay. So you agree your numbers 18 have some bias depending which region did it--
19 MS. McKENNA: Oh, yes, absolutely.
20 MR. CARROLL: And how early in the program and 21 whatever. Okay.
22 DR. REMICK: Recalling from the regional meeting 23 in Region 1, they indicated that of the eight plants 24 apparently they've conducted inspections, five they thought 25 were functioning well and only one was inadequate out of the O Heritage Reporting Corporation (202) 628-4888
.rs. 41
( ~)'~
1 eight of the inspections they've conducted.
2 MS. McKENNA: Yes.
3 MR. MICHELSON: The only question I would have is, 4 what does "well" mean in this case, compared with what you 5 have in mind as a standard? They don't have a standard in 6 front of them yet in which to judge the goodness of the 7 program.
8 MR. KING: No.
9 MR. MICHELSON: Well, they have the inspection--
10 "well" means satisfactory, doesn't it?
11 MR. KING: Yes.
12 MR. MICHELSON: Compared with the inspection 13 module requirements.
(G _/ 14 DR. REMICK: Yeah. And that was patterned 15 somewhat after INPO, is that right?
16 MS. McKENNA: That was one of the documents that 17 was used to generate the tree and the guidance, yes.
18 MR. KING: If you are ready, we will go through 19 the Policy Statement, the main points in the revised Policy 20 Statement.
21 And let me start by just reviewing the guidance 22 that was in the Commission's SRM on what they wanted to see 23 in this revised Policy Statement. They wanted it to note 24 that rule making will be held in abeyance for eighteen 25 months. And the effective date of the revised Policy
,m Heritage Reporting Corporation (202) 628-4888 i
i
42 f)
1 Statement while we monitor' industry's progress.
2 We wanted it to emphasize the need for continued 3- improvement in maintenance.
4 DR. REMICK: Excuse me, Tom. That first bullet, I 5 think I understand what it means, but at the same time, 6 according to your chart that you showed us, the staff is 7 going to give to the Commission in January of ' 91 a proposed 8 rule, so the staff is proceeding with developing a rule but 9 I guess this just means it would not be issued before 10 eighteen months, is that--
11 MR. KING: At the end of eighteen months, there 12 may or may not be a rule issued.
13 DR. REMICK: Right.
() 14 MR. KING: What we are doing in parallel with 15 making that recommendation to the Commission is developing 16 the final Reg Guide and rule so that it's in our back pocket 17 ready to go if the Commission elects to go that way. It 18 doesn't mean that they are going to go that way.
19 DR. REMICK: No, I understand that.
20 MR. KING: But we don't want to get caught short 21 at the last minute without having it ready in case they 22 decide to go that way.
1 23 DR. REMICK: Okay.
24 MR. KING: Okay. SRM wanted the revised Policy 25 Statement to encourage the expanded use of the NPRDS system, O Heritage Reporting Corporation (202) 628-4888 1
i 43 0- 1 encourage industry to assist us in developing the standard 2 for maintenance and to voluntarily adopt it. It wanted it 3 to encourage further developing and use of maintenance 4 performance. indicators. Wanted to state our intention to 5 issue plant specific orders or other enforcement action 6 where we detect core declining performance in maintenance.
7 And to restate the acceptable--elements of an acceptable 8 maintenance program.
9 So we attempted to put all of that into this 10 revised Policy Statement and what I'll do is run through the 11 main points. I believe they are in the order in which they 12 show up in the Policy Statement.
13 MR. MICHELSON: Just for clarification. The
) 14 maintenance indicators apparently are going to be kind of 15 firmed up in November of ' 897 October of '89 rather?
16 MR. KING: I think in October of ' 89 AEOD is 17 issuing a report on their maintenance effectiveness 18 indicator. Maybe Mark will want to expand on that a little 19 bit.
20 MR. MICHELSON: What I was wondering about is, are 21 you going to start implementing their use at that time? Is 22 that the idea?
23 MR. KING: Mark, do you want to answer that?
24 MR. MORRIS: Right now, Carl, we'd have the 25 capability to implement it that early. What we intend to do O Heritage Reporting Corporation (202) 628-4888
c_ _ _ _ ._
44 1 right now is to work with a group of utilities and provide 2- them the data upon which the indicator is based. Have them-
.3 validate the data and then we'd look back through the 4 indicator to see how well it maps maintenance experience at 5 those utilities with those utilities.
6 Once'we convince ourselves that things are right, 7 then we' d have the . capability to go ahead and implement it.
8 MR. MICHELSON: So at most you could have about 9 eight months of experience evaluating utilities with these 10 indicators before the rule-making decision.
11 MR. WILLIAMS: That's right. But it would be--our 12 schedule is for shooting for October. And have the 13 capability to do that.
() 14 All right. The revised Policy Statement really in 15 the big picture it does two things. It states what the 16 Commission plans to do over the next eighteen months. And 17 it states what we'd like to see licensees do over the next 18 eighteen months. And so with that in mind, it contains a 19 number of points.
20 The first one being, it states we plan to hold the 21 rule in abeyance for the next eighteen months while we 22 assess commitments and improvement that the industry makes 23 in the maintenance area.
24 It states five areas where we think additional 25 improvement is needed and these basically come from the Heritage Reporting Corporation l (202) 628-4888 l l
l
_ - _ _ _ _ _ - _ _ . _ _ _ _ - _ _ _ - - _ _ _ _ _ _ _ . _ _ . _ _. _ .i
i 45 l
1 g)
\
'~'
I maintenance team inspections. They are the areas of 2 engineering support, record keeping, trending, root cause 3 analysis, and the use of preventive and predictive 4 maintenance techniques.
5 It states that the licensees are responsible for 6 improvement and encourages the NUMARC and INPO to provide 7 leadership across the industry to make that improvement 8 happen.
9 It states that the Commission will take 10 appropriate enforcement action where it detects poor 11 declining performance, particularly if it's going to 12 emphasize enforcement of existing requirements that are tied 13 to maintenance. Those are right now particularly in the n
() 14 safety-related equipment area.
15 It will issue plant-specific orders if necessary 16 and ask for corrective action plans if necessary. And the 17 Office of Enforcement is working on criterias to exactly 18 when you'd use an order or some other means to make 19 improvement in the maintenance area.
20 It solicits industry and public assistance in 21 developing the standard for maintenance. And particularly 22 on the next page--
23 DR. REMICK: Tom, has there been any indication 24 that industry is willitig to cooperate in the development of 25 that standard recently?
Heritage Reporting Corporation (202) 628-4888
<- 46 i)
~~'
1 MR. KING: I talked to NUMARC informally. A 2 couple of things. They are going to comment on the 3 standard. They said they would participate in the workshop.
4 As I understand it, they have a Board of Directors meeting 5 in November of this year where any formal commitments will 6 be discussed and made at that time regarding whether they 7 are going to propose a standard on their own or just how 8 much' involvement they are going to have in terms of 9 supporting our Reg Guide or supporting some alternative 10 proposal.
11 I expect the end of November or early December to 12 have something formally from them.
13 DR. REMICK: Thank you, f3 14 --to lay out commitments in the
(_) MR. KING:
15 maintenance area.
16 DR. REMICK: Okay.
17 MR. KING: Okay. In developing a standard--as I 18 mentioned, we put out the draft Reg Guide. It's the same 19 one that you saw at the proposed rule time back in April.
20 It's out for comment. As part of issuing it for comment, we 21 asked five specific questions. People can comment on 22 anything but we put five specific questions we wanted
{
23 comments on as part as putting it out. In particular these l I
I l 24 questions dealt with what level of details should be in the 25 standard, what scope of system structures and components l
('\
\- Heritage Reporting Corporation (202) 628-4888 l
i - ------ _ -
f _
47 i 1 should be covered by_the standard. What level of 2 performance should the standard shoot for? And a couple of 3 qusstions on how you would establish and measure that level !
4 of performance, goal setting, if you will.
5 As I said, the revised Policy Statement allows the
-6 option of the industry proposing an alternative standard.
7 If they do that, we are asking that they-submit it by March 8 let 1990 and that can either be in the form of something we 9 would endorse in our Reg Guide or something that would be an 10 industry standard. After we review it,.they would 11 voluntarily commit to adopt it and implement it.
12 In either case, we would like the standard 13 available'in about a year, approximately a year, so that
() 14 there is time for the industry to make the commitments to 15 adopt it. And hopefully if they start to implement it, 16 maybe we can get some feedback, make some changes to it if 17 necessary before it would actually become formalized, if we 18 do pursue the rule making.
19 And courage the~ industry to adopt it. I mentioned 20 that.
21 Encourages expanded use of NPRDS, which includes 22 timely and complete reporting. It also includes extending 23 the amount of or the number of pieces of equipment that are 24 put in NPRDS, particularly I think out in the bounds of 25 plant area.
O Heritage Reporting Corporation (202) 628-4888
48
\s 1 The-revised policy states--
2 MR. CARROLL: So, Tom, what you are saying.is, you 3 are going to try to get NPRDS to expand the balance of plant 4 categories in NPRDS?
5 MR. KING: Yes. I think that's the intent, 6 Is that right, Mark? Again, AEOD is actually the 7 office that's directly working with the NPRDS folks. That's 8 my understanding.
9 MR. WILLIAMS: There is underway at NPRDS in which 10 we are a member is suggested and INFO has agreed to expand 11 to expand the NPRDS to include the turbine and some other 12 major components.
13 Pat O'Reilly is our representative on the j )- 14 cosamittee. Those changes should be ready for implementation 15 around the spring of next year, is my understanding. They 16 need to issue guidance. They need to revise the scoping 17 manuals on the systems scopes. And then there's some 18 detailed issues on the nature of the super components and 19 exactly how the reporting structure will be laid out.
20 But right now the NPRDS recommendations are being 21 implemented to expand the scope of the system to include 22 some other major components.
23 MR. CARROLL: Would there be an attempt to backfit 24 past history into the data base?
25 MR. WILLIAMS: No.
l Heritage Reporting Corporation (202) 628-4888
.__ _ ___ . ________ -_ - a
1 l
,' _ 49 !
l
! ( h l \-'#
1 MR. CARROLL: Just start from some date. Okay.
2 And I guess the other issue along those lines that 3 I wanted to raise was--I believe it was last month AEOD made 1
4 a presentation to us about the SCRAM reduction programs.
5 And one of the questions that was posed to them was how 6 important are SCRAMS from a risk prospective? Are SCRAMS 7 from balance of plant equipment really precursor events and 8 the answer we got was no. They are not important at all.
9 They are not important precursors.
10 And I wonder if that's being taken into account in 11 looking at the very controversial subject of how much of 12 balance of plant you put into a maintenance policy or 13 maintenance role.
() 14 MR. WILLIAMS: Well, there are a couple of 15 questions there.
16 Let me try to answer. I think the question that 17 you've raised has been looked at by the committee of which 18 there are utility members, INFO is a member, there's a 19 number of interests involved. We are a member. And the 20 consensus was that we would go ahead and add this equipment 21 to scope.
22 Now, SCRAMS and the initiators--
23 MR. CARROLL: Oh, I think that's fine because at 24 least, you know, SCRAMS and balance-of-plant problems are 25 very important economically at least. But the issue is, are Heritage Reporting Corporation (202) 628-42B8
50 7
( ')
1 they important from a risk prospective?
2 MR. WILLIAMS: Well, whenever we've quantified it, 3 back when we were working on new plant experience, one of 4 the things that we did was we tried to quantify the risk 5 increment from a SCRAM. And when you try to quantify it, 6 change the conditional probability of core melt given a 7 SCRAM with a half a dozen different models of plants, you 8 don't get that big a change in risk from a nominal SCRAM.
9 It just doesn't work out. You need a lot of SCRAMS.
10 MR. CARROLL: I know of one that caused a rather 11 major problem at a plant called TMI.
12 MR. WILLIAMS: Yeah. And when we model, it's hard 13 to--once you start building in the other failures, of r~m
!) 14 course, as soon as you impact core cooling, then your 15 numbers change dramatically. But if the question is just on 16 a nominal SCRAM where everything works right, then the 17 answer is probably no.
18 But it's a controversial issue and the assumptions 19 that are built into the analysis have a dramatic effect on 20 the results.
21 But on the question of NPRDS expansion, we did 22 look at it and the consensus was we truly hadn't had a 23 selective set of components.
24 MR. WYLIE: Let me put the question a little 25 differently. When you get around to scope, we'll discuss O'- Heritage Reporting Corporation (202) 628-4888
,, 51
('> )
1 this a little bit. But would it be the intent then that 2 everything that finally falls within the scope of the Policy 3 Statement and the proposed Reg Guide or Rule or whatever, 4 then would be expanded- you'd expand the NPRDS to include 5 all those components, would that be the intent?
6 MR. WILLIAMS: No. I don't think that is our 7 intente at the outset.
8 DR. REMICK: Do we have your name in the record?
9 MR. WILLIAMS: Mark Williams. I am the Chief of 10 Trends and Patterns Analysis in AEOD.
11 MR. WYLIE: Well, that doesn't come across in 12 reading the Policy Statement or the Reg Guide. I mean it 13 would imply everything within the scope of the documents it n
() 14 would be intended that the NPRDS be expanded to include 15 those, if you read this.
16 MR. KING: Maybe it comes across that way. I 17 guess I'm not sure we intended it to do that.
18 MR. WYLIE: But the words say that though.
19 DR. REMICK: Do you want to proceed, Tom?
20 MR. KING: All right.
l 21 In addition to NPRDS, the revised Policy Statement 22 states the Commission's intent to develop and use 23 maintenance effectiveness indicators and encourages licensee l
24 and industry development and use of maintenance 25 effectiveness indicators.
l l /h l \d Heritage Reporting Corporation (202) 628-4888 l
l
52
'-) 1 And, again, it mentions the joint demonstration 2 project between NRC and industry to share information on 3 indicators.
4 And it restates the elements of acceptable 5 maintenance program. Those are the elements that were put 6 forth in the fina?, proposed rule back in April, except we've 7 added two additional items. One, a statement that 8 reliability centered maintenance is one of the items under 9 maintenance technology. And we've specifically mentioned 10 root cause analysis in th9re under engineering support.
11 Otherwise the list is the same as you reviewed at the final 12 fuel stage.
13 And at the end of the list, we put in a general
( 14 statement on the scope of system structures and components 15 that we believe should be addressed in the maintenance 16 program and it's a general statement that says it's those 17 whose failure could impact public health or safety.
18 We look for the Reg Guide to really define in 19 better detail what that means. But for the purposes of a 20 Policy Statement, we felt this general statement was 21 appropriate. It's a little different than what was put out 22 in the first Policy Statement and the first proposed Rule 23 which said all system structures and components.
24 MR. WYLIE: What is the intent? As far as scope 25 goes. What is the intent--what would be included?
f'T YJ Heritage Reporting Corporation i (202) 628-4888 l l
__ -_ _- _- _ _ _ i
?
n
-r 53 D) 1 MR. KING: What we had decided upon at the final 2 rule stage, and I'm not sure--I think it was dcuided upon 3 after we came to you with a proposed final rule back in 4 March or 'pril, was to put a scope statement in the rule and 5 in the Rule Guide that said anything that's described in the 6 FSAR, _any system structures or components, would be covered 7 by the scope of that Rule and Reg Guide.
8 MR. WYLIE: The whole facility then?
9 MR. KING: We felt that--
10 MR. WYLIE: The FSAR describes the total facility.
11 MR. KING: It describes most of the facility, 12 that's true. It may not describe warehouses on site or 13 something like that but most of the system structures and
() 14 components are doccribed in some fashion in the rdAR.
15 MR. KING: Yeah.
16 MR. WYLIE: The total--
17 MR. KING: Whether it will stay that--
18 MR. WYLIE: All fluid systems, steata systems--
19 MR. KING: That's what's in the Reg Guide that's 20 out for comment.
21 MR. WYLIE: I find it inconsistent though with the 22 statement that is in the Policy Statement that it's limited 23 to those systems that could impact health and safety. It's 24 inconsistent with what you said.
25 MR. KING: Well, our feeling was at the time that O' Heritage Reporting Corpora'; ion (202) 628-4888
rr 54 n
Eh
'/ 1 there's something in the FSAR that probably in there because 2' it does have some tie in with safety. We would want to look 3 at it--
4 MR. WYLIE: Well, I think the instructions though 5 in the Regulations say, you know, your final safety in FSAR 6 should describe the whole plant site. They do generally.
7 MR. CARROLL: I think it's very arguable that 8 everything in the FSAR has some relation to public health 9 and safety. The standard format and content document in 10 sort of tell us everything kind of language.
11 MR. KING: That's one of the specific points we 12 made--
13 MR. MORRIS: Can I observe--I think to some extent
() 14 the information requested in the FSAR is in part requested 15 to give the staff an ability to make a judgment about the 16 analysis done--in Chapter 15. So that when the utility 17 comes in and says, well,'I've analyzed these events, these 18 design basis events, or anticipated transients, that the 19 staff then has a perspective to judge whether those are a 20 good set of bounding events to use to analyze the plant.
21 I think in the same way, that same connection 22 could be made about--if you want to look at a maintenance 23 program to see whether it is doing the right things about 24 the balance of plant, I think you need to be able to 25 consider just that same kind of a question. How could poor
%> Heritage Reporting Corporation (202) 628-4888 L
A >
55 1 maintenance or inadequate maintenance being the cause of l 2 problems in the balance of plant propagate and become a
'3 safety concern?
4 And I think this kind of area where we are trying' 1
5 to figure out--and, frankly, we are still trying to figure 6 out in our proposed Regulatory Guide how we can sort of put 7 an appropriate balance on the issue of what should you do 8 about the balance of plant.
9 And if you look at the Regulatory Guide, I think 10 we've tried to put some flexibility in there putting a lot 11 of the responsibility back on the individual plant 12 management to try to conform a maintenance program that is 13 commensurate with the significance of the importance of
( 14 ' safety of that equipment.
15 We are still struggling, however, to figure out 16 just how to get that same thought into a rule and have the 17 rule and the Reg Guide compatible with that spirit that I 18 mentioned before about the FSAR considering the whole plant, 19 but appropriately balancing the measures that you take on 20 maintenance to conform to the importance of safety of those 21 equipments.
22 The Commission has yet not I think converged on 23 how to deal with this. They've given us- you know, we hear 24 from them statements, well, we think you should consider 25 everything to be potentially important. But we haven't yet O Heritage Reporting Corporation (202) 628-4888
I 1
56
!' I
' 1 had a complete dialogue with the Commission and conversion 2 on just how you can balance that with the problem that I 3 think some of you have maybe considered of is it appropriate 4 to spend a lot of resources chasing down a lot of minor 5 problems in the balance of plant and putting together a 6 maintenance program that would have equal resources devoted 7 to all kinds of equipment. And I don't think we have, in 8 the staff, thought that was the appropriate thing to do as 9 yet. But we have no converge with the Commission with this 10 at all.
11 MR. CARROLL: I think the industry would say to 12 you that, you know, we are going to have quality maintenance 13 programs on everything that affects safety and reliability
( w) 14 of our power plant. However, if you put too much under this 15 umbrella, you are really going to dilute our efforts and 16 anything that's under the umbrella is going to require a lot 17 more documentation and whatever and interaction with the 18 Commission and, you know, we want to keep it reasonable.
19 MR. MORRIS: I think that is also our objective.
20 And I think if we get back and we come back to you with the 21 Regulatory Guide that we would develop, I would think this 22 would be a key issue we would want to focus on. And how 23 well we've done that and put this forward as a Regulatory 24 Guide.
25 MR. CARROLL: Well, the easy way out for you is
,~
\_/ Heritage Reporting Corporation (202) 628-4888 1
1y 57.
1 just to ' play the -tiypical " bring me a rock" game and, no, not 2' that;rockj try'another approach. But I would hope the 3 staff would do a better job of defining it than that.
7 4 MR. KING: I don't-think we are planning to play l
5 the "give me.a. rock" game. We put a proposal forth in the 6 draft Reg Guide that.said FSAR--stuff described in the FSAR.
7- And'we' asked a specific question directed toward that in'the-j '- 8 comment--
9 MR. CARROLL: I.think that's too broad personally.
10 MR.' KING: All right. Now, for.the Policy 11 Statement, I think it's reasonable to say all system 12 structures and components that could impact safety. That's 13 the Commission's expectation for the Policy Statement.
14' MR. CARROLL: That's fine for policy.
15 MR. WYLIE: Well, that statement in the Policy 16~ Statement, I agree with you but it does limit it to those 17 that. impact safety. In fact, the first sentence says 18 " impact safety," and then the second sentence says, 191 "significantly impact safety." Now, which is it?
20 "Significantly impact safety" or just " impact safety"?
21 MR. KING: Well, I think there has to be a 22 judgment made.
23 MR. WYLIE: Yeah, but it's a signal of what's 24 going out here.
25 MR. KING: I think you are right. Maybe we ought Heritage Reporting Corporation (202) 628-4888
H 58
_. , . - - ~ .
YA l' I to use the same words--if we've got two different words in 1
2 two different lines in there, we ought to change it to be
-3 the same words.
4 MR. WYLIE: Then that takes a definition, 5 "significant."
k 6 MR. CARROLL: It's in the-dictionary.
7 MR. KING: We'll look at that.
8 MR. WYLIE: Well then, if you look at the Reg 9 Guide, then it's different.
10 MR. KING: The Reg Guide tries to define that in a 11 more specific way.
12 MR. WYLIE: Yeah. But it expands the scope.
13 Then they go back to the question that Jay raised a while
() 14 ago as part of your definition of scope, is any system that 15 can cause a transient. A failure of a component causes a 16 transient. Now, is a SCRAM a transient?
17 MR. CARROLL: Oh, yeah.
18 MR. WYLIE: Then anything that causes a SCRAM, 19 MR. KING: Yeah, that's in the Reg Guide.
20 MR. WYLIE: Yeah.
21 MR. KING: Yeah.
22 MR. WYLIE: It's in the Reg Guide. And that's 23 inconsistent with the Policy Statement.
24 MR. KING: Again, I would hope in working on the 25 Reg Guide we come up with something that makes sense and Heritage Reporting Corporation (202) 628-4888
, f- 59 1 certainly we want it to be consistent with the Policy 2 Statement.
3 Again, I am looking for the Reg Guides that puts 4 the bounds on what that is, not so much the Policy 5 Statement, it's more to state the philosophy and the intent 6 without getting into the nitty gritty of defining that 7 boundary exactly.
8 MR. WYLIE: The Reg Guides shouldn't expand the 9 scope for the Policy Statement I wouldn't think.
10 MR. MICHELSON: Yeah. If you really mean to 11 expand the scope, you ought to put it in the Policy 12 Statement.
13 MR. WYLIE: Yep.
) 14 MR. MICHELSON: Because you are going to limit 15 yourself. Now, we'll come back and argue that you've gone 16 beyond the Policy Statement and I think once it's issued, 17 you aren't supposed to go beyond it in developing your Reg 18 Guide. It's supposed to reflect the policy.
19 MR. KING: Whatever words come out in this final 20 revised Policy Statement--
21 MR. MICHELSON: It may box you in unnecessarily--
22 undesirable, if you leave it this way. It's something for 23 you to think about.
24 MR. KING: Well, we do want the last Vu-Graph--the 25 final thing in the revised Policy Statement says we are O Heritage Reporting Corporation (202) 628-4888
l
.. 60 D
!%) 1 going to monitor improvement over the next eighteen months 2 to determine the need for additional regulatory action.
3 Basically we've identified four general. areas that 4 we are going to look at in monitoring that improvement and 5 basing that recommendation. That is, the results of the 6 inspections from the maintenance team inspections and the 7' SALP program. And that will include some selected revisits 8 to certain sights.
9 We've put in the' revised Policy Statements an item 10 that encourages licensees in the industry to supply 11 information to make their case as to what improvement 12 they've made and how they show that. So whatever they would 13 propose to supply we'd look at that as well.
() 14 We are looking for licensee commitments for 15 improvement and the particular importance in that is a 16 commitment to a standard.
17 And then finally the maintenance indicator 18 information. AUDs and whatever comes out of this additional 19 NRC industry interaction on the maintenance indicator to 20 look at what's that telling us in terms of improvement.
21 So we are not putting forth a check list saying 22 these are the specific things we are looking for and that's 23 all we are looking for. We try to identify the major areas 24 that we'll be looking at over the next eighteen months.
25 MR. CARROLL: Just a matter of semantics, Tom.
Heritage Reporting Cory3 ration (202) 628-4888
61 l 1 Youtare prejudging what you are monitoring, the way you've 2' worded it. Aran't you monitoring performance over the next 3 eighteen months that could improve or get worse?
4 MR. KING: It could get worse.
5 MR. CARROLL: I would substitute " performance" for
- 6. " improvement."
7 MR. KING: You are right.
8 DR. SHEWMON: Two questions. One, looking at the 9 proposed Policy Statement, a word I wish you would define 10 for me. I know what corrective maintenance is, preventative.
11 maintenance. I've not heard of predictive maintenance.
12 Differentiate it from preventative maintenance.
13 MR. KING: We've tried to define that in the draft
() 14 Reg Guide, but basically predictive maintenance would be,
'15 for example, looking at something like lube cil, examining 16 lube oi2 and saying, is it time to change the oil? Is it 17 time to replace the bearings? Based on pieces of metal 18 fragments or some other contaminate in the lube oil.
19 MR. CARROLL: Or another example, Paul, would be 20 vibration signature analysis.
21 MR. KING: Vibration signature analysis.
22 MR. CARROLL: You can learn an awful lot about 23 what's going on inside a piece of machinery by following the 1
l 24 vibration.
- 25 DR. SHEWMON: I would call those maintenance, but l
l l Heritage Reporting Corporation (202) 628-4888 1
1 L__._ _ _______
l 1
f')
'~'
1 we choose to call them--I'm sorry. Monitoring, but we call 2 it maintenance because it's a maintenance program we are l 1
3 talking about. )
q 4 MR. CARROLL: Call it predictive maintenance.
5 MR. KING: Okay. l 6 DR. SHEWMON: A different question. There is a 7 strong regulatory framework and tradition of licensing 8 operators and monitoring their training. The training of 9 maintenance personnel is handled by INPO who has procedures 10 and accreditation for these things also? Is that correct?
11 MR. KING: Training of maintenance personnel is 12 handled under the INFO training accreditation process that I 13 believed we've endorsed in a Policy Statement. That's in r
(_y) 14 place. Our Reg Guide acknowledges that as being an 15 acceptable vehicle for training and meeting what we had in 16 mind under the maintenance training.
17 DR. SHEWMON: Fine, thank you.
18 DR. REMICK: Tom, I'm not quite clear. When you 19 talk about additional regulatory actions, are you talking 20 beyond the issuance of a rule? Or is that the point at 21 which you are going to give the Commission a rule on 1/1991 22 and then on 4/91 you are going to recommend any additional 23 regulatory action, but is that recommendation to issue the 24 rule or going beyond the rule? I'm not quite clear.
25 MR. KING: The recommendation could--right now,
(^l
\_) Heritage Reporting Corporation (202) 628-4888 :
63 t
7-)
1 there are several options for that recommendation. It could 2 be issue the rule and Reg Guide. It could be we don't need
'L 3 to issue the rule and Reg Guide. Let's revise the Policy 4 Statement again and acknowledge the commitments or whatever 5 is made that made us decide we don't need a rule.
6 DR. REMICK: This says additional regulatory 7 action.
8 MR. KING: Yes. Maybe it is somewhat confusing.
9 DR. REMICK: But that's the point at which the 10 staff plans to recommend to the Commission such things as 11 issue the rule and Reg Guide and possible other things, is 12 that right?
13 MR. KING: Issue the rule and Reg Guide. Issue p
(_) 14 the rule and Reg Guide plus other things.
15 DR. REMICK: Okay.
16 MR. KING: Don't issue the rule and Reg Guide but 17 do this other thing. Right now it's open. Don't read it to 18 mean that that's the recommendation that will issued in the 19 rule and Reg Guide.
20 DR. REMICK: No, I understand that.
21 MR. KING: That may not be the recommendation.
22 DR. REMICK: It says additional. I'm saying is 23 that additional to the rule or--
24 MR. KING: You've got a point. Maybe we ought to 25 look at that word.
j
(~) '"
Heritage Reporting Corporation (202) 628-4888
_ _ _ _ . __ . - _ - ._ _ _ . _ . A
,3 64 1
l 1 DR. REMICK: Okay. Other questions?
2 MR. KING: That's the end of my talk.
3 MR. WYLIE: This covers basically the Policy 4 Statement.
5 MR. KING: Yes.
6 MR. WYLIE: Or are we going to discuss the Reg 7 Guide?
8 MR. MICHELSON: No , there was no intention. If 9 you have questions that might help you with the Policy 10 Statement I'm sure that it's in order, but we don't intend 11 to write any remarks on the Reg Guide at this time.
12 MR. WYLIE: Well, I don't have any questions.
13 I've already made some comments about the scope being
()
14 inconsistent with the Policy Statement that's in the--
15 MR. MICHELSON: We will have an opportunity to 16 comment at any length on the Reg Guide in a few months.
17 MR. WYLIE: I don't know that we need to discuss 18 any of them right now then.
19 MR. CARROLL: One comment, and I believe it was 20 from our meeting in Region 1 that goes to Paul's question 21 about training. I guess I've been hearint- that people feel 22 that INPO accredited programs for additional training of 23 maintenance personnel are very good. What needs to be done, 24 and I guess is in progress on requal training of the 25 journeymen and journeymen operators. And that's something
(~h Heritage Reporting Corporation (202) 628-4888
,-i
[
$ t- .;
65 g ..
ll you might want'to' consider emphasizing ~during.the next J 2 eighteen months.
3 I believe that is an area te needs--
4 MR. KING: You are saying requal training and 5 . maintenance.is-not covered under the INPO accreditation?
6 MR. CARROLL: I think INPO has plans to--
7 DR. REMICK: Well, continuing training is a part-8 of all the INPO training programs. That's a requirement but 9 some of the people--the incumbents already on the job.are 10 not necessarily getting the same initial training that a new 11 hire'gets. In general they are doing that through 12 continuing training programs. So I think you are talking 13 about incumbents. The qualifications--those things are
()\ 14 being addressed but I don't think in all cases they are 15 complete.
16 MR. KING: Okay.
17 DR. REMICK: You know, new people coming in are 18 getting the full scope. The question is if you have 19 incumbents you can't stop their being qualified immediately 20 and the question is how do you bring them up to speed of new 21 people. I think that's what Jay's referring to.
22 MR. CARROLL: That's correct.
23 MR. KING: All right. We'll talk about it.
24 MR. WYLIE: Just a comment. Back in the beginn!.ng 25 of the Policy Statement, you know, it says that the Heritage Reporting Corporation (202) 628-4888
_ = = _ - - - - - _ _ _ _ _ __ b
i 66 r,
- 'l Commission expects each licensee to assume responsibility 2 for improving maintenance at their facilities. That's sort
. 3 of~a goal statement for the Policy Statement. It would seem 4 4 like to me it would have been better stated to say that'the 5 Commission expects each licensee to assume responsibility 6 for establishing an acceptable maintenance program rather 7 than just improving--it implies it, as i said earlier, that 8 there are no good programs out there.
9 MR. KING: Well, we got a lot of letters at the 10 time the proposed rule was out for comment. We got a lot of 11 letters and commitments in from NUMARC, from licensees, 12 saying that they acknowledged that improvement was needed, 13 and they were committing to make improvements. In general
'( ) 14 terms. I think that's why it's worded that way. But we'll 15 take care of it.
16 MR. WYLIE: But the objective is to have 17 acceptable programs, right?
18 MR. KING: The objective is to have an acceptable 19 program. We'll look at that.
20 MR. WYLIE: It could improve even at a higher --
21 MR. KING: I'll look at that.
22 DR. REMICK: Tom, it seems to me that there are 23 people who will not be happy that the Commission is not 24 issuing the rule at this time. It seems to me that the 25 Commission would want to be a little bit more specific why l Heritage Reporting Corporation (202) 628-4888
7 .
67
~( -
1 they are deferring and point out some of these indications I I
~2 that things are improving. I think we certainly found at 3 Region l', you folks have told us that there are
- 4. improvements. There's a way to go. But it seems to me that 5 the Policy Statement doesn't give much justification why the 6 Commission is doing what it is doing now. There are a few 7 words there, but if you are not familiar with it, it doesn't 8 say much.
9 MR. KING: Yes. There are a few words that 10 acknowledge the improvement, u
11 DR. REMICK: That's where I even thought the 12 training programs could be mentioned as one initiative that 13 the industry has taken and so just thinking about the
.() 14 general public, some of whom would feel that the Commission 15 is making a mistake by not acting more positively at the 16 moment. I don't think you give them much food for thought.
17 MR. CARROLL: You also have to read inside NRC as 18 well as the Policy Statement to know what's going on.
19 DR. REMICK: Yes.
20- MR. KING: Let me look at that. One time we had 21 quite a list of things in there that were the improved 22 areas. One of the earlier drafts of this thing. It got 23 taken out. But maybe a couple of embellishments in a couple 24 of areas might be worthwhile. I'll look at that.
25 DR. REMICK: Does the staff have further O Heritage Reporting Corporation (202) 628-4888
.r s
tr 68 I?
1 presentations?
2 MR, KING: No. This concludes the presentation.
3, DR. REMICK: Any other questions or. comments from 4 the Committee?
5 .If not, I suggest that we take our mid-morning break at this time,
~
6 Let's return at twenty minutes past the 7- hour and then we'll take up the proposed letter.
8 (Whereupon, there was a recess at 10:30 a.m.
9 followed by a break for Lunch until 1:30 p.m.)
10 11 12
-i - 13 14 15 16 17 18 19-20 21 22 23
'24 25
-O Heritage Reporting Corporation (202) 628-4888
i 69
(%
1 A E. I E B H Q Q H E E E E I. Q H 2 (1:30 p.m.)
3 DR. REMICK: Gentlemen, I would like to reconvene.
4 I would like.to inform you of several changes in 5 our agenda.
!- 6 From 1:30 to 2:30 we will take up Agenda Item 7 . Number 3 as planned.
8 And then Item Number 4 we expect to take only 9 about a half hour and that will be from 2:30 to 3:00.
10 From 3:00 to 4:00 then we are going to insert 11 Agenda Item Number 6, Accident Sensitivity Scales.
1:2 And then following that, at 4:15, instead of 13 Industrial Sabotage, our subcommittee chairman is not here,
-[] 14 so we are going.to replace that with NUMARC Activities, 15 which is Agenda Item Number 10, which was originally 16 scheduled for tomorrow.
17 So do you have that?
18 We have a request that the agenda be retyped for 19 the benefit of those with a short memory.
20 So the next item then is Nuclear Power Plant 21 License Renewal.
22 Hal Lewis is the subcommittee chairman. He is not 23 going to be here today. But our vice chairman has agreed to 24 chair this portion of the meeting.
25 So Carl, I turn the meeting over to you to discuss Heritage Reporting Corporation (202) 628-4888
l.{i
'.7 .;
70 mn ' -
'l nuclear power plant license renewal.
U 2 NR. MICHELSON: Thank you, Mr. Chairman.
- 3 .This is a subject of considerable interest, I 4 understand, to the Commission. And the purpose of the
- 5. discussion today is just to get a briefing from the staff as 6 to what is going on in this area. There is no anticipated ~
7 letter.
8' But this will provide a basis ~then for our better 9- understanding of perhaps what kind of ACRS activity might be 10 inputted to the problem in the future.
11 And you have, in Tab 3, I think a very good status 12 report, along with some other material, which you might find 13 of interest.
() 14 Not having had time to read it all I can't tell 15 you what is in.it, but the staff is here. Karl Kniel I 16 think is taking the lead on it. We have his handout. uSo I-
.17 believe we are ready to-roll.
18 So Karl, if you would, we will proceed.
19 (Slides shown) 20 MR. KNIEL: I am here to speak to you about the 21 license renewal effort that is being conducted by the staff.
22 DR. REMICK: Karl, you are going to have to speak 23 a little bit louder, even with the mike. We are having a 24- little bit of trouble hearing you.
25 MR. KNIEL: Okay. Can you hear me better now?
Heritage Reporting Corporation (202) 628-4888 l
h-l 7A
- /W (E V 1 DR. REMICK: Yes.
'2 MR. KNIEL: Okay.
3 DR..REMICK: Thank you.
4' MR. KNIEL: I'm representing the staff today on 5 this. license renewal effort.
6 As Dr. Michelson pointed out, there is a 7 considerable effort at the staff.
- 8. Both the Office of Research and NRR are involved 9 heavily in-it, and I am here at the request of the ACRS to 10 kind of brief the ACRS as to what kind of activities have 11 gone on, and what is going on at the moment, and what kind 12 of direction we are heading in.
13 So the objective of my talk is to provide the
( 14 status and. identify and discuss a little bit the important 15 issues.
16 I am going to discuss those in sort of a broad 17 sense without reaching any conclusions in the middle part of 18 my talk, so to speak, or the beginning of the talk. And at 19 the end I will present a proposed program plan and schedule 20 that we have just recently proposed to the Commission for 21 their approval.
22 The general approach to the license renewal
.23 involves a rulemaking in which we are proposing, we will 24 propose and will follow up on a rule which essentially will 25 define the requirements for license renewal.
O Heritage Reporting Corporation (202) 628-4888
_ _ _ _ _ _ _ - _ _ _ _ _ - _ _ - - _ _ _ _ ._ J
i
<~s 72
()
1 As you may or may not know, this isn't absolutely 2 necessary in a legal sense now. Licenses can be renewed.
3 But there is no definitive discussion anywhere as to what 4 would be involved in a license renewal process.
5 So that the effort that we are engaged in is an 6 attempt to be definitive about that and to provide an 7 adequate basis, generic basis, you might say, that would 8 assure the public of safety and would provide the licensees 9 with some kind of understanding of what the requirements 10 would be.
11 DR. SHEWMON: I have heard that that 40 years is 12 written into law someplace.
13 Can you tell me if that is correct, and where?
tm k_) 14 MR. KNIEL: Yes. There is a 40-year limit on a 15 license that you can issue legally. And all the licenses 16 today --
17 DR. SHEWMON: Is that the Atomic Energy Act?
18 NR. KNIEL: Yes, it is in the Atomic Energy Act.
19 That is correct. And the Act doesn't make any reference to 20 any kind of a technical limitation.
21 The 40-year limit was sort of arrived at on the 22 basis of financial considerations into how long it takes to 23 pay off for the plant.
24 So there isn't any technical basis regarding aging 25 or any other consideration like that that went into the n
U Heritage Reporting Corporation (202) 628-4888 l
i - -
73
.rm.
1 discussion..
2 DR. REMICK: That brings up a related point. Is 3 there any position on how long beyond 40 years a license can 4 be extended?
5 MR. KNIEL: That will be part of my presentation.
6 DR. REMICK: All right. Fine.
7 MR. KNIEL: As a part of the rulemaking effort, we 8 expect to write a number of regulatory guides which will 9 supplement the rule in the manner that we have been 10 following in recent years where we write a rule and provide 11 a more explicit guidance into separate guides, such as the 12 station blackout rules and other rules like that.
13 So there is a strong effort, there will be a
() 14 strong effortLon writing guides. ,
'15 There is a sort of a corresponding effort on the 16 part of industry to develop technical positions and that 17 network is being coordinated through NUMARC, and they are 18 submitting at the moment, there are like ten different 19 technical reports have been scheduled that are on different 20 subjects.
21 We have received the first one on PWR containments 22 August 31, just a few days ago. That is not strictly 23 correct. We had received another one on sort of 24 prioritization of how you look at different systems in terms 25 of aging, and we received that several months ago. But that
(~) Reporting Corporation
)
(_/ Heritage (202) 628-4888 I
.____________________J
74
.1 is going to be resubmitted so we can think of it that the 2 first report was submitted just recently.
3 We will be reviewing these reports and we hope to 4 be able to, I will discuss that in greater detail, what we 5 are going to do with them.
6 The other part of the approach is that there are 7 going to be two lead plants. The lead plants have been 8 identified. They are Yankee Rowe and Monticello, in
11 And I will discuss a little bit more how the lead 12 plant activities get tied into the whole rulemaking effort.
13 As you are probably aware, we have been at this
() 14 for a little bit of time already. This is a summary of the 15 . previous milestones, as early as the Fall of --
16 DR. REMICK: It says '89. '
17 MR. KNIEL: Yes. It should have been '86, I 18 think. Right. It should have been '86. I'm sorry for the 19 misprint. It should be November '86. We published a notice l
20 of intent with a bunch of questions and we've got responses 21 from those questions from industry and from a very limited 22 amount of public interest groups.
23 We then went to an advance notice of proposed l
24 rulemaking, after there was some discussion about whether we 25 should go to a policy statement or whether we should go Beritage Reporting Corporation (202) 628-4888
_ _ _ _ _ _ _ _ _ _ _ _ i
t i
, . 75 i
\- 1 directly to'a rule, which was resolved in favor of going to i 2 a rule because we wanted to be more definitive about what we 3 were going to do.
4 And the advanced notice was published last year,
.5 just almost' exactly a year ago, and we published, in 6 connection with that we published a NUREG report which 7 discussed some of the options that we might consider for 8 license renewal.
9 We recently had a briefing in June to the 10 Commission on what our progress has been. And the_ briefing 11 I am giving you here today is essentially an update of that 12 briefing.
13 Initial drafts have been completed of a proposed
() 14 rule and a regulatory analysis to go over the rule, and an 15 environmental assessment.
16 DR. REMICK: Has the staff determined then that an 17 EIS is not required, the assessment is adequate?
18 MR. KNIEL: I'll get into that subject a little 19 more also.
20 DR. REMICK: Okay.
21 MR. KNIEL: The current activities are the 22 identification and resolution of technical and procedural 23 isrues for the rule, refining the draft of proposed rule and 24 concurrent revisions to the regulatory analysis, and 25 expanding environmental assessment.
Heritage Reporting Corporation (202) 628-4888
(y 76
~
1 I will expand on each one of these subjects.
2 In the next few slides I am going to discuss sort 3 of a number of different issues, including procedural 4 issues, and sort of scope out that space there that we are 5 considering.
6 The basic problem the way we see it in license 7 renewal is the adequacy of the licensing basis. In other 8 words, is the plant as it appears, and has been modified, is 9 that adequate in the safety sense, for the renewal period?
10 And the other basic question, assumption is, what 11 about the degradation of the plant during the renewal 12 period? What do we have to do about that? Are there, what 13 considerations need to be focused on to assure that the 14 additional 20 years of operation can be, the operation can 15 be as safe as it has been in the last, in the initial period 16 of licensing?
17 MR. MICHELSON: Would the renewed license be for 18 20 years?
19 MR. KNIEL: I'll get into that subject a little 20 more also.
21 MR. MICHELSON: Okay.
22 MR. KNIEL: The major alternatives that were 23 considered, and these were discussed in NUREG 1317, are 24 these four that are listed here in this viewgraph.
25 One of the options is using the current licensing p.
l
' (_ Heritage Reporting Corporation (202) 628-4888 l
77 i',, )
1 basis as amended to the date of the renewal application, and 2 essentially assuming that any aging considerations have been 3 appropriately considered during the period of the operation 4 of the plant. In other words, no additional effort.
5 The second alternative is essentially an extension 6 of that. In other words, to accept the current licensing 7 basis, but to make an assessment of the aging, of the 8 management aging for the renewal period.
9 In other words, you have to decide on what systems 10 components need to be reviewed and what needs to be shown 11 technically so that the plant could operate for the renewal 12 period safely.
13 Part of that consideration is to guide those
!( ) 14 choices by using PRA technology which would incorporate a 15 way of evaluating risk from aged components and systems 16 structures.
17 The third alternative is the extension further to 18 require an assessment against selected new plant standards.
19 In other words, we would pick certain up to date standards 20 that we would want to judge each renewal application 21 against.
22 And the fourth option would be to require 23 compliance with new plant standards, period, for a renewal 24 license.
25 DR. SHENMON: Would you go through these again?
'O
'w/ Heritage Reporting Corporation (202) 628-4888
78 1 <
1 MR. KNIEL: I'm going to emphasize the one we sort 2 of decided to proceed with.
3 DR. SHEWMON: It is not clear to me what the 4 difference is between A, which is the." original basis as 5 amended to up to the date of renewal application," and 6 " assessment of design differences against selected new 7 standards."
8 MR. KNIEL: Okay. Essentially, Option C would 9 probably require a certain amount of backfit, depending on 10 what was found in evaluating design against certain new 11 standards.
12 Whereas option A and B would not contemplate 13 backfits in the areas of --
() 14 DR. SHEWMON: As amended, if it was licensed on 15 39-1/2, it would be licensed on 40-1/2, on the same casis?
16 I mean, if it went up to 40 years, you would just extend the 17 same requirements that it had before?
18 MR. KNIEL: That's right.
19 DR. SHEWMON: Okay.
20 MR. KNIEL: As amended means like we passed a 21 station blackout rule and a lot of plants had to conform to 22 that. So the original licensing basis has certainly been 23 changed by the station blackout rule. It has been changed 1
24 by the ATWS rule. It has been changed by all sorts of other 25 things.
i V l
.h v Heritage Reporting Corporation (202) 628-4888
\
L_:_ - - __
t 1 l
E g, 79 1 DR. SHEWMON: Okay. Fine.
2 DR. REMICK: You are going to tell us which one of 3 these you opted for?
4 MR. KNIEL: Yes.
5 DR. REMICK: All right.
6 MR. KNIEL: When I say we opted for, that we are 7 proposing to opt for. The Commission has not blessed that 8 choice.
9 Another one of the issues is timely renewal.
10 At the present time, legally, an cpplicant can 11 request within 30 days of his expiration to renew his 12 license, and he would then continue to operate his plant 13 after the four year period, without having us act on it.
A T,) 14 MR. MICHELSON: When do these periods start, the 15 original 40 years?
16 MR. KNIEL: The original 40 years, with many 17 plants, it started at the construction permit stage but now 18 most of the plants have either licenses that start from the 19 initial operating license or are applying for those.
20 MR. MICHELSON: Okay. Now, you kind of mix the 21 two together in your answer. You are saying that some of 22 the plants will be construction permit, some of them will be 23 operating?
24 MR. KNIEL: Only those that haven't applied. Many 25 plants that were started with the construction permit have
' Heritage Reporting Corporation (202} 628-4888
l
/~
80 h
! )
\# 1 now applied to change that so that their 40 year license 2 originates from the date of the operating license. l
-3 MR. MICHELSON: Okay. But in general it will be v,
4 the date of the operating license?
5 MR. KNIEL: That is correct.
6 HR. MICHELSON: Okay. ]
7 MR. CARROLL: I have kind of lost' track. I 8 remember in my former life we were concerned about getting 9 it changed from the CP to the OL basis, but were concerned 10 that this would result in a public hearing.
11 Did that ever eventuate?
12 MR. KNIEL: I'm not real u; co date on this. But 13 I understand a number of plants have made the change and it
()
,m 14 doesn't seem to have been a big fuss about it.
15 Our thoughts were to, we want to extend this 30-16 day period, and we have been thinking in terms of like three 17 to five years, and our most recent thinking is more like 18 three years.
19 In other words, if an applicant would apply three 20 years before the expiration of his license, then the timely 21 renewal policy would apply. And we are picking three years 22 because we think we can make a decision within a three year 23 period regarding the license.
24 And the other factor here is that we expect most 25 utilities will come in way before that. They will come in
,/
x/ Heritage Reporting Corporation (202) 628-4888
L I l
l l i
,_ - 81 i r ;
1 eight, ten, 12 years ahead of time.
2 What are the requirements of the National !
I 3 Environmental Policy Act?
4 And we have considered a spectrum of options of 5 what we should do about this.
6 The first basic option is essentially an 7 environmental assessment, in which we do an assessment on 8 the rule to be published with the rule, which would involve 9 a limited number of generic analysis on what kind of 10 environmental problems there would be on individual plants.
11 The other approach is to write a generic 12 environmental impact statement, which would be a rather 13 comprehensive, very thorough document, an attempt to j qj
! 14 essentially avaluate the impact of relicensing all plants 15 that are now operating.
16 And this would involve a rulemaking actioa in 17 which we would attempt to resolve those problems 18 generically, which would minimize the amount of effort that 19 would have to be done by both the staff and the applicants, 20 licensee applicants, during actual license renewal requests.
21 DR. REMICK: Any decision on that? Or are we 22 going to hear about that later also?
23 MR. KNIEL: You're going to hear about that.
24 DR. REMICK: All right.
25 MR. KNIEL: As I said, I'm trying to give you kind Heritage Reporting Corporation (202) 628-4888
1 of a scope'of'the issues from the beginning and then a 2 proposal at the end.
3 DR. REMICK: Okay. The suspense is obviously 4 killing us.
5 MR. KNIEL: I have a good audience, then.
6 The severe accident issue closure has been a 7 consideration of license renewal. I'm sure the Committee is 8 up to date on the severe accident IPE question.
9 And we have considered a number of ways of
^
10 including that. And one is by not including it, by 11 essentially maintaining the effort on closing it on a case 12 by case basis.
13 Another consideration would be to have a separate G
(_/ 14 rulemaking on the severe accident issue. And then another 15 way of handling it would be to make it actually a part of 16 the license renewal rule. In other words, to include j 17 specific requirements regarding closure of the severe 18 accident issue in the rule itself.
19 There is a question of the backfit rule. And the 20 two breakdowns that I have listed here are essentially, we 21 are thinking about not including the requirements in the 22 rule as being as a backfit. )
23 In other words, the rule would require certain 24 things and they would not be considered a backfit.
25 But requirements beyond the rule, any requirement O Heritage Reporting Corporation (202) 628-4888 i
)
, ,=------- -.
83-
'l~ that came out beyond'the rule, would be, the backfit rule 2 would still be applicable. :I think we would have to,'the i
3 way I-understand it we would have to provide for that in the 4 rule because the backfit rule may only apply for the'first 5 40 years'of' operation.
6 In other words, the second bullet here' refers to a 7 specific provision in the rule which would say the backfit 8 rule continues to apply during the renewal period.
9 MR. MICHELSON: But, as I understand what you 10 said, whatever requirements.you deem necessary at the time 11 of renewing the license would not be considered backr'ito?
12 MR. KNIEL: That is correct.
13 MR. MICHELSON: But if at a later date you added
() 14 something, then it is treated as a backfit, perhaps?
15 MR. KNIEL: Correct.
16 MR. MICHELSON: Depending.on how the rule is 17 written.
18 MR. KNIEL: Right.
19 MR. MICHELSON: Okay. Thank you.
l 20 MR. KNIEL: We have looked at the potential for 21 applying probabilistic risk assessment in the license 22 renewal arena.
23 We were considering applying it as a means of l-24 identifying the safety systems structures and components 25 which are subject to aging degradation. And we have also Beritage Reporting Corporation (202) 628-4888 i
l-
f
,_ 84 I)
'-< 1 considered as a tool for verifying continued acceptability 2 of the current licensing basis.
3 This second item here where it is not being 4 emphasized because we believe the severe accident work is 5 going to address a lot of the acceptability of the plant, 6 and we are leaning towards one of the options in there that 7 don' t include backfitting old requirements.
8 MR. MICHELSON: Under that first bullet, the first 9 item, you are talking about PRA somehow.
10 MR. KNIEL: That's right.
11 MR. MICHELSON: This whole slide.
12 MR. KN. '5: Right.
13 MR. MICHELSON: What do you mean, how can PRA im i) t_ 14 identify components subject to aging degradation?
15 MR. KNIEL: We started, and the NPAR program has 16 sponsored work on how do you use PRA to show the incremental 17 risk from aging considerations.
18 MR. MICHELSON: Yes. Not from aging 19 considerations, is it?
20 MR. KNIEL: Well, I'm using aging as a very 21 general term. Lack of reliability. Whatever you want to 22 call it.
23 Essentially, from deteriorating situations. How 24 do you show the increased risk.
25 MR. MICHELSON: Somehow you have to put in changes
'J Heritage Reporting Corporation (202) 628-4888
i
< -- - 85
~
'" l in the reliability of the individual' components and you have 2- to know what that is.-
3 MR. KNIEL: Right.
4 MR. MICHELSON:- In order to do a PRA. And do you 5 know that?
6 MR. KNIEL: Well, I think in some cases-we'do know 7 it.
8' MR. MICHELSON: I think in some cases that is 9 correct.
10 MR. KNIEL:' Yes.
11 MR. MICHELSON: But not very many cases.
12 MR. KNIEL: We got involved in this'because we are 13 trying to write a regulatory analysis in a fairly rigorous t ,
14 sense.
15 MR. MICHELSON: Yes. But wouldn't this require a 16 'significant research program to show the effect of aging' on 17 failure rate?
18 MR. KNIEL: Yes, it does. And what I'm trying to 19 tell you is I think we are doing some of that work. _The 20 NPAR program had started on that work. And we have 21 reinforced that work in terms of the license renewal, 22 particularly in terms of trying to write a regulatory 23 analysis, in which we could 24 MR. MICHELSON: To do a license renewal in the 25 next couple of years or so, it is already too late to get O' Heritage Reporting Corporation (202) 628-4888
7
. 86 1 the research program data. It takes a lot of time to get 2 that kind of information, doesn't it?
3- MR. KNIEL: The points you made are valid. It is 4 not clear how well we will be able to use the PRA or how far 5' the technology can be moved so that we can use it in a very.
6 constructive sense.
7 I think there is good reason to believe that it 8 can be used. That's my personal opinion. I think we 9 certainly should. push the technology because if we don't 10 we're going to get into these arguments that we had in the 11 original licensing about deterministic, using just pure 12 deterministic methods and not knowing really what the risk 13 was from it.
( J- 14 MR. MICHELSON: In PRA, a lot of what you do is 15 model active cocponents and their probability of failure.
16 But passive couponents like pipes and wires and so forth are 17 not necessarily modeled. They can be, but not normally.
18 But yet, wire ages and its probability of failure 19 would intuitively increase with time. And somehow we don't 20 even consider that in a PRA normally, but do you have to at 21 this point in time?
22 MR. KNIEL: Those are all valid points also. I 23 think you have to include the vulnerability of passive 24 components to various aging mechanisms. And they would have 25 to be considered.
Heritage Reporting Corporation (202) 628-4888
.m 87
)
1 But I think if you can consider those in a 2 quantitative sense, ultimately I think it will help the 3 cause of prioritizing the kind of effort you want to make in 4 terms of managing aging.
5 DR. CATTONt Do you have somebody trying to do one 6 of these kinds of PRAs?
7 MR. KNIEL: Yes.
8 DR. REMICK: I'm not quite sure I completely 9 understand. The purpose of the PRA is to identify 10 predominant sequences, and then if you look at those to 11 identify the components and systems, and ask yourself how 12 are these subject to aging? Is that what you, when you say 13 you use it to prioritize, is that how you would do it? I'm A
(_) 14 not quite sure I understand.
15 MR. KNIEL: I think ultimately what you do is, 16 knowing what deterioration is, and if you can represent 17 deterioration appropriately, you do the PRA and that will 18 tell you how important that deterioration is in terms of 19 risk.
20 DR. REMICK: So then the approach is if I 21 understand what you just said, is to take the information 22 you have on aging and apply it intelligently in the PRA to 23 tell you how important that is.
24 MR. KNIEL: Right.
1 25 DR. REMICK: Is that the approach?
l Heritage Reporting Corporation (202) 628-4888
p r<
1km -
88 ia;- .
~
I
-1 MR. KNIEL: Right.
- 2. DR. REMICK: Okay.
3 DR. CATTON: So the PRA is just a vehicle?
4 MR. KNIEL: The PRA is just a vehicle. This kind 5 of thing hasn't been included, I mean the reliability of 6 components in PRAs now does or doesn't include aging you 7 might say. To some extent it does. To a large' extent it-8 doesn't.
9 DR. SHEWMON: You have a research program on aging 10 to help you shape up some issues of some sort. Is this one 11 of them? How you get better input on what equipment you 12 would need to worry about?
13 MR. KNIEL: The techniques of doing a PRA, which
() 14 incorporates the aging mechanisms, is part of the NPAR 15 program.
16 DR. SHEWMON: I guess I was more interested in 17 knowing how you were going to decide or whether somebody was 18 trying to help you decide what components you should worry 19 about and what aging rates you should put in for them.
20 MR. KNIEL: I would rather have somebody from the 21 NPAR program respond to that. I think we are concerned 22 about that in the NPAR program but it is not as well 23 coordinated as it might be.
24 DR. SHEWMON: Would you spell Empire?
25 MR. KHIEL: N-P-A-R.
O Heritage Reporting Corporation (202) 628-4888
7.,
89 i ) 1 DR. SHEWMON: It's not Empire at all then. Okay.
2 MR. WYLIE: Nuclear Power Plant Aging Research.
3 MR. KNIEL: Here is a length of renewal term.
4 The kinds of things we are thinking about is case 5 by case. And we have discussed 20 years versus 40 years 6 maximum. Again, the law limits you to 40 years, so 40 years 7 is the greatest time we could relicense for.
8 There seems to be a sort of a consensus that maybe 9 even includes industry, that 20 years is the kind of number 10 that maybe we ought to be talking about at the moment, with 11 no restriction on renewals after 20 years.
12 In other words, there is no built-in restriction 13 into the rule that you could not ask for another renewal.
(,)j I'
14 So we're talking about at the moment limiting the 15 renewal period to 20 years. That is, the actual renewal 16 after the 40 years.
17 DR. REMICK: For what reasons? I could understand 18 no more than 40.
19 MR. KNIEL: The principal reason is lack of 20 confidence in being able to project those real long numbers.
21 DR. REMICK: You predicted 40 years initially 22 apparently.
23 MR. KNIEL: But we' re talking 80 years.
24 DR. REMICK: But you're going to take a close look l 25 after 40 years.
Heritage Reporting Corporation (202) 628-4888
d fa .
+
g 90
'f- f" 1 MR. KNIEL: Yes. It just seems'to be sort of a i
1 2- ~ collegial l kind of consensus that_20 years might be the right- ,
3- number. 'But we haven't necessarily restricted'it, but 4- -that's the kind of number we are~using at the moment, 20-
'5: year renewal period. -
6 DR. REMICK: Of course, you've imposed 20 years on 7 a number of research reactor renewals, I believe.
8 HR. KNIEL: Yes.
9 DR. REMICK: There have been a number of research 10 reactor renewals in which the staff for some reason thought 11 20 years.
12 T'm not sure that quote " industry" agreed with 13 that.
). 14' MR. KNIEL: The other factor is, you might.think 15 of it in terms of when you actually issue the license, you 16 will see what we're discussing'. We're talking about super 17 session licenses.
18 So if somebody comes in 12 years ahead of time, 19 and they get reviewed in two years, then they will get their 20 new license and that license will be' issued for 30 years. A 21 new license will be issued immediately.
22 So it will be the 20 years plus the additional ten 23 that they have to go on their present license. But it'll be 24 a new license.
25 So that's the 30 year license. And there may be Beritage Reporting Corporation (202) 628-4888
777:;3+;
.. ~ ' .,
.[.
O
[:)% ,
c .(.
91: :;
ynfj (, ,
- 11 ..quiteLa few plants-that' handle itLthat way. ..
2 2- DR. REMICK:' Okay.
'3 h
- )
5-6
.7-
.8 9
s 10.
s .11 r12
.13
- . 14 15' ,
.16 17
-18 19 20 21-l 22 23 24 25 O Heritage Reporting Corporation (202) 628-4888
i i
92 V(3 1 MR. KNIEL: This is largely a rehush of what we 2 have already discussed. This is a discussion of the earlier i i
3 state of the application, and we have been talking like 4 twelve, fifteen or twenty years prior to the expiration of 5 the current license. And our information indicates that the 6 utilities would like ten to twelve years, that they really 7 need ten to twelve years for planning purposes. In other 8 words, they need to decide ten years ahead of time or more 9 what their principal capacity is going to be and what they 10 are going to get it from, whether it is going to be 11 increased coal, conservation or whatever.
12 DR. CATTON: What kinds of things do they 13 anticipate that they are going to have to do, go in and im
(_) 14 replace all of the wiring or something?
15 MR. KNIEL: You mean in a plant?
16 DR. CATTON: Yes. In order to get ready to get 17 the renewal, what kind of things do they anticipate that 18 they are going to have to do?
19 MR. WYLIE: Some may and some may not.
20 DR. SHEWMON: Build a pressure vessel.
21 DR. CATTON: Oh, okay. Maybe change out steam 22 generators, major new piping systems.
23 MR. KNIEL: A steam generator is certainly an item 24 and other piping; stress, corrosion, and cracking piping.
25 DR. CATTON: I could just imagine what they are A
I)
' Heritage Reporting Corporation (202) 628-4888
93 l(%-) 1 going to have to do if all of-those wires have to be 2 replaced.
3 MR. KNIEL: That is the subject of the NPAR
- 4. program. It has not been decided yet.
5 DR. SHENMON: The hopper is still in good shape.
6 DR. CATTON: When two pieces of that copper touch 7 it gets exciting.
8 MR. KNIEL: I thank that your point is well taken 9 in the sense that if you plan ten years ahead of time that 10 you can use a lot of your scheduled down time to do some of 11 the things that you might want to change. So then you do.
12 not have to take a lot of time out afterwards.
13 MR. CARROLL: I also know of fossil plants that
() 14' ran 55 years and really did not have any major wiring 15- problems.
-16 DR. CATTON: I recollect something at the 17 Savannah River, but I do not recollect what it was.
18 MR. WYLIE: It depends. You have got to remember 19 that there are various compounds used by'different 20 utilities, and some of them age faster than others. So it 21 is really plant specific.
22 DR. CATTON: They might have two different kinds 23 in the same cable.
24 MR. WYLIE: Oh, yes. I remember that they used to 25 use latex insulation, and it was very poor as far as aging l Heritage Reporting Corporation I
(202) 628-4888
94
,/
k/ 1 goes. The synthetics came out and they are very good.
2 MR. MICHELSON: There is also a serious question 3 about the flammability of some of this wiring as it gets 4 older, because the inhibitors that are in it are out gassing 5 over life, so that has to be kind of cleared up.
6 DR. CATTON: It sounds like there are all kinds of 7 exciting things.
8 MR. KNIEL: One of the additional features of the 9 longer period allowed for application would be a flexibility 10 to the NRC for reviewing applications.
11 MR. MICHELSON: Does that mean that you try to fix 12 it so that you can take more than two or three years if 13 necessary to do it?
14 I think yes, but not to do the actual
( )) MR. KNIEL:
15 work.
16 MR. MICHELSON: What puzzles me is if everyone 17 came in tomorrow thinking that it was a great idea to get 18 this long lead time, that is not flexibility for you.
19 MR. KNIEL: No. But if we allowed people to come 20 in say up to twenty years ahead of time, then the ones who 21 came in tomorrow that had twenty years we could put them off 22 for awhile.
23 MR. MICHELSON: That is the flexibility that you 24 are talking about.
25 MR. KNIEL: That is the flexibility that I am l ~
/ C's,
'xs) Heritage Reporting Corporation (202) 628-4888
L-k
[,
b ..
'95 L -A U l' talking about.
2 DR. REMICK: Although I can see from the utility's 3 standpoint that if they have got to make the decision of are l; 4 we going to renew the license of this facility or build a L
5 new facility that twelve or fifteen years is not 6 unreasonable.
7 MR. KNIEL: Yes. The only limiting feature here 8 is we would like to have as much experience on the original 9 license as we can before we renew the license. So that is 10 the only limiting area. We are thinking like fifteen to 11 twenty years.
12 We just recently finished a Commission paper in 13 which we are proposing a course of action, and there are
() 14 many slides where I am going to discuss what this course of 15 action is. And the first item here is that we are preparing 16 a rule which essentially goes to the second option.
17 In other words, we are going to accept the 18 original licensing basis as amended and we are going to 19 define what additional work is necessary to essentially
- 20 manage the aging process. Bear in mind that the current 21 licensing basis will be whatever the licensing basis is at 22 the time of the submittal of the application.
23 MR. MICHELSON: So that essentially says that the 24 only thing that I am worried about is aging?
25 MR. KNIEL: Correct.
Heritage Reporting Corporation (202) 628-4888
.1
'96 v"^
l 'MR.'MICHELSON: The only thing:that_I am. worried 2 about'in terms of extending-further. operations?
l 3' MR. KNIEL: Right.
l 4- DR. REMICK:' .So those additional items would be' 5 done'on a case by; case basis based'on a PRA, is that what 6- you are saying?
7 MR. KNIEL: No, I do not think so. If you could 8 clarify that question.
9 DR.'REMICK: Well, I was looking back to your 10 alternatives.
11 MR. KNIEL: Okay.
12 DR. REMICK: It sounds like you have picked 13 Alternative B, is that right?
f-s' 14 MR. KNIEL: That is correct.
15 DR. REMICK: Okay.
16 MR. KNIEL: The question is how much did we.use 17 the PRA.in terms of the selection identification of' 18 structures, systems and components. The extent that we used 19 the PRA or we asked the licensee to use PRA to do that has 20 'not been determined.
'21 DR. REMICK: But it is on a plant by plant or a 22 case by case basis?
- 23. MR. KNIEL: Well, it may not be. It could vary 24 from being very specific in the rule about any and every l 25 system to allowing it to be totally case by case or O Heritage Reporting Corporation (202) 628-4888 i
i
____ _ - - -- 1
97
-)
V' 1 somewhere in between.
2 DR. REMICK: Okay. ,
3 DR. CATTON: You can get a pretty detailed PRA.
4 MR. KNIEL: Well, we are hoping to get a fairly 5 good PRA out of them in the IPE process.
6 DR. CATTON: Do they include things all the way 7 down to pipes that might wear out if another structure might 8 fail?
9 MR. MICHELSON: That is not in there, no.
10 DR. CATTON: That we have never seen.
11 MR. KNIEL: I think that the extent to which we do 12 that will depend on how we see the progress in the PRA 13 technologies going. And I do not think that we are going to
/'N
() 14 include things in the rule or we are going to be careful 15 about including things in the rule for which the current 16 technology is inadequate. So this is an area that we 17 finally considering.
18 DR. CATTON: There may be computer technology 19 capable of processing it.
20 MR. KNIEL: Well, I think that you might use a 21 combination of deterministic knowledge where you limit it 22 the PRA that has to be done to certain structures, systems 23 or components that you have already identified or for which 24 you have identified the aging to be significant.
25 DR. CATTON: I think that this is going to be an O '
Heritage Reporting Corporation (202) 628-4888
98
\ 1 exciting endeavor.
2 MR. KNIEL: Yes, I think that it will be 3 interesting also. i 1
4 MR. MICHELSON: I can see that the real problem is 5 not with methodology. I think that is well developed if 6 that is what you mean by technology. I think that the 7 problem is going be with the data that you put into the PRA.
8 When you start talking about data based on aging effects and 9 so forth.
10 DR. CATTON: That is right.
11 MR. MICHELSON: That is nonexistent in most cases.
12 DR. CATTON: Deciding what you ought to put in it.
13 MR. MICHELSON: That is just in its infancy yet as 14 far as I know. Maybe we will hear that it is well
([ )
15 developed.
16 MR. KNIEL: It is not well developed. It is in 17 its infancy. Personally I think that I am interested in it.
18 The reason that I am interested in it is because I thire in 19 the long run that it will help to decide some of these 20 issues which took us years in the initial licensing process 21 to decide. In other words, for years we did things on a 22 deterministic basis and then we found out that with the help 23 of PRA that the risk was elsewhere. I think that what we 24 want to do here is to try to address ourselves to where the 25 risk is and keep guided by that.
A
(- Heritage Reporting Corporation (202) 628-4888 l
99' q)'
. f-m .
1- The second bullet is where we are essentially 2 suggesting to the Commission with strong input from the 3 executive director that we prepare a single generic 4 environmental impact statement to cover the rule making 5 which would limit the number of issues subject to litigation 6 in' individual relicensing actions. So.that is the way that 7 we are proposing to proceed. Bear in mind that this is a 8 proposal to the Commission at the moment.
9 The severe accident issue we are going to handle.
10 on a case by case basis. At the moment we are not planning 11 on addressing the rule, but,the statement of considerations 12 will indicate that we would expect that most plants would 13 have gone through the severe accident implementation of the 14 policy statement in terms of doing their analysis and having 15 the plant accepted on that basis by the staff.
16 There may be a few exceptions, and that would be 17 the near term plants and maybe a very few early plants which 18 we would have to handle on a case by case basis. But 19 essentially the position that we are taking here is that we 20 would expect that most people who came in for renewal would 21 have that question of severe accident decided before they 22 requested a renewal license.
23 As part of this plan, we are preparing to conduct 24 a work shop very shortly this fall to essentially solicit 25 more public participation and industry participation in the O Heritage Reporting Corporation (202) 628-4888
-L 11 specific technical' issues, and also in the. scope'of the 2' generic environmental impact statement.
3 The next bullet is essentially a discussion of the 4 regulatory guides that are necessary to essentially flesh'
, 5 out the rule. The second bullet is essentially the' guides j t
6 that address what.is required in terms of the application, j 7 what kind of material. And the third bullet discusses l 8 guides which discuss other subjects, particularly areas that 9 have either come out of industry technical reports or out of 10 the NPAR program or out of other sources where we have 11 determined Ohat there are specific requirements for aging 12 that have to be addressed in the renewal period.
13 The next bullet is our review of industry
() 14 technical reports. And we will be adopting regulatory 15 positions as appropriate on reviewing these industry 16 technical reports. As I indicated, at the moment there are.
17 about ten reports that are planned subjects. The first one 18 is PWR containments, PWR pressure vessels, PWR internals, 19 electrical equipment and things like that. They are kind of 20 generic.
21 The last part of the program or the last part 22 indicated on the slide is that two lead plants will be 23 reviewed. You will see later that the schedule for the 24 final rule is April 1992. And the lead plants are coming in 25 in June of 1991 and December of 1991. And there has already l
O V Heritage Reporting Corporation (202) 628-4888
g db
.r-G 101 I% )- . .
1 1 been considerable interaction with the lead plants. So that 2' part of the strategy'here is to perform the review on the q
- 3 lead plants and to use that information as part of'the rule i
.4 . making process and the regulatory guide process.
5 MR. WYLIE: These reports are all generated by 6 EPRI?
- 7. MR. KNIEL: I think that a lot of them if not all 8 of them are being generated by EPRI, right. But they are 9 all being issued through NUMARC, and I think that there is L 10 quite a bit of a collegial effort at NUMARC to assure that 11 these reports are representative of the industry position.
12 DR. REMICK: Karl, I see that we have about ten 13 minutes yet. There are a number of slides, so you might
'14 speed up a little bit.
15 MR. KNIEL: Fine. These are the different aging 16 mechanisms which you are probably familiar with. This the 17 approach to the technical issues that we are talking at the 18 moment. We are trying to define these major aging 19 categories that we have been discussing here not in detail 20 but in terms of the background as to what is required for 21 the rule. And we are trying to identify the existing
-22 programs that address these aging issues on a periodic 23 basis.
24 In other words, we have got a lot of existing 25 programs which already address aging and they do it on a O Heritage Reporting Corporation (202) 628-4888
102
~
1- periodic basis. They require either annual inspections, or 2 ten year inspections or whatever. And we are comparing the 3 existing programs.with the aging concerns for the twenty 4 year renewal period of whatever the renewal period would be.
5 Juud then we will identify additional areas not covered by 6 existing programs.
7 So the significance of this slide is that we were 8- attempting to write the rule about things that are not 9 already addressed in the current programs. In other words 10 where current programs are adequate or deemed adequate to
~
11 cover the renewal period, we probably will not try to 12 address them in the rule.
13 So the actual considerations of aging will involve
() 14 both the rule and other existing programs. Now a 15 potentially interesting example of that is the diesel 16 generator. We are presently finishing up the regulatory 17 guide and we will be discussing it with the committee in 18 October on diesel generator reliability, design, 19 et cetera, et cetera with emphasis on reliability.
20 And this guide was started initially to address 21 the reliability requirements of the station blackout rule.
22 But it now appears as though the guide essentially addresses 23 what is required for reliability in diesel generators and 24 therefore it would appear to cover essentially what aging 25 requirements that we need to put in to license for guidance.
O Heritage Reporting Corporation (202) 628-4888
?
103 r~)1
-1 And you might want to consider it from that point of view.
2 It is a good example of-where either the programs we have.in 3 place now or are working on will address the question of
'4 aging for a renewal period in an adequate way.
5 Here are some of the other applicable programs 6 that we have identified'so far. And I noted the station 7 blackout rule already. But essentially all of these 8 programs involve a periodic process of evaluating the status 9 of structures, systems or components.
10 The major documents that we expect to produce in 11 the rule making would be the rule, the statement of 12 considerations that go with the rule, the regulatory 13 analysis,.the regulatory guides, the standard review plan
. ,q '
-(d 14 changes, the generic environmental impact statement, the 15 regulatory positions on industry technical reports, and 16 regulatory positions on topics regarding the lead plants.
17 Again we see the lead plants as a major input to the 18 preparation of the rule making and the guides.
19 MR. CARROLL: What does the standard review plan 20 item mean?
l 21 MR. KNIEL: Well, at the moment there has not been 22 much emphasis on that, but there might be some requirements 1
23 in changing the standard review plan to accommodate the rule 24 or to implement the rule.
25 MR. CARROLL: You are not talking about a new A
V Heritage Reporting Corporation (202) 628-4888
104
,9 1 standard review form for looking at license renewal?
2 MR. KNIEL: It is not clear what we are talking 3 about at the moment. We are not that far along on it. But 4 it is sort of an after the fact documentation. In other 5 words, if we are going to do it we are going to do it first 6 in the rule making effort and then we will specify it. The 7 review plan will be an after the fact kind of thing.
8 And my last slide here is essentially a summary of 9 the most important dates that I think would be of interest 10 to the committee. We are proposing at the moment to come 11 with a package to you in March of 1990.
12 MR. MICHELSON: What is going to be in that 13 package roughly?
() 14 MR. KNIEL: Well, that package will include 15 essentially the proposed rule, the statement of 16 considerations, and the regulatory analysis.
17 Another important date here are the draft reg 18 guides, SRPs, and the draft generic environmental impact 19 statement that we expect to publish in 12/90, December of 20 1990. I imagine that a number of those guides would be 21 coming to the committee for their review before they are 22 published for comment end correction. I imagine that all of 23 them will be. And we are talking about at the moment a 24 final rule published in April of 1992.
l 25 DR. REMICK: Is that not a short time between the l (~
- Heritage Reporting Corporation (202) 628-4888 L _ __ _- _
-m- ---
gs 105
\
'") 1 issuance of a draft environmental impact statement and the 2 final rule?
3 MR. KNIEL: Well, we are talking about over a 4 year.
5 DR. REMICK: Oh, I am sorry, okay.
6 MR. MICHELSON: When does the first license 7 renewal come up?
8 MR. KNIEL: Well, the first renewals will be the 9 lead plants. And I think that Yankee Rowe is still talking 10 June 1990.
11 MR. MICHELSON: They are going to come in ahead of 12 the rule?
13 MR. KNIEL: That is right.
,r\
(,/ 14 MR. MICHELSON: How do you treat them then when 15 they come in?
16 MR. KNIEL: They will not come in ahead of the 17 proposed rule. They will come in ahead of the final rule.
18 MR. MICHELSON: Yes. You will treat them on the 19 basis of the proposed rule.
20 MR. KNIEL: We will treat them on the basis of the 1 21 proposed rule.
22 MR. MICHELSON: And adjust later if it be 23 necessary.
24 MR. KNIEL: Yes. We are trying to get the benefit 25 of doing the lead plants into the rule making process.
') Heritage Reporting Corporation (202) 628-4888
106-
~ l' MR. MICHELSON: They are going'to be the guinea 2 . pigs.
3 . MR . KNIEL: Right. And they know it. I am sure 4- that in terms of their certainty for schedule that they 5 would like to have a final rule out before they came in, and 6 they may feel that way strongly enough'to say so in public 7 several times. At the moment they are already involved in 8 briefing the staff on their approach. There have several_ ,
9 trips to Yankee. There is a trip today to Monticello. So 10 in addition to the actual application there is going to be a 11 lot of preapplication work with the utilities on these lead-12 plants.
13 MR. WYLIE: When is there license up?
.14 MR. KNIEL: Monticello, I think that they are way l
15 ahead of schedule. It is like 2010 or something like that. ;
16 They are way ahead of. schedule.
17 MR. WYLIE: What about Yankee Rowe?
18 MR. KNIEL: Yankee, their license is up like the 19 year 2000. So they are slightly behind in terms of the ten 20 to twelve years.
l 21 DR. REMICK: Is that it, Karl, as far as your 22 presentation?
23 MR. KNIEL: That is it.
24 DR. REMICK: Are there other questions or 25 comments?
Heritage Reporting Corporation l
l (202) 628-4888 i
l
<-s 107 i I v
1 MR. CARROLL: Only that he completed with two 2 minutes to spare despite your pessimism.
3 DR. REMICK: That was because of my encouragement.
4 We thank you very much, Karl. That was .?. good 5 summary of the situation.
6 Our next topic is individual plant examination for 7 external events. There was a subcommittee meeting yesterday 8 I know. And Chet Siess is going to give us the subcommittee 9 report.
10 DR. SIESS: Thank you. There is nothing in Tab 4 11 worth looking at. But I do have a handout to pass out to 12 you. The change from the original agenda is simply that 13 after spending seven hours with the staff yesterday that we
,O
(_) 14 decided that spending even an hour and a hair today probably 15 would not be fruitful either for improving our understanding 16 or improving the staff's. They are still working on this 17 and they are working hard, and we will wait until they have 18 gotten a little further along.
19 DR. REMICK: They cannot hear you around the table 20 for some reason.
21 DR. SIESS: Some of them are not around the table 22 and I really do not care about them.
23 DR. REMICK: I hope that the court reporter is 24 getting all of it. She is.
25 DR. SIESS: Let me remind you that this handout
((
Heritage Reporting Corporation (202) 628-4880 l
108
\- 1 that I just gave you is something that I am sure that you 2 are all familiar with, but I had not looked at it in quite 3 awhile. And I thought that it was an interesting way to 4 spend part of our time today, to look back and see just why 5 we are doing the IPE and why we are doing the IPEEE which is 6 the external part of the IPE.
7 What I have given you is the last two pages of the 8 policy statement on severe accidents. The first sixteen 9 pages deal with how the Commission is going to handle severe 10 accidents in future plants. These two pages address 11 operating reactors. You will note that it says that they do 12 not require any further action unless some new safety 13 information comes out. That is sert of parallel to the
() 14 statement on the future reactors that we think that they 15 would be safe enough if they do all of the right things.
16 And it goes on to say that there is new safety 77 information. That first you should decide whether it is 18 plant or site specific or generic. And note also in that 19 second bullet that the words severe accident vulnerability 20 appears.
21 Now this can either be a plant or site specific 22 vulnerability or generic vulnerability. In whichever case, 23 there is supposed to be a cost effective option for reducing 24 the vulnerability consistent with the backfit policy. And 25 it is no longer a vulnerability but it is now a technical
[ \
\/ Heritage Reporting Corporation (202) 628-4888
~.
109
~1 issue. If it goes beyond existing regulatory requirements, 2 generic rule making will be preferred. Now that seems 3 reasonably logical in a series'of events if you understand 4 what is meant by vulnerability, and if you do let me know.
5- There is also an interesting point at the bottom 6 of that first page going over to the top one on the generic 7 rule making. It says that in other cases, that is where it 8 does not go beyond existing regulatory requirements, that' 9 the issue should be disposed of through the conventional 10 practice of issuing bulletins and orders or generic letters 11 where modifications are justified through backfit policy or
'2 . through plant specific decision making along the lines of 13 the integrated safety assessment program conception.
14 ISAP is actually enshrined in the policy statement on severe (f
15 accidents, and I expect to remind people of that form time 16 to time.
17 The bullet at the top of page 819 is the one that 18 leads us to the so-called independent plant examination and 19 let me just read this. " Recognizing that plant specific 20 PRAs," and I do not think that there have been any other 21 kind of PRAs that were worth anything, " plant specific PRAs 22 have yielded valuable insights to unique plant 23 vulnerabilities to severe accidents leading to low cost 24 modifications." Not the number of qualifications on that, 25 unique and low cost modifications.
Heritage Reporting Corporation (202) 628-4888
r k 110 j
('
l' " Licensees of each operating reactor will be 2 expected to perform a limited scope accident safety analysis ,
3 designed to discover instances, that is outliers of 4 particular vulnerability to core melt or to unusually poor 5 containment performance given core melt accidents."
6 Now that presumably is the basis for the 7 individual plant examinations. Then it goes on to say that 8 these plant specific studies will verify the conclusions-9 developed from intensive severe accident safety analyses 10 that reference surrogate plants, which I think means 1150,.
11 and can be applied to each of the individual operating 12 plants. And then during the next two years the Commission 13 is going to tell you how to do this. .
14 Now the IPE that one segment of the staff has been
.15 vorking on has limited itself to internal events, and I aun 16 not quite sure how they defined internal events to us.
17 These were failures of the plant systems or components 18 initiated by failures of systems in the plant. Is that not 19 right, Carl?
20 MR. MICHELSON: That is about it.
21 DR. SIESS: Now I have left a series of external 22 events which include seismic, flooding.
23 MR. CARROLL: External flooding.
24 DR. SIESS: Flooding of which there is external 25 flooding from rivers, lakes, or local precipitation, and Heritage Reporting Corporation (202) 628-4888
. . 111 j
/'~j
' \~d l' internal flooding from a tank or a pipe that' fails. And 2' internal flooding got folded into the internal events part 3 of the IPE at our urging I believe, I am not sure. But that 4 is as far as we got on that one.
5 Now external flooding, river, lake, hurricane, dam 6 failure or what have you including local VHP is considered 7 an external event. Seismic is external. High wind, a
- 8. hurricane, or tornado is external, et, cetera.
9 DR. REMICK: And there is another category of gas 10 pipe lines and tho3e type things.
11 DR. SIESS: Everything, yes. I will give you a 12' little more on'that. Now the staff attacked the external 13- from a subcommitfiee type of organization. They really put a
) 14 lot of people to work on this and got some help from the 15' national labs. They set up an external event steering 16 committee, and Larry Shaw was chairman of that and still is 17 I guess even though he has changed jobs. j 18 And under this external events steering tommittee, 19 they set up three subcommittees. One is seismic. They have 20 got seismologists and structural engineers, and at least one 21 systems man, and I think one PRA man on it. They have got a 22 subcommittee on fire, and we heard from them last month.
23 Carl's subcommittee met or somebody's and they were talking 24 to us.
25 And then they have a subcommittee that I call a O Heritage Reporting Corporation (202) 628-4888
I gm,, 112
%). ^
1 subcommittee on everything else. They call it the 2- subcommittee on high wind, flood and others. High wind if 3 fairly straightforward, hurricane and tornado. Flood is the 4 external flood from any. source, lake, river site, ocean 5 site, and surge. And others are volcanoes, aircraft crash, 6 transportation accidents, industrial accidents, pipelines.
7 I am not quite sure that the barge coming down the river at 8 Hope Creek, I think that is part of flood, but whatever 9 floats down the river.
10 DR. REMICK: In other words, transportation.
11 DR. SIESS: It is transportation I guess.
12 Now the staff is setting this up, and they are 13 looking for vulnerabilities. They are being consistent with
) 14 the internal events people'ir the sense that they have 15 refused to define vulnerability. The internal events people 16 in NUREG 1335 which is the guidance for the IPE has said a 17 list of any vulnerabilities identified by the review 18 process, a precise discussion of the criteria used by the 19 utility to define vulnerabilities, and the fundamental 20 causes of each vulnerability. This is a list of things to 21 be reported.
22 So a vulnerability now whether it is internal or 23 external looks like it is going to be what the utility 24 thinks it is. Of course, the staff is going to have a 25 chance to look at it.
Heritage Reporting Corporation (202) 628-4888 q
113 V
1 Now if there is a vulnerability, what are you 2 going to do about it. Again that is up to the utility. If 3 he wants to do something about it, fine, he tells the staff 4 what he wants to do. If he does not want to do anything 5 about it, the staff will have to decide whether they want to 6 make him. If it is_important enough and they can prove the 7 cost benefit, they can backfit it.
8 But it is just like the SEP was. It is either 9 voluntary or the staff -- well, if it is a vulnerability 10 because it does not meet the requirements, that is obviously 11 an enforcement action.
12 The staff has worked on and are fairly well along 13 on their approach for seismic. There are going to be two
- v
(_) 1-4 approaches and two alternatives available. A full seismic 15 PRA is acceptable. They think that that will determine 16 vulnerabilities. And incidentally, a major feature of a ,
17 seismic PRA is a walkdown.
18 The other alternative will be some form of the 19 seismic margin review, like was done for Maine Yankee. They 20 are still trying to decide what the review earthquake is.
21 That also requires a walkdown. And they said from their 22 experience on the seismic margin reviews that practically 23 all of the vulnerabilities that they found large and small 24 had been found in the walkdown, not by the analysis that 25 came later. And one option for a plant in a low seismic Heritage Reporting Corporation (202) 628-4888
fs 114 b 1 hazard area might be simply what they call a quality 2 walkdown, a good thorough walkdown without any calculations.
3 Now there are still things that they have to 4 decide on this seismic, but they are essentially down to the 5 point of trying to reach some agreement. EPRI has a seismic 6 margin procedure, and the staff has a seismic margin 7 procedure. They are different. There are some fundamental 8 differences in what they will find and what they will not 9 find.
10 And the staff is working very hard with CPRI 11 trying to get some agreement, not necessarily a common 12 method because each one ?las some advantages and they may 13 wind up accepting either one. So they are coming along
( 14 pretty good on the seismic, but they have not got it down to 15 a stage where it is worth looking at the details of it.
16 On fire they have got no further than they were 17 the last time that we did not even want to talk to them.
18 Tommy McCracken said that he would repeat the old story.
19 On high wind, flood and others, they are going 20 through a screening process within the staff. They had some 21 of this done at one of the national labs, where was it Los 22 Alamos, or I mean Lawrence Livermore. And for example what 23 they find is and some of this is based on the SEP experience j l
24 -- Livermore went back and looked at the SEP, they have ]
I 25 looked at the PRAs, and they have looked at all of these i
O Heritage Reporting Corporation (202) 628-4888 l
1
-___--__--____-___________--O
U :
l 115- 1
. r'"; I e .1- things.-- for example taking flood, external flood,'if the I
[- 2' plant has been licensed in the last several years under the
- c. ,
3 current standard review plan flood criteria, they'do not 1 l
4 think that there is any vulnerability there. ]
5 The probable maximum flood if it is exceeded is 6 such a low probability that they cannot call that an outlier 7 or a vulnerability. . If a plant was licensed before those 8 standards camelup, then they would want them to look at it
? for special vulnerabilities to external floods which is 10 exactly what the SEP plants did, and some of them were found 11- to be fairly vulnerable and things had to be done, some of 12 them were procedural.
13 The same thing is true on wind. If they were
() 14 licensed to our current tornado criteria, they do not think 15 that there is any problem. If they were not, yes, they 16 should look to see if they have any particular 17 vulnerabilities, things that could fall down, or tornado 18 missiles could cause damage and lead to a special 19 vulnerability in terms of core melt.
20 They have gone through a whole series of these 21 things. When they get to aircraft crash or transportation 22 accidents, they are looking at a frequency of the initiator.
23 If it is 10 to the minus 6, forget about it. They are 24 taking 10 to the minus 5 if they think that there is a 25 90 percent chance of surviving it. This is a judgment call.
Heritage Reporting Corporation (202) 628-4888
116 l
tr s) 1 But they tried to give the utilities some I guess 2 you would say preapproved screening criteria on what the 3 ste.ff thinks is a pretty conservative level. And if the 4 utilities screen on that basis, they are not going to get 5 any argument. If they want to come in and argue on a 6 different basis, then I think that they are entitled to do 7 it.
8 So this is the direction that they are going.
9 There is going to be a fairly good emphasis I think on 10 walkdowns both for the seismic and some of these other 11 things. We suggested to them that a walkdown of the outside 12 of the plant when you are looking for flood and so forth.
13 Oh, one other thing under other, lightening. And
() 14 Charlie was not every happy with what he heard. They had 15 somebody from Livermore that looked at LERs for lightening 16 and decided that it did not do anything except cause losses 17 of off-site power. And Charlie has got a collection of LERs 18 on lightening that do not agree with that data base. So 19 they got fussed out a little bit about that, and I think 20 that they will go back and take another look at it.
21 We suggested that external flooding ought to be 22 sort of integrated with their internal flooding. That once 23 the water got over the sill at the door that maybe they 24 ought to look at it there too. And we made a few plugs to 25 integration, although this group is pretty well integrated Heritage Reporting Corporation (202) 628-4888
r 117 M). 1 but not every much with the internal.
2' DR. REMICK: All fires internal or external are 1 3 considered external, is that right?
I
.4 DR. SIESS: All fires are considered external 5 unless there is one in a coffee pot or something.
6 MR. MICHELSON: The internal fires are in a 7 category by themselves. The external fires outside the 8 plant.
9 DR. SIESS: But internal fires are considered 10 external events, that is what be asked. l 11 MR. MICHELSON: Ycs.
12 DR. SIESS: I think that Carl asked about brush 13 fires and forest fires outside, and those are plant specific
( 14 things and they have got them on the list and they expect 15 them to be looked at.
16 MR. MICHELSON: They were treated as others.
17 DR. SIESS: They are under others.
18 MR. MICHELSON: Where a regular fire is not under 19 others.
20 DR SIESS: No, no. There is a fire subcommittee 21 and there is a wind, flood and other. An outside brush fire 22 or forest fires are others. And those are very site 23 specific and I do not think that they are going to try to 24 get too fancy with those. They are things that people ought e 25 to look at. It will just probably be a list of saying have O Heritage Reporting Corporation (202) 628-4888
/
3
1
+ !
1 g 118 j
(_) 1 you looked at these things.
l 2 An aircraft crash, they will not go beyond current 1
3 criteria which geographically related to the location of the J 4 airport. And they assumed that anything outside of that is i
5 in background and background is not a special vulnerability i l
6 or not at some probability level. i 7 Now a lot of this is not probabilistic but is 8 deterministic. The flood is not a probabilistic thing.
9 Actually the seismic margin thing does not have to be 10 probabilistic. You can arrive at those HCLPF values 11 deterministically. Licensing is deterministic, and 12 basically . ey are keeping it on that level as much as 13 possible. And some of these things I am not sure that you
() 14 would get them out of a PRA very well.
15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
,_ 119
/ \
s
' / 1 (Continued from previous page) 2 I am not sure you can do a wind PRA and a flood 3 PRA and fire PRA.
4 Now, they expect to have something by later this 5 year to let the subcommittee look at. And I thought I would l
6 have one or two subcommittee meetings until we understood 7 the thing well enough to come into the full committee with 8 sorse pretty clear recommendations and then let the full 9 committee have a chance at the staff to understand our 10 recommendations.
11 There are just too many different things involved 12 in this.
13 But it looks like they will be out pretty close to It )\ 14 the time people get started. One of our concerns, if you 15 will recall back a ways, was walkdowns in connection with 16 internal and then start all over on external.
17 And end of report.
18 DR. REMICK: Okay. Questions, comments?
19 (No response) 20 DR. REMICK: That's a good summary, Chet.
21 If there are none, I suggest we take an early 22 midafternoon break for the next ten minutes, returning at 23 3:00, where we will talk about accident severity scale, with 24 Mr. Carroll.
25 (Whereupon, a brief recess was taken.)
k#' Heritage Reporting Corporation (202) 628-4888
' I<- 120
~1' DR. REMICK: The next agenda item is the 2 discussion of accident severity scales. And Jay Carroll is 3 going to lead us in this discussion along with the staff.
4 MR. CARROLL: Okay. This is in Tab 6 of the black l
5 binder. ;
6 You probably received a SECY that was prepared to 7 inform the Commission of a proposed NRC position regarding 8 the international development of an event. severity scale for 9 commercial power reactors.
10 Jack, I guess you are going to brief us on this 11 scale and the French and Japanese scales that are enclosures 12 to the SECY which is in the tab.
13 I guess I would comment that the very last thing 14 in the tab is a classification of U.S. evente 83 through 88.
15 I found very interesting the number of 30-day arritten 16 reports under 50.73, unusual events, alerts, that are 17 tabularized in there.
18 So, I'll let you take off.
19 (Slides shown) 20 MR. HELTEMES: Good afternoon. I am Jack 21 Heltemes. I am the Deputy Director of AEOD. The Director 22 of AEOD, Ed Jordan, wanted to be with you today and give 23 this presentation, but unfortunately, he is overseas. He is 24 as IAEA today and won't return until next week.
25 This information comes to you in support of the i
Beritage Reporting Corporation (202) 628-4888
b:
7- 121 t., ^
1 SECY papers, Mr. Carroll said.
2 What we want to do is tell you what the staff has 3 been doing with event severity scales and some proposed 4 staff positions or conclusions for your information, and any.
I-5 comment you may-wish to offer.
6 What I would like to do is walk through some of 7 the information coming out of the international community, 8 and most of it is contained in the SECY paper, and I will 9 wind up with the positions that we intend to express or to q 10 present at future international meetings if our Commission 11 accepts them and if we don't receive any strong comment from 12 the ACRS.
13 So with that, I would like to just walk through my 14 charts. I've passed out copies of them.
15 Basically the background is a number of countries 1
16 have problems with their public in the sense the public 17 believes or has concerns they are not getting sufficient 18 information on operational events.
19 So these countries have a desire, have an 20 incentive to improve public communication. And one way to 21 do that is by use of event severity scale, in order to 22 better communicate with the public, and try to make sure 23 that the media have an understanding as to the implications 24 and potential significance of operational events.
25 The severity scales are very much like a Richter Heritage Reporting Corporation (202) 628-4888
(.. s 122 The thought was to educate the public on these l' scale. j I
.2 scales so that.when they are told it is a certain level on 3 the scale, they will.have an understanding of it's j 1
4 significance. They will be conditioned, if you will, to ]
5 have.a feel for the operational event in terms of its 6 implications and. significance.
7 The severity scales that have been adopted in the B countries I will speak about, and there are really two 9 primarily, that is, France and Japan, have adopted.these 10- scales only for public information-purposes.. And they are 11 an adjunct or an extension of ongoing activities. They are 12 ' separate from their normal activities of event reporting and s
13 assessment.
() 16 In terms'of the status and use of severity scales, 15 the~ French were the'first to adopt a scale and they adopted.
16- .a six-level scale in April of 1988.
17- That has now been followed by Japan, who has 18 adopted a nine-level acale and'they did so formally in June 19 of 1989.
20 Now, both France and Japan have announced that 4
21 these scales are being used in a trial use period. I think 22 in both cases it is a one year or two-year trial use.
23 The nine-level scale in use in Japan, and I will 24 show it in a few minutes, but basically it goes down further 25 into the less significant events in order to get more of the Beritage Reporting Corporation (202) 628-4888
_ _ _ - _ - _ _ = - _ _ _ _ _ -
123-14 1 ' Japanese events on scale.
- 2. The U.K. and Germany are serious aboutLadopting a 3 scale.- They have been participating'in the international 4- discussions, and basically they feel that a scale'would.
5 offer advantages to them and they are watching'the.
6 experience'being gained in France and Japan. But they are 7 very much inclined to adopt a scale. And they both believe 8 that the six-level scale being used in France would provide 9 a suitable basis for a scale in their countries.
10 In the United States, we believe that we have a e
11 severity scale in.effect right now. We use it for emergency 12 response. It is our four-level scale, starting with the
- L3 - unusual events, the alert, site area emergency, and general "h14 emergency. 'And.I will talk more about that.
15 But I would point out that our scale for emergency 16 classifications of events has been in effect for almost ten 17 years. It is well entrenched in terms of procedures and in 18 terms of training for utilities,-for state, local and l
19 Federal agencies. We've used it during actual emergencies.
20 We've used it during many exercises. And so it is very 21 familiar-to the nuclear community and also our media 22 understand it and seem to be able to work with it.
23 MR. WYLIE: Do any of the other countries use 24 theirs for emergencies?
25 MR. HELTEMES: Not the ones I'll be talking about O Heritage Reporting Corporation (202) 628-4888
f 124'
- 1 today. It is' separate from their' normal emergency response.
2 In France'and Japan, it is for public information purposes.
3 The two: international. agencies, NEA, Nuclear 4 ~ Energy Agency, and the IAEA, have sponsored a number of 5 meetings.and have some committees working on this. general-
-6: subject, to look into the needs and the uses for such a 7 system. . .
8 Quite frankly, I think the purpose is to see if 9 they can come out with a recommended scale that could be:
10 ' adopted by various countries.
11 Whenever you get together and start talking about 12 a severity scale,-you start. talking about the 13 characteristics of an idesi 'acale.
14 And_this chart attempts.to put'down some of these.
15 First of all, it should be simple. The public has 16 to understand it. It has.to be something that comes to mind 17 and is intelligible to the man on the street.
18 DR. REMICK: Jack, along that line, do people
' 19. think that the Richter scale is something that is understood 20 by the public? I guess I can't help but question.whether 21 the public really understands the Richter scale, which has 22 been around a long time.
23 MR. HELTEMES: It's a good point. I think the 24 public has an understanding that a 7-level earthquake is
- 25 much more severe than a 5-level. And they never hear about O Heritage Reporting Corporation (202) 628-4888
g 125
) \
1 la and 2s. And so they develop a feel that if it is more ]
2 than 5, buildings start to shake at 5, and damage really 3 gets serious at 7 or so. But the idea was that the public 4 does have a general awareness of that scale and does have a i l
5 general appreciation for the magnitude of an earthquake, in 1'
6 terms of concept.
7 DR. REMICK: I can understand that might be true 8 in California.
9 MR. HELTEMES: You always see it reported in 10 newspapers, for example, so it is a communication link with 11 the media to the public.
12 I think it is in that context that the parallel is 13 drawn.
/~T
(-) 14 It should be applicable to incidents or accidents.
15 The idea of course is to have anything that, any event that 16 can occur at a reactor, and quite frankly we are talking 17 primarily about reactors here, be somewhere on the scale, so 18 you shouldn't have the type of event that can happen that 19 bypasses the scale.
20 And also, the scales hopefully will be used for 21 other types of facilities such as reprocessing plants, 22 should we have any, but other countries may, and fuel 23 facilities, that if you can develop such a scale, it would 24 be used widespread, if you will, for all facilities that 25 could impact public health and safety.
,s, G Heritage Reporting Corporation (202) 628-4888
i 126 j pl i
i i
It should allow prompt classifications within 1 )
i 2 hours. And the idea here is that the utility or the 3 operator would do the first classification and then the 4 regulatory authority normally comes in and reviews that.
5 But the prompt classification should be done with minimum 6 reclassification based on later information, and there 7 should be reasonable consistency between the regulatory 1
8 authorities and the utility.
9 And that gets into the next point about 10 consistency. The scale has to be sufficiently definitive or l 11 specific if you will to allow various utilities to implement 12 in a mors or less uniform fashion.
13 And since judgment is involved, you will always be
() 14 faced with problems of consistency. And I think that is one 15 of the reasons the trial uses are going on, to assure that 16 both in Japan and in France, that they are getting 17 reasonable consistencies out of the plant cperators.
18 It should give widespread resolution between the 19 events, and it should clearly define the events which have 20 no real impact on public health and safety, versus those 21 that do have an impact. And they are widely separated in 22 that sense.
23 It should correlate with risk in terms of a 24 technical basis. Otherwise, it will probably be perceived 25 by the public as just a public relations tool.
p)
\. Heritage Reporting Corporation (202) 628-4888
J
./~g. 127 1 And, in our view at least, and generally-j 2 recognized, it should be consistent with emergency planning. j 3 You don't want to start switching scales in midstream. You 4 don't want to confuse the media.
5 Also, you need a number of events onscale in order !
6 for the scale to be used, and so the public becomes familiar
! 7 with it and has confidence in the scale in the sense that 8 they have a spectrum of events occupying at least the lower 9 several ranges on the scale.
t 10 And it should be properly calibrated in terms of 11 past events. And the two calibrations that people normally 12 use are Chernobyl and Three-Mile Island. Although, as we 13 will see in a few minutes, the French have gone back into
( 14 their operating history and pulled forward some of the past 15 operating events, and put them where they believed they 16 would have prcperly been classified today on their proposed 17 scale.
18 Now, when you look at.the elements, or criteria 19 involved with severity scales, there are a number of them 20- that come to the front. And that is what this chart has on ,
21 it, are some of the considerations or elements normally j 22 involved in the construction of scales.
I 23 But quite frankly, there is no one element that
]
1 24 dominates the scale. It is a composite or multi-element, is 25 the normal way they are constructed, as we see, that if you l
f~
Heritage Reporting Corporation (202) 628-4888 j l
l 1
128 e
- - 1 take something like the amount of radioactive material 2 released, that doesn't really oftentimes correlate with
-3 public impact.
- 4. You really have to know what is being released in 5 terms of isotopic content, how it is being released, and the 6 extent over time, the release rate.
7 Or, you can get into the offsite impact. And that 8 is normally dose. But once you get into that, you need a 9 defined methodology.
10- Are you talking about the dose to an actual human 11 being, to the person at the site boundary, which would oe 12 the maximum hypothetical dose?
13 Are you talking about the collective dose to the
() 14 total population? If so, over what period of time? Can you 15 take into effect any emergency response, evacuations, and so 16 forth?
17 And so once you get into that impact, you have to 18 get more specific in order to get consistency.
19 onsite impacts of course lead.to significance.
20 And here, most of the scales have some onsite radiological 21 impact, either contamination or exposure to plant personnel.
22 But the public can get confused if there are no 23 offsite impacts. And that gets back to the purposes of 24 these scales is really to kind of calibrate to the public 25 the significance of an operating event, but that Heritage Reporting Corporation (202) 628-4888
p-l
)
u'
- 1. media than'the ones I deal with in Champaign, Illinois. I i 12 will have to ask Joe Fouchard if he has been back there
-3 recently.
4 MR. HELTEMES: That brings up the next point here, 5' 'that we don't believe's parallel scale is needed for public 6 information purposes.
7 Joe Fouchard has said to me personally that it has 8 been years since we and the agency have received a complaint 9 that the public is being denied information on operating 10 events.
11 Essentially all the information that we have on 12 operational events, operational experience, is made public, 13 'and we have'several different calibration systems as you 14 well know. The performance indicator significant events, we 15 have Aos that we put out. All that goes in the PDR. And 16 based on our public affairs people, they indicate that we do 17 seem to have the credibility with the public in terms of 18 putting out accurate information.
19 We don't think that we have a problem with public 20 information.
21 DR. REMICK: Jack, and I don't disagree with what 22 you are saying, but don't you think it is inevitable though 23 that if there is something reported in a country like Japan 24 or France where a severity scale is given, don't you think 25 it is going to be inevitable that the press is going to call O# Heritage Reporting Corporation (202) 628-4888
138 l
i (;. "
,'C^ 1 the NRC and say what level would this be on our scale or 2 vice versa? I can see that that would be one advantage of a 3 common scale that you wouldn't have that type of problem 4 across country.
5 I'm not saying it is adequate, but it just seems 6 inevitable that maybe the media will learn the foreign 7 severity scales. But I rather doubt it.
8 MR. HELTEMES: We agree with you, Dr. Remick. And 9 that's why we have been giving some thoughts to this pre-10 established correlation. We feel that if chere is an 11 international scale, or scales in various countries, that we 12 will have to correlate our own experience with theirs. And 13 we would do it with the pre-established correlations.
(~w) q 14 The other point I would make is that if we really 15 wanted to adopt a scale and really wanted our utilities to 16 use it and to participate in it, then we probably have to do 17 it by rulemaking in order that it be mandatory and not 18 voluntary.
19 So, with all that as background, what we have done 20 is develop a proposed U.S. position that is in the paper to 21 the Commission. l 22 Basically it has these points that we support the 23 use of such scales in those countries that don't have good 24 public communications systems because we think they can add 25 to public understanding, public perception as to what is q
l Heritage Reporting Corporation (202) 628-4888
b+ ,
1
!. r- 139
(. occurring,'and we think too that in France and Germany-and 11 4 1
- 2 other places that there is a new awareness of assuring that 3 the public is well informed. j
.l 4' We also maintain that we think that the public
-5 information scales and the emergency response scales should 6 be very consistent with one another so that you are not in 7 effect having or trying to implement two different scales.
8 We believe that we have an established scale for 9 emergency response, our four-level scale, that is working 10 reasonably well. It is well established in the sense of 11 procedures and training. It is about ten years old now. So 12 that we don't think we need to depart from that or try to 13 come up with a new scale.
L ) 14 We also think that we have very open and very 15 prompt public communication in the sense of press releases, 16 et cetera.
17 And thus our bottom line is t sat in the United 18 States, we are unlikely to adopt another syatem for public 19 information purposes only.
20 And that's all I have to cover.
21 DR. REMICK: Thank you, Jack.
22 Questions, comments? Chet?
23 ,
DR. SIESS: I have a great deal of problems with 24 the five-level scale where the fifth level scale, the top 25 number five is essentially a real problem, but there are O Heritage Reporting Corporation (202) 628-4888
l l,
3 140
.)
1 hundreds of number twos. And I know an awful lot of people 2 that will think a 2 is 40 percent as bad as a 5. And 3 somebody on my right said oh, yes, but the Richter scale.
4 But you already pointed out that they don't hear about 2 and l 5 3 Richters. And they don't understand a logarithmic scale 6 which is what the Richter scale.
7 I know my wife doesn't. And she's fairly 8 representative of the public. She tells me that. She says 9 try it on me.
10 DR. REMICK: So the staff recommendation to the
- 1. i Commise4on is not to adopt a scale other than what we have, 12 is thsc it?
13 MR. HELTEMES: That is correct.
14 DR. REMICK: Other questions or comments?
15 MR. CARROLL: I guess the only comment I would 16 make is after living with our present scale all these years, 17 I think we could have had sene better descriptions.
18 MR. HELTEMES: If we were to start over, it would 19 be different today. We probably would have a scale very 20 similar to some of the others, if we were to start over. So 21 the comment is well taken.
22 CR. REMICK: All right, gentlemen.
23 MR. HELTEMES: Thank you very much.
24 DR. REMICK: Thank you, Jack.
25 We are again ahead of schedule. I assume our Heritage Reporting Corporation '
(202) 628-4888 I
L -- - - - _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _________ _-_ 9
h 141
- 1 NUMARC folks will not be here for another 45 minutes.
2 If he is not available now, one thing I can do, 3 although I am not prepared, is to give you the subcommittee 4 report on the Regional Program Subcommittee meeting in 5 Region'1. But I do have a draft of Paul Boehnert's minutes 6 of that meeting. And using that as a guide, if you don't 7 object, I can walk.through that. That is something we can 8 do if he is not available. It's scheduled for Saturday.
9 DR. SHEMMON: I was one of the few that did not 10 attend.
11-12 13
( . 14 15 16 17 18 19 20 21 22 23 24 25 O Heritage Reporting Corporation (202) 628-4888 l
142
- ('"'
1 DR. REMICK: Let's' wait a few minutes.
2 Let's go off the record for a few minutes.
3 (Whereupon, a break was-taken.)'
'4- DR. RF. MICK: Gentlemen,-we will continue with the 5 last item on the agenda for today and that's an overview by p
6' NUMARC, Mr. Bill'Rasin, who is going to give us some 7 overviews on what is being done in the area of IPE and 8 accident management.
9 We greatly appreciate your accommodating your 10 schedule with our changing schedule for this meeting. We 11 appreciate you. coming up with short notice.
12 MR. RASIN: Thank you.
13 7 will warn you, though, there is one repercussion
() 14 of tl.:at.and you will find at least'one typo in the slides.
15 DR. REMICK: All right.
16 MR- RASIN: Of course, as you noti a that's your 17 fault.
18' DR. REMICK: We're used to typo in slides.
19 (Slides being shown.)
20 MR. RASIN: I appreciate the opportunity to speak 21 briefly to you on'this subject. We've had a number of 22 requests over the last four to six weeks to appear before 23 some of your subcommittees to discuss the various aspects of 24 our activities.
25 It was my judgment that we were not at a point Heritage Reporting Corporation (202) 628-4888 i
o- 143
-() 1 where that would be partientlarly productive in some areas, 2 and I was glad to hear Dr. Sless say to you today he didn't 3 think that the details were quite ready in external events; 4 that was my view.
5 It occurred to me that it would be valuable for us 6 to give you an overview of the industry activities in 7 preparation for these more detailed pieces that will come 8 along. And, in fact, I believe that since this has been 9 scheduled we have scheduled a detailed meeting on the 10 accident management program with one of your subcommittees 11 on September 20th. So this will indeed start the process.
12 I have not spoken to this group in this capacity 13 at NUMARC before. Let me just show you in our priority n
(_> 14 issues list the scope of the responsibilities of my 15 division. The ones with the stars are ander the purview of 16 the technical division. At least four of them have bearing 17 in the severe accident area and I will touch upon them 18 today.
19 Obviously, severe accident policy implementation, 20 that's IPE. Severe accident management program, which we 21 see as, in fact, a complimentary program to IPE. External 22 events which is taken in a severe accident sense. And then 23 portion of our seirmic issue is really an attempt to 24 integrate what's going on in the seismic area and the severe 25 accident area.
7~
(' Heritage Reporting Corporation (202) 628-4888
1 144
(-)3
~
1 Some of the other activities, I'm sure, we'll talk
)
2 about again after this afternoon's presentation. I'm 3 anxious to give our version of life extension license 4 renewalJand maybe we'll do that in the near future, if it ,
5 suits the committee.
6 With regard to the severe accident area --
7 MR. CARROLL: Bill, before you get too far into 8 this, I guess I would be curious to know who Bill Rasin'is.
! 9 What's your job at NUMARC and what's your background before 10 that.
11 MR. RASIN: Fine.
12 My job at NUMARC is Director of the Technical 13 Division, and in that capacity my division is responsible
) 14 for generally the technical issues: engineering; a:alysis; 15 hardware related issues are generally in my scope.
16 MR. CARROLL: And how big is that division?
17 MR. RASIN: That division right now is -- I don't 18 know, 12, 15 people total, something like that.
19 MR. CARROLL: That are full-time NUMARC employees.
20 E T. RASIN: Yes, full-time NUMARC employees.
21 MR. CARROLL: Augmented by a lot of industry 22 groups that get together on different issues.
23 MR. RASIN: You bet.
24 Yes, that's correct.
25 Prior to coming to NUMARC I spent over 10 years O Heritage Reporting Corporation (202) 628-4888
145 l' at,-probably the best utility in the country, that's Duke L 2 Power Company. And there I was in design engineering 3 department. I headed up the nuclear engineering portion of 4 design engineering for a.while.
5 And additionally, after TMI we formed some special 6 safety analysis groups to do some independent analysis and 7 rfstems interaction analysis as well as PRA studies. .And I 8 went off to form those groups and conduct those studies.
9 P,rior to that I spent some time at UBA and then 10 also some time in the Navy.
11 My educational background is a BS in. nuclear 12 engineering.
13 MR. CARROLL: So if you came from Duke, why don't O
'(-) 14 you talk like Charlie Wylie.
15' MR. RASIN: I'm not a native. Charlie had the 16 good fortune to be born down there, but I'had the good sense 17 to move down there. But I left, so it shows you what 18 happened to my sense.
19 MR. CARROLL: Okay.
20 MR. RASIN: In the severe accident area, as we 21 closed out the IDCOR program right after NUMARC was formed, 22 we formed severe accident working group and I'll talk to you 23 about the responsibilities and the membership of that group.
24 And we are concentrating on individual plant examinations, 25 trying to provide some industry leadership in that area. )
Heritage Reporting Corporation (202) 628-4888 ;
1
H s 146 S'
1
'Looking.at the external. events and trying to-determine what 2.- it makes sense to do'there. Looking at the containwnt~
3 performance improvement program; accident management; and 4 trying to.give now some spe & l. attention to the closure 5 process. I 6 In this regard we've been trying to work'in a very 7 cooperative manner with the NRC. It.is our position that.we 8 should proceed with the steps necessary to implement the 9 severe accident policy statement and we should proceed post-10 haste to get started on that.
- 11. To that end we've concentrated on getting the 12 process started. After it's rolling we will naturally turn 13 our attention: now,.how are we going to bring it to closure, 14 and stop it?
15 Let me turn to the severe accident working group.
16' Me: formed this group of industry-executives, and I'll show 17 you who they are, and prepared a mission state:aent for the 18 group that indicates our intentions in the severe accident 19 area. And the purpose of the group is to coordinate the 20 industry activities and serve as the focal point for 21 industry /NRC interactions leading to the closure of severe 22 accident issues.
23 As I stated before, number one, concentration at j 24 first was the IPEs. Let's get on with the generic letter 25 and get started. We told the NRC as an industry we promised O Beritage Reporting Corporation (202) 628-4888
i 147
.( [] 1 we would work on accident management and work with them on l
2 that. And then we would look at external events.
3 And these two issues: the accident management; and 4 external events were kind of hold-overs from the IDCOR 5 process where we felt the scope.of that process really was 6 not right to address those two issues.
7 And then, of course, other severe accident issues 8 such as containment performance source terms, we'll come to 9 grips with later.
10 The membership of that group is on the next couple 11 of slides. You'll see it's a pretty distinctive group, I 12 think, of the industry and chaired by Cordell Reed, whom I'm 13 sure you all know. Cordell, by the way, was also the
() 14 chairman of the IDCOR Steering Committee. And so we have 15 here a core from that IDCOR Steering Committee to carry on 16 continuity with the industry.
17 And I'll just let you read the rest of the names 18 on the slides.
19 This is a fairly senior level working group and 20 they provide very valuable policy guidance to us as we 21 proceed to come to grips with these issues.
22 By and large, it has been my observation that our 23 philosophies and approaches have been largely in tune with 24 what I sense are the ACRS' feelings from their letters.
25 However, there have been a couple of areas where we have O Heritage Reporting Corporation (202) 67.8-4888 l
hw l.
148 q f 1 taken different positions'than you have, and perhaps we 2 could explore'a couple of those as we go through.
3 with regard to the IPE implementation'we have-l 4 interacted with the Staff ever since -- actually, before the 5 formation of this working group trying to encourage them to 6 issue Generic Letter 88-20 because we felt it was. time to 7 get on with the process. We commented for the industry on:
8 that letter. We also reviewed and commented on NUREG-1335 9 to try to bring the industry's concerna back to the Staff in 10 their efforts to revise and finally publish that.
11 We have'taken the position that utilities should 12 expeditiously begin IPEs. Juxi I might say, we are trying to 13J encourage the industry to do this in the spirit in which
-( ) 14 it's intended; not to approach it as a typical licensing 15 activity, but to really do a thorough job of looking at the 16 plant and implementing the severe accident policy statement 17 in the spirit which we think was intended.
18- At this point we have taken the position that each 19 utility should develop its own decision criteria with regard l 20 to what'is a vulnerability. As Dr. Siess mentioned, none of i
21 us have been able to define it and we have tried. And also, 22 have their own criteria with regard to how they would 23 determine what of those vulnerabilities they would fix.
24 Yes, sir.
25 DR. SHEWMON: Go back up one bullet. Can you tell 4 O Heritage Reporting Corporation (202) 628-4888 i
l l
. - - _ . _ - _ - _ __- __ _a
149
-{} 1 Hme what kind of a group is.getting set up? ~ I guess there's 2 a few outfits.that have full-time people that do PRAs like 3 Northeast Utility does, the group that I'm familiar with,_
- 4 that many of them do not. How many people are we talking
.5- _about? Do you feel it's a one year assignment for them?
6 Are they hiring other groups to come in and do this for them 7 like some people have PRAs?
8 .MR. RASIN: Yes, that's a good question. And, in 9 fact, that figured in somewhat to one of the areas where we 10 differed a little bit with the ACRS on our approach.
11 You're correct-in that there are not many 12 utilities. Probably no more than six who can really do this 13 job themselves. There are a number of others who can do big O
Assl 14 portions of it themselves. But then there are a lot of 15 others that's going to have to rely heavily on outside 16 contract personnel.
17 Obviously, there are a number of consultants and 18 service organizations in the country that can provide this.
19 In fact, there was an IPE partnership of some of the firms l 20 that did a lot of the IDCOR work that formed specifically to 21 support the utilities in this effort. There are the vendors l 22 who will offer PRA type services. There is the Pickett, 23 Lowe, and Garrick, the SAICs. So there are a number of I 24 outfits that can do this.
25 If you recall a year or so ago I believe the ACRS 1
=O Heritage Reporting Corporation (202) 628-4888 l
f( '
150
(
L 1 wrote a letter recommending that, in fact, the Staff take 2 the' approach of requiring PRAs and strongly encouraging the-g 3 ISAP program for all utilities, and we took issue with that 4 in large part because of this question of resources. Our 5 concern was two-fold.
6 One, if we tried to do this on the same reasonable 7 -time schedule we would have trouble finding the available 8 resources in the industry to do a quality job. It wasn't 9 clear to us that everybody could contract for a PRA at the 10 same time and come to completion in this time frame.
11 A parallel concern with that was that, if that was 12 required in the same time frame.that more utilities would 13 rely more heavily on consultants and not participate as n
k_) 14 heavily themselves in this IPE process. And therefore, we 15 felt that pushing for everyone to do a PRA to satisfy the 16 IPE in this time frame was not in the best interest of the 17 industry or coming to closure on these issues. And so we 18 took a position somewhat different from you for those 19 reasons.
20 As you will see later, we are reconsidering this 21 question of criteria as to whether perhaps we shouldn't try 22 to establish an industry-wide set of criteria on 23 vulnerabilities and on fixes. It's a very difficult issue.
j 24 We are working on a document which we hope to l q
25 publish, I think, by the end of the year as guidelines to Heritage Reporting Corporation (202) 628-4888 1
]
- .. .. _ . _ _ _ _ _ _ _ ____________-______D
,-)
151
\_ J 1 provide a methodology for evaluation and disposal of IPE 2 insights and identification of possible procedural hardware 3 enhancements.
4 This actually grew out of our effort to develop 5 the accident management guideline which I believe you were 6 provided a copy of. Our first attempt at that we felt was a 7 little too broad; it actually almost encompassed the subject 8 of risk management. And we decided to separate those two 9 and provide an accident management guideline. But we felt 10 we would go on with the second document and try to turn it 11 into an IPE guideline and provide to the utilities.
12 One of our missions in the IPE was to educate the 13 Staff a little bit in the latest versions of the MAAP code, en k-) 14 The MAAP code was left with a bad reputation with the Staff 15 out of the IDCOR interactions. Since the time when those 16 interactions stopped we had done tremendoue amounts of work 17 on that code, much of it driven by the NRC comments. So we 18 were honestly trying to address their comments wherever we 19 could, and the code maintained a bad reputation with them.
20 DR. CATTON: The documentation kept up with the 21 improvements?
22 MR. RASIN: Yes, it had. Yes.
23 So we have engaged the Staff in some discussions.
24 We hope to convince them that, by and large, we have taken {
l their views into account and, in fact, changed the code j 25 i
i Heritage Reporting Corporation (202) 628-4888 I
i
.l 1
7-; - 152 .
~
-1 accordingly and we' re having that dialogue now.
2 The reason we think this is important is because 3 this clearly is the industry's tool for doing severe 4 accident analyses. And the industry is going to use it. We .
l 5 spent a lot of money and effort developing it, and we hope 6 it's seen in a little bit better light. l 7 The other thing that we're in the process of doing 8 as we start the IPE process is to identify some industry 9 people who are going to go first. We'd like to get a group 10 of people to get on early in the process, not wait for the l 11 end of the third year, and get some reviews underway with 12 the Staff so we can see where maybe the difficulties in the 13 review and approvals are and try to iron those out
) 14 expeditiously.
15 That is the crux of our effort right now with 16 regard to individual plant examinations.
17 We're also working with --
18 DR. SHEWMON: You had an interesting point of 19 identifying lead projects, do you feel you're close to that 20 on your last bullet?
21 MR. RASIN: Yes. We are sura that we will have 22 some. And what we're doing now is trying to look at who do 23 we want.
24 In talking with Vic Stello at one point he said, 25 well, get the NUREG-1150 plants to come in. I said, well, O Heritage Reporting Corporation i (202) 628-4888
p 153
!A.1 7 .
1- 'okay, I'd like to have a couple 1150 plants.. But also, I' d -
2 like to have a couple of non-1150 plants, because that's 3 going to'be a'different level of review for.the Staff; and 4 we are working on that. We have some people talking to us.
5 I wouldn't want to give you any names now because I don't-6 want to. embarrass anyone.
7 I will say, though, that some of the prime 8 candidates were mentioned during the license renewal 9 discussion earlier today.
10 DR. SEEWMON: Fine.
11 MR. RASIN: With regard to external events, at the 12 end of the IDCOR process we had some discussions with the 13 Staff regarding external events. Obviously, the ones of 14 major concern are fires, seismic. And then some of the ones 15 that crop up in the other analysis, external floods has come 16 up in scme PRAs, high winds in some, and miscellaneous other 17 hazards.
18 The position we took in IDCOR was, we opposed the 19 inclusion of external events in the IPE process because, in 20 fact, through all the work we had done in IDCOR in working 21 with the Staff in response to the advanced notice of 22 proposed rulemaking on severe accidents the question of 23 external events was always left aside, and that was done 24 from some very early discussions and for some specific 25 reasons for that time.
Heritage Reporting Corporation (202) 628-4888
f,r{., ,
'e 154 v (
1 We thought-we were very close-to'the end of 2 process and close to issuance of the, generic letter when 3 again the. question of external events came'up. We thought 4 they should be left aside because we believe they.are 5 extremely conservatively treated in the design basis and 6 examined extensively.as different' generic issues.
7 And at that time there was an regulatory 8 activities underway which we're looking at some of these 9 same issues and this was particularly true in the' seismic 10 area.
11 But also at that time the industry was just 12 beginning to get signed off on Appendix R and had been 13 through rigorous fire hazards analysis'and fire evaluations
( 14 and we really didn't see the need to go through all that-15 again.
16 MR. WYLIE: Bill, your position today is --
17 DR. REMICK: Microphone, Charlie.
18 MR. RASIN: This was our position at --
19 MR. WYLIE: Then your position would be as far as 20 the effects of lightening was concerned, this should be 21 considered as a generic issue.
22 MR. RASIN: Yes. I would not recommend that 23 lightening be included in these other issues and I'll tell 24 you why. If we come up with a screening process based on an 25 initiation frequency it's going to get screened out, it O Heritage Reporting Corporation (202) 628-4888
v nl < ; _
- 155 p 1 'isn't going to show. And if we carried it through it is'not p
1 ;2' . going.to come;up as'a core melt contributor thatowould in-
- 3 any way. pop up to the undefined category of vulnerabilities.
4 I'm aware of.the LESs that you are' referring to.
5' And,.in fact, at Duke we did a systems interaction kind of 6 study on-lightening; and I'm certainly not opposed to doing 7 that. 'I don't really feel that it fits into the severe 8 accident category. I think it's better handled as a cause 9 of. transients; a'cause of embarrassment for the industry.
10 But I don't see it as a severe accident precursor. And I 11 don't think the LERs really led down that path either.
12 DR.-SIESS: Before you did the study at Duke, how 13 much confidence would you have in saying that there were no I 14 plant unique vulnerabilities to lightening?
15 MR. RASIN: Well, again, we.can't define 16 vulnerabilities. If you're talking about vulnerabilities in 17 proceeding to a core melt sense, to be honest with you, I'm 18 fairly comfortable that that is not on the same par as these 19 other issues we're dealing with.
20 DR. SIESS: And you can say that before you made 21 your study? See, this is not generic now; we're not talking 22 anything generic. We are looking for individual plant 23 vulnerabilities that might be unique to a plant or a site.
24 MR. RASIN: I felt that way. And we, in response 25 to some of the LERs that have occurred on lightening we O Heritage Reporting Corporation (202) 628-4888
,s 156 L !
.1 decided to undertake the study, even though at that time 2 through our PRA work we had a sense that this wcs not a 3 significant severe accident issue. It was more significant f 4 to us in terms of plant protection and loss of plant 5 availability than it was a concern with severe accident 6 damage to the plant.
7 And having then proceeded to do an engineering 8 study of it, not a probabilistic study but an engineering i 9 study, I don't remember exactly how the results came out. I 10 remember we were happy with two of the plants and unhappy 11 with the third and made a few recommendations regarding the 12 lightening protection of the third.
13 I believe there's still a generic issue on
( 14 lightening protection that hasn't been signed off. I might 15 be wrong on that, but I remember it's on the list. And it's 16 my feeling it would be much better to handle that through 17 'that process than it would be to try to handle that in a 18 severe accident sense.
19 DR. REMICK: Bill, I apologize for the moaning I
20 and groaning you hear but members are getting their reading 21 material for tonight and that's why you see raising of 22 eyebrows and moaning; it has nothing to do with what you're 23 saying. ;
l 24 MR. RASIN: Oh, I thought they didn't like my 25 answer about lightening.
I 1
I)~
Heritage Report.ing Corporation (202) 628-4888
-- -- y TGV- .j 157 MR. CARROLL: Is this new or is this just more of'
~
l' .
E 2c 'the'same?
'3 DR. REMICK: There's still'more coming. .q l
L
'4 MR. RASIN: If I could continue now with a very 1
5 .brief snapshot..of the external' events' area. In' discussions 6 with the Staff-we were not winning our argument that we just.
7 should not treat it. And, in fact, decided that while we 8 thought on'a reasonable. sense we could win it was'not 9 productive to do that. And, in fact, there were some 10 weaknesses in our argument.
11 So we agreed that we would work with the Staff to 12 determine.how we'could come to grips with this area provided 13 that we could proceed on a reasonable' basis and'come upLwith
-( 14- something that was not a major reactivation of an' Appendix R 15 evaluation or that type of approach. And I think we're 16 successfully doing that.
17 So in the. fire area we are trying to develop -- in 18 fact, we're in the process of_ developing a methodology'that 19 goes on from Appendix R. l[t says, okay, we have Appendix R, 20 now what vulnerabilities do we have or what weaknesses are 21 there in that from a severe accident point of view and
-22 multiple failure point of view. So that's proceeding and 23 we'll be ready to discuss that probably in a couple more 24 months I guess.
- .25 Seismic is an area where our interest in seismic Heritage Reporting Corporation (202) 628-4888
= -__=_=_ _: _ _ _ _ _ - _ _ _ _ _ _ _
l-158
\* 1; was not_ treating ' seismic for severe accident purposes 2 totally separately and then going on and resolving the 3 questione of seismic design margins and A-46 and seismic 4 qualification and the Charleston earthquake issue and OBE 5 exceedance, et cetera.
6 What we wanted to do was to integrate these 7 seismic issues and let's see if we could not come to a 8 resolution that really addressed as many as possible of
.9 these through one approach. And if we could do that, then 10 we were willing to proceed with a seismic evaluation of the 11 plants and wouldn't argue that we shouldn't have to do it 12 for severe accidents. So that's the approach we're taking.
13 And again, I'm pretty happy with the progress we're making
() 14 there. l 15 This one is harder to come to gripe with. It's 16- noted the Staff is working hard on it; we're working hard on 17 it. In this area it's hard to come up with a reasonable 18 screening criteria because if you set it low enough to be 19 very, very conservative you wind up with some structural ;
20 analysis that are very, very expensive; and we don't want to 21 do that. So we're searching for where is the right cutoff 22 and the right approach. It's going to take us a little 23 while I think.
24 I don't think we need to talk more about this 25 because Dr. Siess' summary I think gave you most of this.
Heritage Reporting Corporation (202) 628-4888 4
,, s, 159 U 1 Let'me point out one other thing, with regard to 2 the industry's seismicity owners group efforts to come to 3 closure on the Charleston earthquake issue, we sensed a 4 feeling on the Staff that while a lot of good work had been 5' done on that and they didn't think it was a big hazard that 6 we should just say, okay, let's just leave that on the shelf 7 for a while. We said, wait a minute, we spent a lot.of work 8 on this and we want the issue closed.
9 So in this context we are continuing discussions 10 to say, no, let's look at all we have done and let's assess 11 it and let's see if we can't close that issue and not leave 12 it open in people's minds.
13 I think I'll skip these, too, because that.was 14 covered previously.
15 Let me talk a minute about the containment 16 performance improvement program. Here is an area where our 17 position has been very similar to the ACRS in that we feel 18 that to recommend generic fixes on containments is not the 19 right approach. And, in fact, the containment 20 considerations should be part of the IPE process and should 21 be done in an integrated fashion with the IPE.
22 We believe that the generic containment 23 performance program is not proper and, in fact, not even in 24 the spirit of the severe accident policy statement which 25 says, no new generic requirements are needed. And so we Beritage Reporting Corporation (202) 628-4888
,, 160 s j\
1 1 don't agree with proceeding that way.
2 I want to make clear that that doesn't mean we do 3 not believe that the items that they put on the list are not 4 worth looking at. In fact, we do agree that those are 5 things worth considering, but they should be done integrally 6 with the IPE, not imposed separately.
7 With regard to accidert management, we struggled 8 with this at the end of IDCOR and the industry was very 9 divided. There were people who thought, yes, accident 10 management is something we should get into in a formal 11 sense; and there were people who were afraid of getting into 12 that.
13 I think finally after a lot of debate the industry
) 14 has come to the position that this is a wise thing to do; 15 it's a natural follow-on to the IPE process. If you're 16 going to learn about your plant it only makes sense then to 17 use that knowledge. And, in fact, we see an accident 18 management program as a way to use that knowledge and keep 19 it in practice at your plant.
! 20 So we have been working with the Staff to try to l
21 define such a program. And, in fact, we have developed a 22 draft guideline document. That has been transmitted to the l 23 Staff for their comments and also to the industry at large l
l 24 for industry-wide comments. We hope to finalize that l 25 document; conduct some pilot programs; and then issue that 1
(~')
Heritage Reporting Corporation j (202) 628-4888
l 161 1 document sometime next year so that utilities will have it 2 and will proceed to put an accident management program in i
3 place in accordance with those guidelines.
4- DR. SHEWMON: Can you give me an example of some 5 of the things that might come as a result of this? Are we 6 talking hardware or just training?
7 MR. RASIN: We think that hardware is not and 8 should not be the main thrust of this. Obviously, you 9 cannot rule out that there could be hardware involved. Our 10 idea was that we should treat this accident management as an 11 immediate follow-on to the IPE process. So that, in fact, 12 what you could do, when you come out of the IPE you would 13 have a list of things you wanted to consider and from those
() 14 things you could choose that I will make a hardware fix to '
15 the plant to reduce the likelihood of that event.
16 Or I will make a hardware fix to the plant that 17 allows me to deal with that event. Or I will make 18 procedural changes or extensions to deal with the issue. I 19 will provide training to deal with the issue. Or it's 20 something just out of the question to deal with. If we get 21 an earthquake so large that the containment falls down, 22 there's not a sense in spending a lot of engineering time 23 looking for fixes for that; you're not going to find any.
24 Then in this whole package we would see the --
25 primarily the hardware fixes come with the IPE. The O Heritage Reporting Corporation (202) 628-4888
_ 162
,I )
1 accident management involves more adjustments to your EOPs 2 or.providing additional accident management guidance, I
3 perhaps, in your emergency centers or your TOCs for your 4 engineers to use, for your STAS to use. And then 5- additionally, the training required to do that.
l.
6 We are very concerned that we don't want to'take 7 the approach that we try to expand the EOPs to cover-all 8 eventualities of severe accident. And we don't get into the 9 kind of training that would be required if you did that.
10 Our concern is that you would overwhelm the 11 training process with 10 to the minus 6, 10 to the minus 7 12 events and take away from the day-to-day ordinary operations 13 which may enhance your chance of getting into that
() 14 situation, so there's got to be a balance there.
15 With the accident management there is the 16 possibility that to carry out the strategy maybe you need to 17 change some instruments or add something. We can't rule 18 that out.
19 We are -- our thrust on this has been to say, 20 we're going to use supplemental technical staff training.
21 We're reluctant to go full bore simnlator kind of training 22 that we would have for regular procedures and EOPs; we think 23 that excessive.
24 We're going to rely heavily on non-safety related 25 equipment. This is not a licensing exercise; it's what do O Heritage Reporting Corporation (202) 628-4888
P L'
163 l-[)
1 you really have to use when you.get in the situation. And, 2 in. fact, we will even consider recovery of failed equipment.
3 But it will'be done realistically. This will be, how do you
- 4. do this. It won't be, how do we fix a number and stick back 5 in the IPE so the sequence goes down.
6 I think that's going very well and I'm looking
- 7. forward to the Staff and industry comments on that document.
8 Again, as I said, we thought it very important 9 that this be integrated. That we not treat accident 10 management as something totally separate from IPEs, just the 11 same as we don't think we should treat containment 12 performance totally separately from IPEs. And I think the 13 Staff and the industry see pretty close to that.
14 DR. REMICK: Bill, if I recall, when we had a 15 presentation some months-ago from the Staff in the accident 16 management area they had some things where they felt that 17 licensees should do right away; have you responded to that 18 in any way?
19 MR. RASIN: Well, we did. We had early meetings
- 20 on that and I think initially the thought was that they 21 could issue those things even ahead of an IPE and that, in 22 fact, they didn't have anything to do with the IPE; you 23 could just do these things. And they were called -- they 24 were just painless things. ;
25 But I guess I object to any changes in a nuclear O Heritage Reporting Corporation (202) 628-4888
'i q 164
~
- 1. plant being painless. And we felt that was the wrong 2 approach. I think -- it's my understanding now they are 3 still going to issue a list of strategies that they want to 4 be considered along with the IPE process, and we have no 5 problem with that. It's integrated in with theirs and 6 that's fine.
7 DR. REMICK: I don't recall if we put that in 8 writing but basically that was our position, also, why push 9 thead with these things why not. If they're good ideas let 10 industry know it and let them consider it under IPE.
11 MR. RASIN: Yes, we think that's a reasonable way 12 to proceed.
13 Again, on the accident management, each utility r~)s
(_ 14 will make its own decision on what it should treat in this 15 program and its own decision on what it should fix. Again, 16 we are still assessing that as with IPEs with the thought 17 that maybe we should take another try for an industry-wide 18 criteria. I think that's all we need to say on that.
19 Let me take a minute --
20 DR. REMICK: We see the typo.
21 MR. RASIN: Yes.
22 I was going to define that sever accident as an 23 accident containing multiple vulnerability and the e
24 definition flowed right from it, but we'll let that pass.
25 We are concerned about closure. As I said before, f3
~
Heritage Reporting Corporation (202) 628-4888 i
165 1 it was my-feeling that the time had come that we get started 2- on this. And I felt that if we sat back and argued about a 3 criteria which the industry in total and the Staff in total 4 would agree to, this is the end criteria before we get 5 started, I was convinced we would never get started. So I 6 felt we ought to move along and let's go do it.
7 That's not to .f that now I'm not very concerned 8 about, we have all these balls rolling, how are we going to 9 stop them. .And this is a question that we're turning our-10 attention to now.
11 Obviously, one of the questions is: do we provide 12 industry-wide closure criteria? And if we do we think that 13 they have to-have a quantitative and a philosophical (G,j 14 element. I see absolutely no possibility that we can define 15 a set of numbers that's going to do the whole job unto 16 itself. I think they would be misunderstood and misused.
17 So we're taking a look at that both from an overall closure 18 question and from a specific - plant-specific consideration 19 for IPE and accident management.
20 Right now the Staff's definition of closure has 21 been that you will be finished when we're finished our 22 review and we're happy with it.
23 While I fully believe that they have the right 24 spirit of the IPE and accident management process and we 25 have the right spirit, I don't think that's going to work.
O- Heritage Reporting Corporation (202) 628-4888'
r -I
.n-. 166
.L.)
~
1 I think we're going to need more than just when we're all 2 happy we'll stop. So we're giving a lot of thought and 1
3 attention to that right now.
4 I might add one other area where we have taken a 5 different position than ACR$ in regard to severe a:cidents.
6 I mentioned the PRA and the ISAP. The other area was the 7 question of generic issues and treating all or most of the 8 generic issues in the IPE process. That was an ACRS 9 positlon along with the PRA and the ISAP.
10 Wo took issue of that. In fact, I think I wrote a 1:L letter to Dr. Kerr when he was chairman at that time, taking 12 issue of that point of view; and I'll give you a couple 13 reasons for that. One, it was our feeling that, to be k 14 honest with you, that made the job too big. I agree it 15 makes all kind of intellectual sense to do that, but it just 16 makes the job too big.
17 I felt taat if we stopped and assured ourselves 18 that the analysis we were doing would actually satisfy the 19 ability to resolve all of those criteria that again we would 20 be several more years before we got started and that was not 21 in the best interest of the industry.
22 And so we decided to say, no, we don't want that 23 to be a requirement.
24 The Generic Letter 88-20 does state that if the 25 utility chooses to claim that generic issues are resolved Heritage Reporting Corporation I (202) 628-4888
\
O L >- 167
-('*
1 through this process, they can't make that argument to the 2 Staff and we support that and say that's very appropriate, 3 but let's not try to make that so for all utilities for all 4 issues.
5 The second thing that concerned me with putting 6 the generic issues in with the IPE is that, I believe, if 7 that was done on the front-end I think the Staff would have 8 felt the need to eveluate each issue and put a little module 9 into the IPE to say, okay, you have to do this analysis this 10 way to treat this issue. And again, I thought that would 11 contribute greatly to the time to get started; and also, 12 contribute to the. difficulty of the job.
13 So as anxious as I am to get all these other
() 14 generic issues signed off, I just honestly felt that that 15 was not the way to proceed. And so we did differ with you 16 in that regard.
17 DR. REMICK: Go aheadr Jay.
18 MR. CARROLL: Isn't reality some place in between.
19 I mean, A-45 has been subsumed into the IPE.
20 MR. RASIN: Well, A-45 is subsumed but I would 21 maintain that some of the guidance given by the Staff and 22 some of the response in the SERs to the IDCOR IPE 23 methodology was driven by the fact of signing off A-45 and 24 therefore they wanted some more detailed kind of analysia.
25 That supposition I'll just -- I won't attribute that to the Heritage Reporting Corporation (202) 628-4888
,w,--v---r- - - - - - - - - - - , - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
I-168
'4N -
El Staff, I'll say I have that suspicion. And I'm afraid that 2 would have happened with a number of the other issues as 3- well.
4 MR. CARROLL: Well,'I don't know, I've seen a few 5 come along recently where I almost think the industry would 6 be better off putting them in the IPE process. I realize 7 some of the problems you're talking about, as opposed to 8 being nickel and dime to death.
9 MR. RASIN: Yes, I sympathize with that.
10 What I have done and we have not done much work on 11 it yet, quite honestly, because we've got a lot of things on 12 our plate in this area. But we have thought about, well, 13 maybe what we should do for the industry is to take a look
( ). 14 at EPRI or INFAC, take a look at the list of generic issues 15 and identify those which perhaps we thought would very E16 naturally be t-ken care of by the analysis we were doing and 17 separate out those which we felt would require some 18 additional or supplemental analysis; and then provide that 19 list to the industry and say, here, we think that you could 20 make an argument that you could sign these off just by doing 21 the IPE. We'll take a look at that. Quite honestly, we 22 just haven't had time to get to it yet.
23 MR. CARROLL: A recent one was on a bunch of cats 24 and dogs electrical issues.
25 MR. RASIN: I'm aware of that; we've been j Heritage neporting Corporation (202) 628-4888
169 h
1 following that issue. j i
2 MR. CARROLL: That's seems to be something I could 3 closeout for my utility once and for all through.IPE.
4 MR. RASIN: I'm not sure I agree you could do that 5 without some supplemental analysis on that. We're still 6 looking at that one.
7 MR. CARROLL: I picked that as an example.
8 MR. RASIN: Yes, I was aware of that example 9 because we had -- in fact, we offered to talk to the Staff 10 and try to help them with the questions they were going to 11 ask the industry, so that they could get the information 12 with the least impact. So we have been working with them on 13 that to try to get that resolved.
y gJ L 14 MR. CARROLL: But a lot of the Staff's problems 15 seem to be, well, we didn't really go look at the plants, we 16 looked at what they had in their tech specs and if they 17 didn't have a tech spec requirement we assumed the worst 18 about them. And now we're going to send out this big 19 elaborate questionnaire to everybody to find, you know, to 20 find out what we could find out by some other process. And 21 that seemed like a waste of everybody's time.
22 MR. RASIN'. Well, I understand that. And as I 23 said, we offered to talk to the Staff mainly from that 24 concern; we were concerned with the resource impact of it.
25 But I'm not yet convinced that that would automatically fall O Heritage Reporting Corporation (202) 628-4888
IPff.,
- f-. 170
~
1 out of the IPE.
2 The other thing, I noticed your comments on that, 3 gee, here's another deterministic thing, not a reliability 4 approach. I agree with that, but that's another thing that 5 troubles me; I'm not sure that we're all ready to turn to a 6 real reliability approach. We're seeing that in working 7 with the diesels where we're trying to offer up a pretty 8 comprehensive reliability program. But we're seeing it on 9 the side, they still want to keep a few deterministic 10 things. So I'm concerned that we're just going to wind up 11 with both, which I don't think is productive either.
12 I guess with that, that's what I have to say.
13 We'll look forward to providing more detail in the future.
) 14 DR , REMICK: Did you have anoth6r question you 15 wanted to ask Bill on that matter?
16 HR. CARROLL: Last month when --
17 MR. RASIN: Oh, systems interaction.
18 MR. CARROLL: -
yes, we were going to hear about 19 systems interaction from you and we ran out of time. Are
'0 6 you prepared to give us the insights.
21 MR. RASIN: Well, I don't know about insights, but 22 I'll be happy to say a few words about that.
l 23 We have been following that issue. We thought 24 back about 1986 or so that that issue was on the verge of 25 resolution with the Staff; and then some reorganization in l
O Heritage Reporting Corporation (202) 628-4888 i
L' . . ___ . _ _ _ _ .__ _ _ _i
V: "
171 O l' the Staff and'in the industry I think kind of threw that off
, 2 base. And we've been watching the process now in looking at 3 .- this multiple systems response program.
4 I have to tell-you honestly,-I don't think I 5 really understand completely the multiple systems response 6 program yet. We're looking forward to some more in-depth 7 material being tvailable from the. Staff and we will look at-8 it.
9 .The syster s _ interaction going away, I guess I'm
- x U0 1 happy to see that. I think they took a couple of pieces and 11 1- put it in the right place.
12 With' regard to the concern in general of systems 13 interaction, and almost as I sense the committee's 14 discussion on that is, how do we know'the annu11able. And 15 in my experience in doing some of that and setting up a 16 group to do it, it's very difficult to do.
17 It has been my experience that the most 18 significant things we found were found in the process of 19 doing other studies. We set out to do a coople just non-20 descript sys?. ems interaction, sneak circuits, you know, 21 using all that kind of methodology.
22 And I'll tell you, you don't find a whole lot that 23 way. And to ask people to do it winds up being kind of 24 frustrating because you take very good talented eager people 25 wanting to make a contribution and they study something for OI Heritage Reporting Corporation (202) 628-4888
172 1 months and months and months and you come up with nothing.
i 2 And you say, well, okay, let's go do another one.
3 So we started out doing-a lot of that and scaling 4 back our activities it. that regard.
5 I guess it's my feeling that the solution to that 6 -is through an awareness and through doing your safety 7 reviews for plant modifications through doing things like ,
8 the IPE and chasing questions down. That's worth doing.
9 Concentrating a lot of engineering effort within 10 the utility, specifically just going around looking for 11 systems interactions we have not discovered, I don't think 12 is very productive.
13 And approaching it from a regulatory point of view p
L(_) 14 I think is probably counterproductive because that would 15 require a greater degree of effort if ae got into the 16 regulatory arena.
17 So I'm happy to see that program go that way.
18 We'll look at the multiple systems response program and 19 we'll see whether there's a contribution industry can make 20 to help come to grips with that.
21 MR. CARROLL: Well, do you feel that in most 22 utility operating an engineering organization that there's a 23 sensitivity problem and a desire to look for it or do 24 people, you know, say, I'm not going to ask for trouble, you l 25 know, maybe there's a problem here, I'm not going to step l
Heritage Reporting Corporation (202) 628-4888 l
l l
Y_-_-_-___-____-__---_________________-____--__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _
e.
( T,
. .y 173 1 off into this mine field. And should NUMARC be encouraging i'
- 2 people to find these kind of things.
3 MR. RASIN: Yes, that's a good question. I think, 4 obviously, I have not done any kind of a poll to tell you 5 what other utilities do in this area. I would be willing to 6 bet that the answer is, those without large engineering 7 organizations probably don't'd.o much and probably don't have 8 that_much sensitivity. We're hoping that that's one of the 9 things the IPE study /reates, particularly with encouraging 10 ~the utilities to get their own people involved in it.
11 A lot of people who have their AE work contracted 12 outside, perhaps, don't do adequate systems interaction 13_ studies or even interdisciplinary design studies of how that
) 14 fits in. We've got to do better in that regard I think as 15 an industry.
16 Even at Duke, I'll tell you, that in the days we
~17 set this up I don't think any of us were convinced with our 18 large engineering organization and our desire to do it that 19 we were really doing the right job on it and doing a good 20 enough job.
21 MR. CARROLL: So you're going to take the message 22 back to the utilities that they probably ought to, at least, 23 take advantage of IPE to look at some of these kind of 24 things.
25 MR. RASIN: Well, I don't know what you mean by Heritage Reporting Corporation (202) 628-4888 l
I
t-174 ,
(c)'~'
look at some of these kind of things. See, that's where you l
1 l l
2 get into a problem, what do you mean by look at. If you i l'
3 could define these things then you could look at those.
4 That's different from a sensitivity which says, you know, 5 ask the question. When you're looking at how a system works 6 and you go off, if something looks funny, you know trace 7 that string down and see, is that power really available or l 8 is that water supply really available kind of thing.
9 MR. CARROLL: We did this at Diablo, the seismic 10 one, which it encompasses everything. Pretty soon, the guys 11 that were doing it and the people they were going to and 12 saying, tell me about this. I almost got the feeling that 13 at some point that people who operated the plant, you know,
( 14 didn't even want to confess up to some of this st uff. I 15 don't want to get off into a mine field here.
16 MR. RASIN: Well, as you well know at the plants 17 there's always been -- and downtown -- there's always been a 18 concern with, gee, don't make regulatory issues because you 19 know what happens there.
20 I got to tell you, I believe that that environment 21 is changing in the industry. I think we have all learned 22 that that doesn't get us anywhere and if anything you're.
23 just buying bigger trouble if you don't go look at what you 24 suspect is wrong. I think we're maturing from that point of 25 view.
O' Heritage Reporting Corporation (202) 628-4888
0 m 175
.1 MR.. CARROLL: Carl, we're talking about system 2- interactions and you haven't said a word.
3 MR. MICHELSON: I've heard every bit of it. i 4 think -- I really do agree with the statement that it is a 5 question of education, understanding, and then 6 implementation of that understanding into the design process 7 or into the review process.
8 What I don't find is an attempt to -- maybe you 9 can tell us what the industry is doing to try to develop 10 this understanding so that you can then sensitize people to 11 the problem and the review process will work properly.
12 I agree, it isn't ever a question of sittirg down.
13 and doing a system interaction study per se; that's a
( 14 difficult impossible way of doing it. I've always felt that 15 way. You've got -- it's a matter of understanding and 16 implementation.
17 Is the industry doing anything to develop that 18 understanding?
19 MR. RASIN: I'll have to tell you that in regards 20 to the present operating plants and operating organizations, 21 no, we do not have any structured program underway to do 22 that.
23 In regard to the work that's been done on the 24 advanced lightwater reactors and in the requirements 25 document, that was something that was considered in the EPRI O Heritage Reporting Corporation (202) 628-4088
E ..
176
.O l' process early-on'to say, wait a minute, we've got to require
'2 'some good design reviews and some good interdisciplinary 3 . reviews right in the design process because that's where you 4 have to find these things.
5 It's.a good point, we'll certainly discuss it 6 further.
7 MR. MICHELSON: It's a difficult issue though.
8 MR. RASIN: It's hard because everybody does 9 business a little different way. So it's hard to come up 10 with one simple program that fits everybody and the way they i
11 do business.
12 DR. REMICK: Bill, I know' earlier you talked about 13 NUMARC differed with the position of ACRS on PRA for all 14 reactors but ISAP. I wonder if you would just briefly 15 repeat that, I would like Dr. Siess who wasn't here at that 16 . time to have the advantage of your remarks on it.
17 MR. RASIN: As to why we differed with that?
- 18. DR. SIESS: On the ISAP.
19 DR. REMICK: On the ISAP.
20- MR. RASIN: You want to talk about ISAPs 21 'specifically and not PRAs. We'll le. ave PRAs aside because 22 -- well, we won't. One of the problems with ISAP is, you've 23 got to have a PRA to enter into the process. It was our 24 understanding and, in fact, the Staff stated their position 25 that an IPE wasn't good enough; it . had to be a full PRA.
O Heritage Reporting Corporation (202) 628-4888
. . . _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - .1
l I
L 177 L
l '" -)
1 DR. SIESS: That was before the IPE was invented,.
2 MR. RASIN: No, sir.
3 DR. SIESS: ISAP came before PRA.
l l
4 MR. RASIN: Well, I understand ISAP came before j
. I l
5 PRA. What I'm telling you that, in the process of talking I J
6 about IPEs and ISAP we asked the Staff and the position was i
7 taken that, no, IPE doesn't get you in the ISAP door, a full 8 PFA d70s.
9 Now, our problem with PRAs was two-fold. We felt !
10 that if the whole industry was required to do a full PRA at 11 that point in time that we were very concerned that the 12 resources were not ava:lable across the industry to be able 13 to do that in a timely fashion and in the time frame we were
() 14 talking about for IPE implementation.
15 Secondly, we were concerned thrit by requiring full 16 PRAs in a fairly short time frame would turn more people or 17 would cause more people to just turn and have a PRA done 18 them and not get their people directly involved in it. And 19 so we saw disadvantages to a PRA.
20 Now, with regard to ISAP we say, okay, we're a 21 little -- we had a little problem because we didn't want the 22 PRA required to go into it. With regard to the ISAP we 23 didn't take a position that we're totally against ISAP; 24 that's for the industry and each company to decide. That, 25 as I remember, the ACRS letter, it was all r >lled into, we
,m Heritage Reporting Corporation (202) 628-4888 j
178 i
' 1 ought to do a PRA, we ought to have ISAP, and we got to roll j 2 in all the generic issues. I mentioned we took opposition 3 to doing the PRA and we took opposition of rolling in all 4 the generic issues as I mentioned before.
5 With regard to ISAP we did not take the position 1 6 that it should not play any role. We did take the position, 7 it shouldn't be required of everybody because these other 8 things were required. And our position remains, if 9 individual utilities want to sign up for that, that should 10 be an individual utility decision.
11 So far there has not been a lot of interest in the 12 industry for a variety of reasons. People who do, I think, 13 a good job and have good relations with the Staff really
() 14 don't feel need for an ISAP. They feel they can talk to the 15 Staff when they need to rearrange their schedule and they're 16 happy with that.
17 DR. SIESS: Now, wait a minute, that's not the 18 feature of ISAP; that's a feature of the schedule.
19 MR. RASIN: I don't see any sense to doing ISAP 20 unless you go on to an integrated schedule.
21 DR. SIESS: I know, but ISAP goes beyond an 22 integrated living schedule. ISAP says there's some things l
23 you don't have to do. And I don't know anybody yet that's 24 talked the Staff out of doing something that's required 25' without ISAP, and there are only two plants doing it.
Heritage Reporting Corporation (202) 628-4888 l i i _-_ -_____- _ -
l I
I 1
179 l 1 MR. RASIN: That's what ISAP says and I guess that 2 goes back to my other statement on reliability and I don't 3 think we're ready for it.
4 DR. SIESS: My question -- see, you've answered my I
5 question I didn't really ask, entirely in terms of the IPE 6 program. And I really wanted to ask you, why is there lack 7 of interest in ISAP in the industry which was introduced 8 long before the IPE was?
9 MR. RASIN: Well, again, I think there's a variety 10 of reasons for that and we haven't taken any kind of a poll 11 on that. I can tell you some of the --
12 DR. SIESS: Well, the Staff did, you know, and 13 didn't get very much input.
O 14 Oh, they just took a poll on who was
's_/ MR. RASIN:
15 interested and they didn't get much interest. They didn't 16 take a poll on, why are you not interested. Now, the 17 why's --
18 DR. SIESS: That's why I'm asking you.
19 MR. RASIN: -- the why's are -- I'll just tell you 20 from my experience in talking to people and I won't 21 represent this in any way as an industry position or a 22 statistically valid sample.
23 DR. SIESS: I wouldn't believe you if you did.
24 MR. RASIN: There is the -- the fact you 25 mentioned, well, this tells you, you don't have to do some O Heritage Reporting Corporation (202) 628-4888
g:
1g-180 1 things. :To be honest with you, there's not a lot of 2 confidence that that would ever happen. The feeling is h
3 that, well, you go to a'living' schedule and maybe there will 4 be things in there you never ever got'to. But they wouldn't 5 just disappear.
6- There's another' feeling that, okay I do an ISbP 7 and I move on to an integrated schedule. That makes the NRC 8 a partner in my business decisions and.I don't want that.
9 DR. SIESS: Why is it that one utility whom I 10 would never accuse of being in partnership with NRC is so 11 enthusiastic about ISAP?
12 MR. RASIN: I would --
13 DR. SIESS: This is a utility that fights the NRC 14 tooth and nail.
15' MR. RASIN: Let me say that I do not speak and 16 will not speak for Northeast and suggest maybe you ask them 17 that question directly.
18~ DR. SIESS: Well, we've asked them and they just 19 think it's a great idea. And I'm trying to figure out why 20 nobody agrees with them.
21 MR. RASIN: You may explore the fact that they had 22 an SEP plant.
23 MR. CARROLL: You touched on one issue that always 24 troubled me when I was wearing another hat, namely, that it 25 gets the NRC under the management of your business.
Heritage Reporting Corporation (202) 628-4888 l
ir-- 181
~
1 DR. SIESS: I don't-see how the integrated living 2 schedule gets the NRC in. t 3 MR. CARROLL: Yes.
4 DR. SIESS: And a lot of utilities that have gone 5 to integrated living schedule are not considering ISAP. f l
6 There are several plants that have the living schedule; 7 there's only two that have ISAP.
8 MR. CARROLL: Is that true?
9 MR. RASIN: Yes, that'is true. But I think -- I 10 don't'know of anyone who felt that it made any sense to do i 11 all the effort to do'ISAP without going right on-to a living l
12 schedule.
13 DR. SIESS: No , I would put it the other way
( 14 around; you start with the living schedule and then you go I
15 -to ISAP to see what you can clear up. They're not 16 completely separate things. But there's several plants -- I 17 have never seen a list, but I keep aseing correspondence on l
18 it. This is the kind of stuff we lost by not adopting 19 plants.
20 MR. CARROLL: I had the impression that the Staff i 1
21 kind of lost interest in the living schedule idea. True, to 22 me a well managed utility was doing something like an 23 integrated living schedule already for its own purpose.
24 MR. RASIN: You have to, to do businesc.
25 MR. CARROLL: But the concept where the NRC gets l
0 Heritage Reporting Corporation (202) 628-4888 1
)
. ,_ s 182
(~'I 1 involved in negotiating these sort of things; is that really 2 being done out in the industry? There are a few.
3 MR. RASIN: Yes, there are few who have gone the 4 integrated schedule route.
5 DR. SIESS: There's more than two.
'6 MR. RASIN: Obviously, everyone has this 7 negotiation. If you have a list of regulatory commitments 8 and something happens where you have to make some other 9 modifications or postpone these you've got to go back and <
10 talk to the Staff. So it happens whether it's official or 11 not.
12 DR. REMICK: Bill, another subject, on the 13 accident management area, has NUMARC addressed the question 14 in case of a severe accident who operates? Whose in charge, 15 the plant operating staff or does it shift to the technical 16 support staff? Has any thought been given -- if there is a 17 transition, how that's done?
18 MR. RASIN: That's an important aspect. We have 19 not taken a position, again, because people are organized 20 differently and there's significant differences in the EPGs 21 between BWRs and PWRs. We haven't tried to impose 22 frameworks as you do this.
23 However, one of the major attendance of developing 24 an accident management program is t.. clearly delineate 25 authority and transition. Who makes what decision? If you i
Heritage Reporting Corporation (202) 628-4888
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l
i i
l I
, 183 l 1
t )
- ' 1 go to, _ you' re going to dump river water in the basin of the 2 containment, who is going to make that decision; and that's 3 got to be based on the time frame and your organization and 4 who is in place.
5 So we think that's a question every utility has 6 got to answer for himself and the responsibility has got to 7 be clearly delineated at this plant.
8 DR. REMICK: So you're just identifying the 9 questions and not the answers --
10 MR. RASIN: Identifying the questions that have to 11 be answered; that's got to come out the other end.
12 MR. CARROLL: I guess I would have answered it 13 differently. I would have said that people have done O
k..s 14 exactly what you' re describing in the development of their 15 emergency plans. Maybe there will be some new insights that 16 come out of IPE and the thinking that goes into, quote, 17 " accident management," which I view as just sort of an 18 extension of emergency planning. But basically people have 19 answered that question.
20 MR. RASIN: Yes, many people have. And we felt --
21 one of the reasons that we want this guideline approach 22 instead of trying to define a problem or little boxes and 23 all that was the fact that we thought that what was done 24 here was really an extension of the efforts that people had 25 taken for their emergency planning.
O Heritage Reporting Corporation (202) 628-4888
184
(sI '
1 You already have the major organizations in 2 effect. It's now, maybe you're going to learn some more 3 things they should do or maybe some of this should be done 4 over here instead of over there. But what you did had to be 5 consistent with the organization you had in place. So we 6 tried to produce the guidelines that made them answer those 7 questions and then fit them into the organization that was 8 in place.
9 DR. REMICK: Any further questions or comments?
10 MR. MICHELSON: Yes.
12 DR. REMICK: Carl.
i 12 MR. MICHELSON: Do you get involved very deeply in 13 PRA or is that kind of outside --
/"\
(,j, 14 MR. RASIN: Personally or what?
15 MR. MICHELSON: As NUMARC. Or is that a cut below 16 what you ordinarily look at in detail?
17 MR. RASIN: I guess without knowing the thrust of 18 your question I'll have to say, yes, I don't think you can 19 really be in the business these days without getting 20 involved.
21 MR. MICHELSON: The area of interest is, to do a 22 good PRA particularly for accident conditions and perhaps 23 even for licensing renewal one needs to understand the 24 difference between reliability numbers based on nominal 25 operating experience and reliability based on severe 9d Heritage Reporting Corporation (7"") 628-4888
m 185 f- g L
D 1 accident loadings or even normal accident loading.
2 You also have to understand the effect of. aging on 3 these reliabilities. Do you have any kind of a' program in 4 progress to try to get better information and better data?
5 MR. RASIN: We do not have a specific program in 6 progress with that thrust. We do, as an industry, have some 7 aging research underway and we're dialoguing with the Staff 8 on their aging research.
9 With regard to this use in license renewal -- I'm 10 kind of glad you brought that up because I wasn't real happy 11 with that discussion that went on earlier today with that.
12 We have produced a screening methodology which is 13 a way to go through your plant and decide what safety
() 14 significant systems have to be especially treated in license 15 renewal and what doesn't. You can go through that screening 16 methodology -- if you have a PRA you can use it ta go 17 through it. If you do not have a PRA you can still do it in 18 a programmatic sense.
19 It does not depend on the age related degradation.
20 That's one of our concerns with highlighting a PRA with the 21 use of license renewal, the state of the art is not there.
22 It can't do it.
23 MR. MICHELSON: In what respect do you mean, you 24 can't do it?
25 MR. RASIN: We do not have the information to have i
Heritage Reporting Corporation (202) 628-4888
.g 186
' t,) 1 age related degradation.
2 MR. MICHELSON: The failure rates suggested for
'3 aging effects.do not exist, I guess you're saying.
4 MR. RASIN: That's correct. And, in fact, I would 5 take the point of view that some aging degradation is 6 already naturally in the data base.
7 MR. MICHELSON: Oh, yes.
8 MR. RASIN: And so you can't just say, well, we'll 3 add 20 percent. We. don't know what we're doing in that 10 area.
31 MR. MICHELSON: Depends on the component.
12 MR. RASIN: And so we think that using that to 13 that' extent for license renewal is just not viable at this (I 14 point in time. That's not to say that you cannot take
'15 account of a PRA that you have done to tell you which of 16 your systems are particularly important from a safety point
- . 17 of view and then give those special attention in looking for 1
18 aged related degradation. So we would see them in that '!
19 light.
20 MR. MICHELSON: But you wouldn't attempt to do an 21 aging PRA.
22 MR. RASIN: I don't know. An aging PRA is not --
23 we don't see as a viable option. The state of the art just 24 isn't there.
25 MR. MICHELSON: Now, in the case of normal PRAs i
() Heritage Reporting Corporation !
(202) 628-4888 i
l
187 1 for the non-aging question, have you any efforts underway to {
2 determine if your reliability data base is adequate? I'm I
3 . thinking in particular motor operated valves, for instance, 1
4 which are primarily based on some very old data bases which 5 .do not reflect real loadings of valves, real world 6 situations. But maybe these aren't large corrections, I 7 don't know. Have you had anything underway to try to 8 determine if that data base is still good enough?
9 MR. RASIN: Well, again, that's a difficult 10 question to answer in total. No, we do not have a specific 11 program directed towards that.
12 .However, a lot of the work done in the industry at 13 EPRI takes a look at that. And by saying, that data base is
)- 14 kind of difficult to begin with because there's a number of 15 different data base that people have used.
16 MR. MICHELSON: I was thinking just motor operated 17 valves only to point the discussion.
18 HR. RASIN: That is a point that -- I can't give 19 you any specifics, but I remember having discussions. I 20 think there are some people taking a look at some specific 21 examples on motor operated valves and check valves.
22 MR. MICHELSON: Because there's a lot of valves in 23 a PRA.
24 MR. RASIN: Yes.
25 One of the things that's being encouraged for l
O Heritage Reporting Corporation (202) 628-4888 i
188 r
' 'j 1 plants with operating experience to use their own data base.
2 Their own plant-specific experience which should naturally l
3 correct that. l 1
MR. MICHELSON:
4 To some extent.
5 MR. RASIN: To some extent. However, as you're 6 well aware, that adds a significant chunk of work on doing 7 one of these, it's a lot of man-hours.
8 DR. REMICK: Further questions or comments?
4 9 (No response) 10 DR. REMICK: If not, we thank you very much, Bill, 11 and we appreciate you rearranging your schedule to comply 12 with ours.
13 Mr. Executive Director -- Mr. Fraley, am I
) 14 correct, we have covered all of our agenda for today. It 15 has changed so many times I've lost track.
16 MR. FRALEY: Yes, we have.
17 DR. REMICK: Gentlemen, yott worked so hard and to 18 allow you ample time to read the information that you have 19 to read tonight I suggest we adjourn for today.
20 MR. CARROLL: I did search through it and in a lot 21 of cases there's a cover letter on the top that you might 22 want to read; the rest of it is references.
23 DR. SIESS.' Read it, I can't even lift it.
24 DR. REMICF: Off the record.
25 (Whereupon, at 5:25 p.m. the meeting was adjourned O Heritage Reporting Corporation (202) 628-4888
l 189 7-~3 s"/
1 to reconvene tomorrow morning at 8:30 a.m., Friday, 2 September 8, 1989.)
3 4
)
5 l
6 j 7
8 9
10 11 12 13 iv 14 15 16 17 18 19 20 21 22 23 24 25 r\
V Heritage Reporting Corporation (202) 628-4888
,I b- ,1 CERTIFICATE 2
3 .This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory. Commission in the matter 5 of:
6 , Name: 353rd ACRS i
. j l
7 8 Docket Number: g 9 P1 ace: Bethesda, Maryland 1
10 -Date: Thursday, September 7, 1989 '
11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear- j 13 Regulatory Commission taken stenographically by me and, 14 thereafter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings. ,,..
y j j 18 /s/ Y h d>4 t
I/ I ffild]
IRWIN L. COFF 19 (Signature typed) : ([ERRY 20 official Reporter 21 Heritage Reporting Corporation l 22 23 24 25 Beritage Reporting Corporation (202) 628-4888
~
/^\
N-]
1 CERTIFICATE 2
3 This is to certify that the attached proceedings before the 4- United States Nuclear Regulatory Commission in the matter 5 of: ADVISORY OCNMITI'EE ON REACIOR SAFEGUARDS 0 N"***
353 rd GE2ERAL fEEH'ING 7
8 Docket Number: -
9 Place: Bethesda, Maryland 10 Date: September 7, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and,
-A
'() 14 thereafter reduced to typewriting by me or'under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings.
18 /s/ h M E 19 (Signature typed) :
20 Official Reporter 21 Heritage Reporting Corporation 22 23 1 24 1 25 O
LJ Heritage Reporting Corporation l (202) 628-4888 i
t i
- n. _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ . . _ _ . _ . __ ._ _ _ _ _ _ .._. ____ ___. _______.__ ________J
.O RES STAFF PRESENTATION TO THE ACRS- i i
1
SUBJECT:
REVISION TO THE C0 MISSION'S POLICY STATEMENT ON MAINTENANCE DATE: SEPTUBER 7, 1989 PRESENTER: THOMAS L. KING O
PRESENTER'S TITLE / BRANCH /DIV: CHIEF, ADVANCED REACTORS AND GENERIC ISSUES BRANCH DIVISION OF REGULATORY APPLICATIONS PRESENTER'S NRC TEL. NO.: (301) 492-3765 SUBCOMMITTEE: FULL COMITTEE O -
PURPOSE OF BRIEFING
. . (~'s u) 0 TO BRIEF THE ACRS ON THE STAFF PLANS, STRATEGY AND SCHEDULE FOR RESPONDING TO THE COMMISSION'S JUNE 26, 1989 SRM ON MAINTENANCE.
O TO BRIEF ACRS ON THE CONTENT OF A PROPOSED REVISED POLICY STATEMENT ON MAINTENANCE.
O ACRS LETTER IS REQUESTED ON THE REVISED POLICY STATEMENT.
( -
D 8
O -
l 1
r._
(f
[.
[l
.. w/
BACKGROUND 0 PROPOSED FINAL RULE ON MAINTENANCE AND DRAFT REG GUIDE PROVIDED FOR COMMISSION ACTION IN SECY-89-143, DATED APRIL 28, 1989.
O COMMISSION RESPONDED VIA SRM, DATED JUNE 26, 1989.
O 4
e 0 -
2
t l
l
(~') JUNE 26, 1989 SRM !
. A/ j i
s 0 ISSUE REVISED' POLICY STATEMENT. 1 i
o PUBLISH DRAFT REG GUIDE FOR COMMENT. DEVELOP FINAL REG GUIDE IN TIME FOR ISSUANCE WITH A RULE.
O PROCEED WITH VAllDATION AND IMPLEMENTATION OF AEOD MAINTENANCE EFFECTIVEN3SS INDICATOR. INv1TE VOLUNTARY PARTICIPATION OF LICENSEES IN A DEMONSTRATION PROJECT.
ESTABLISH CRITERIA TO DETERMINE WHEN A PLANT SPECIFIC I)O
~
ORDER OR OTHER ENFORCEMENT ACTION SHOULD BE TAKEN UNDER THE POLICY STATEMENT. IDENTIFY ANY CHAN5ES NEEDED IN THE REGULATIO! ..
O CCORDINATE WITH AND OBTAIN ACRS VIEWS.
3
g, . . - _ - _
!E i'
b:
h I > STRATEGY O PUBL1SH REVISED POLICY STATEMENT IN 10/89.
0- WORK'0N STANDARD (IN THE FORM OF A DRAFT REG. GUIDE.) AND
~
HAVE IT AVAILABLE FOR USE PRIOR TO END OF-18-MONTH PERIOD.
O ~ PROVIDE'AN OPTION FOR INDUSTRY TO PROPOSE THE STANDARD.
O ENCOURAGE. VOLUNTARY INDUSTRY ADOPTION OF STANDARD.
O BASED ON INDUSTRY IMPROVEMENT AND COMMITMENTS, RECOMMEND BY 4/91 ANY ADDITIONAL REGULATORY ACTION.
O PROVIDE FINAL DRAFT REG GUIDE AND RULE Tb COMMISSION FOR INFORMATION PRIOR TO END OF 18-MONTH EVALUATION PERIOD (JAN.-1991).
i
+
Q .
4
_ =_ _ _ _ _ _ __ __ _ _ __- - -
,. i 1
Plan /Schidule
! T
. (O j 1989 1990 1991 1 4th 1st 2nT'Trd 4th 1st 2nd Policy Statement:
--To commission U (9/89) !
i j
---Publish CR- V(10/89)
Reg. Guide ;.velopment: l
--FRN on R.G.
Availability (8/17/89)
--Comment Period (12/f/89)
--Revise R.G.
--FRN on revised R.G. (3/90_)
availability and workshop V(4/90l
--Workshop T
--Revise R.G. '
--Issue for voluntary industry adoptfon d use and feed back -
p Industry Proposed Standard Option:
Subs.it Workshop To Comm. To Comm.(1/91)
--To be endorsed in Reg. Guide T T IV PC T I
--Industry voluntary standard Submit Workshop To Com. Adoption and Maintenance performance Indicators:
anduse(10/90!
-- AEOD developed indicator T - 10/89 - report l l >
- Demonstration Project 7 - 9/12/89 - scoping meeting I Enforcement Criteria:
--Proposal to Comission 9 (9/89; Recommendation to Commission:
--5ubmittal of final rule and (1/91)
R.G. for Comission review' Y
-- Submit final staff recomm. (4/91) on the need for additional y regulatory action Maintenance Team Inspections: (12/89) (7/90) (4/91)
-W s tus ,
' T T (555; (785) (100%)
s
,. _ 7 -
y.
{}; LSRM GUIDANCE FOR REVISING POLICY STATEMENT ON MAINTENANCE RULEMAKING IS TO BE HELD IN ABEYANCE-FOR 18 MONTHS FROM THE DATE OF THE REVISED POLICY STATEMENT WHILE INDUSTRY PROGRESS IN MAINTENANCE IS MONITORED.
EMPHASIZE NEED FOR CONTINUED IMPROVEMENT IN MAINTENANCE.
ENCOURAGE EXPANDED USE OF NPRDS.
ENC 0JRAGE INDUSTRY ASSISTANCE IN DEVELOPING AND VOLUNTARY ADOPTION CF A STANDARD FOR MAINTENANCE.
ENCOURAGE FURTHER DEVELOPMENT AND USE OF MPIS.
- ' INDICATE INTENTION TO ISSUE PLANT SPECIFIC ORDERS, WHERE-THERE IS POOR OR DECLINING PERFORMANCE.
.lDENTIFY PRINCIPAL ELEMENTS OF AN ACCEPTABLE MAINTENANCE PROGRAM.
e 1
0 -
6
_ = _ _ _ _ - _ _ _ - _ _ _ - _ - .
^
. '. REVISED POLICY STATEMENT 0 COMMISSION TO HOLD RULE IN ABEYANCE-FOR 18 MONTHS..
O ADDITIONAL IMPROVEMENT NEEDED:
ENGINEERING SUPPORT RECORD KEEPING TRENDlhG-ROOT CAUSE ANALYSIS-USE OF PREVENTIVE AND PREDICTIVE MAINTENANCE O LICENSEES RESPONSIBLE FOR IMPROVEMENT. NUMARC AND INPO
.CAN PROVIDE INDUSTRY-WIDE LEADERSHIP.
O COMMISSION WILL TAKE APPROPRIATE ENFORCEMENT ACTION WHERE THERE IS POOR OR DECLINING MAINTENANCE PERFORMANCE:
EMPHASIZE ENFORCEMENT OF EXISTING REQUIREMENTS PLANT SPECIFIC ORDER CORRECT,lVE ACTION PLANS O SOLICITS INDUSTRY AND PUBLIC ASSISTANCE IN DEVELOPING A STANDARD FOR MAINTENANCE: l J
L l
+
_ ______._________._._.________________U
L-p I REVISED POLICY STATEMENT (CONT'D)
([
DRAFT R.G. AND SUPPORTING REGULATORY ANALYSIS ISSUED FOR COMMENT 8/17/S9.
- INDUSTRY COULD PROPOSE AN ALTERNATIVE (BY MARCH 1,1990):
ENDORSE VIA-R.G. CR VOLUNTARY INDUSTRY ADOPTION AFTER NRC REVIEW.
- -WANT STANDARD AVAILABLE IN ~ ONE YEAR TO ALLOW ADOPTION, USE AND FEEDBACK.
ENCOURAGE VOLUNTARY INDUSTRY ADOPTION OF STANDARD.
0 ENCOURAGES EXPANDED USE OF NPRDS, INCLUDING TIMELY AND COMPLETE REPORTING.
O STATES COMMISSION'S INTENT TO DEVELOP AND USE MAINTENANCE EFFECTIVENESS INDICATORS AND ENCOURAGES LICENSEE AND INDUSTRY DEVELOPMENT AND USE OF MAINTENANCE EFFECTIVENESS INDICATORS.
O RESTATES E,LEMENTS OF AN ACCEPTABLE MAINTENANCE PROGRAM FROM PROPOSED FINAL ROLE WITH THE ADDITION OF ELEMENTS ON:
RELIABILITY CENTERED MAINTENANCE ROOT CAUSE ANALYSIS J
O -
SCOPE INCLUDES ALL SSCS WHOSE FAILURE COULD IMPACT ]
PUBLIC HEALTH OR SAFETY.
8 e a
- g. , _ - _ - . ._
t s
j'.!
REVISED P01. ICY' STATEMENT. (CONT'D) 1 O- MONITOR IMPROVEMENT OVER NEXT 18 MONTHS AND DETERMINE NEED
'FOR. ADDITIONAL REGULATORY ACTION. RECOMMENDATION TO BE BASED ON:
- INSPECTIONS (MTI, SALP), INCLUDING REVISIT TO SELECTED SITES' LICENSEE AND INDUSTRY SUPPLIED-INFORMATION
-- LICENSEE: COMMITMENTS, INCLUDING COMMITMENT TO AND USE OF A COMPREHENSIVE STANDARD.-
MAINTENANCE INDICATOR INFORMATION o
O e
O -
9
g- -
c: : p 7
Q;, .
- ,; 1,,/ l l
STATUS OF LICENSE RENEWAL RULEMAKING PRESENTED BY KARL KNIEL, CHIEF
.. REACTOR AND PLANT SAFETY ISSUES BRANCH O orv1S10N OF SArETY 1SSUE RESOLrT10N OFFICE OF NUCLEAR REGULATQRY RESSARCH U.S. NUCLEAR REGULATORY COMMISSION SEPTEMBER 7, 1989 R-s ..
h l ...
l:
O- _ _ _ - _ - _ - - _
1
,a 50'
- OBJECTIVE
- o. ' PROVIDE STATUS
- o- IDENTIFY IMPORTANT ISSUES O o PRESENT PROPOSED PROGRAM PLAN AND SCHEDULE .
r 6
e i
O -
~ h. A_____.id_______..m__.__ _ . _ _ _ _ _ _ . _ _ _ . _
W . .
y s
j col:
I GENERAL APPROACH-
- h; o RULEMAKING -
-' - .o REGULATORY GUIDES 1
o INDUSTRY TECHNICAL REPORTS LO-o LEAD PLANT ACTIVITIES ,
. i e
l_
O -
5 m_ _ _ _ . _ _ _ . _ . _ . _ _ _ _ - _ _ . _ . _ _ . _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . . . _ _ . _ _ . . _ - -
i
' '~'
PREVIOUS MILESTONES o NOTICE ON PROPOSED POLICY j DEVELOPMENT NOV. 6, 1989 j o SECY-87-179, STATUS OF STAFF ACTIVITIES TO DEVELOP A LICENSE RENEWAL POLICY, REGULATIONS AND LICENSING GUIDANCE AND TO REPORT ON PUBLIC COMMENTS JULY, 21, 1987 o SECY-88-180, LICENSE RENEWAL RULEMAKING JUN. 27, 1988 o ADVANCE NOTICE OF PROPOSED
() RULEMAKING AND NUREG-1317,
" REGULATORY OPTIONS FOR NUCLEAR PLANT LICENSE RENEWAL," AUG. 29, 1988 o NUREG/CR-5332, "
SUMMARY
AND ANALYSIS OF PUBLIC COMMENTS ON NUREG-1317" o BRIEFING TO THE COMMISSION ON STATUS OF RULEMAKING, JUN. 22, 1989 o INITIAL DRAFTS HAVE BEEN COMPLETED OF PROPOSED RULE REGULATORY ANALYSIS
, ENVIRONMENTAL ASSESSMENT U
p -
4
. .\n .)
CURRENT RULEMAKING ACTIVITIES o IDENTIFICATION AND RESOLUTION OF TECHNICAL AND PROCEDURAL ISSUES FOR RULE o REFINING DRAFT OF PROPOSAL RD'LE r{) o CONCURRENT REVISIONS TO REGULATORY ANALYSIS .-
o EXPAND ENVIRONMENTAL ASSESSMENT g
n
. q,) .
BASIC ASSUMPTIONS o ADEQUACY OF LICENSING BASIS o REQUIREMENTS AIMED AT
() PREVENTING DEGRADATION OF LEVEL OF SAFETY .-
f
.. \
i e*
'I O)
~
1 I
l l
E L ._ _ _ _ - - _ _ _ _ . _ - 1
4
. q/
MAJOR ALTERNATIVES CONSIDERED A. CURRENT LICENSING BASIS (ORIGINAL LICENSING BASIS, AS AMENDED UP TO THE DATE OF RENEWAL APPLICATION)
B. EXTENSION OF A TO REQUIRE ASSESSMENT AND MANAGEMENT OF AGING, GUIDED IN PART BY A PLANT-SPECIFIC PRA C. EXTENSION OF B TO REQUIIE
() ASSESSMENT OF DESIGN DIFFERENCES AGAINST SELECTED NEW PLANT STANDARDS D. REQUIRE COMPLIANCE WITH ALL NEW-PLANT STANDARDS
(]
l
l -l 0 f
.t .
u TIMELY RENEWAL o 10 CFR:2.109 - AT LEAST-30 DAYS PRIOR TO EXPIRATION o CONSIDERED UP TO FIVE YEARS PRIOR
- o. TWO YEAR REVIEW PLUS HEARING p TIME o CENTRAL ISSUE HOW LOND BEYOND 40 YEARS CAN SAFE OPERATION BE ASSURED WITHOUT RENEWED LICENSE?
e4 g ..
()
L NEPA o ENVIRONMENTAL ASSESSMENT (EA)
- PROGRAMMATIC TO SUPPORT FINDING OF NO SIGNIFICANT ENVIRONMENTAL IMPACT FROM RULEMAKING
- LIMITED GENERIC TO SUPPORT DEVELOPMENT OF REGULATORY GUIDE
(')
'~'
- PROVIDE BASIS FOR ALLOWING EA FOR RELICENSING ACTIONS o GENERIC ENVIRONMENTAL IMPACT STATEMENT (GEIS)
- CONSIDERING POTENTIAL TO DISPOSE OF NEPA ISSUES THROUGH SEPARATE PART 51 RULEMAKING e
o . .
V w
k: -)
SEVERE ACCIDENT ISSUE CLOSURE r
o CASE BY. CASE I.E., IPE, CPI, ACCIDENT MANAGEMENT o SEPARATE RULEMAKING o PART OF LICENSE RENEWAL RULE O-
[
o ..
w ._ --
l
(.
V..
r-p).
s l
BACKFIT RULE o REQUIREMENTS DEFINED BY LICENSE RENEWAL RULE' o REQUIREMENTS BEYOND.
LICENSE RENEWAL RULE
- O
- ;
f O -
ko\ .z.---_--_.-,a- - - - , . .---.--_ - - - - - - - - - - _ _ _ _ - _ - - - - - - . - - - - . _ - - - - . _ _
m_
I I
PROBABILISTIC RISK ASSESSMENT 4
o APPROPRIATE RULE IN REVIEW IDENTIFY. SAFETY SIGNIFICANT
' STRUCTURES; SYSTEMS, COMPONENTS g SUBJECT TO. AGING DEGRADATION-
- VERIFY CONTINUED-ACCEPTABILITY OF-CURRENT LICENSING BASIS STANDARDS OF ACCEPTABILITY o'
e*
IO -
p n.
! i l
i l LENGTH OF RENEWAL TERM o JUSTIFICATION CASE-BY-CASE o- 20 YEARS VS 40 YEARS MAXIMUM BEYOND CURRENT TERM Q o CENTRAL ISSUE - CONFIDENCE IN PREDICTING SAFE OPERATION
~~
.BEYOND 20 YEARS o*
g ..
O
.__._.__._m_L5._._-__.__m__ _ _ _ - _ . _ . _ __ _ _ _
E ' : '
EARLIEST-DATE OF APPLICATION o CONSIDERED 15 AND 20 YEARS PRIOR TO EXPIRATION OF
-CURRENT TERM o -UTILITIES NEED 10-12 YEARS
-'O FROM PLANNING o FLEXIBILITY TO EVEN O T NRC RESOURCES o CENTRAL ISSUE - CONTRIBUTION Of ADDITIONAL YEARS OF OPERATION TO LICENSE RENEWAL REVIEW e
IO -
w_ - - - - -
w, , ~
.n E.
f's
.u ;
1P rogram Plan for the-completion of L License Renewal Rulemaking as proposed E
to the Commission
- Prepare a rule modifying the current licensing basis as necessary to assure assessment and control of safety q significant aging degradation of j structures, systems and components during the extended plant life. The current licensing basis means the basis on which a plant is licensed to operate under its initial license, as amended, at the time an application for a renewal
{} license is tendered.
- Prepare a single generic environmental impact statement to cover the rulemaking and to limit the number of issues subject to litigation in individual relicensing actions.
- Completely resolve severe accident issues on each plant before granting a renewed license except that for the earliest submittal, including the two lead plants, deal with these issues on a case-by-case basis.
O -
'> Program Plan Continued
- Prepare for and conduct a workshop in November 1989 to solicit public comments on specific technical issues and the scope of the Generic Environmental Impact Statement.
- Prepare Regulatory Guides necessary for an applicant to have a complete understanding of the staff's expectation relative to the content of a renewal application on the same schedule as the final rule.
(}
- Prepare other Regulatory Guides, which are derived from the Aging Research Program and operating experience as relevant technical information becomes available.
- Review industry technical reports and adopt regulatory positions as appropriate.
- Review two Lead Plants and use experience and information developed in formulating the final rule and regulatory guides I
1 l (D i
l l
^
- f}-
w AGING MECHANISM FATIGUE / VIBRATION EROSION CORROSION WEAR
. RADIATION EMBRITTLEMENT O- THERMAL EMBRITTLEMENT
~~
CHEMICAL EFFECTS CREEP / SWELLING u DEGRADION DUE TO OPERATIONAL ENVIRONMENT e
e O -
E-
,m .
p_ 4 L
h, p
4 i
APPROACH TO TECHNICAL ISSUES l
- DEFINE' MAJOR AGING CATEGORIES
- - IDENTIFY EXISTING PROGRAMS THAT
. - ADDRESS AGING ISSUES ON A PERIODIC
. BASIS.
O* COMPARE TnE Ex1ST1NG PROGRAMS w1Ta
. THE AGING CONCERNS ,,
- - IDENTIFY ADDITIONAL AREAS NOT COVERED BYLTHE EXISTING PROGRAMS t . .-
d' O -
um.--. -__l - - - - - u.--- - -
n
} ;< ,
- APPLICABL'E PROGRAMS IN SERVICE TESTING-IN. SERVICE ~ INSPECTION INTERGRANULAR STRESS CORROSION CRACKING APPENDIX J CODES AND STANDARDS (50.49)
STATION BLACKOUT RULE O .
CODES AND STANDARDS (50.55a) ,
TECHNICAL. SPECIFICATIONS BULLETINS AND GENERIC LETTERS EROSION / CORROSION
-BORIC ACID MOTOR OPERATED VALVES
' SERVICE WATER SYSTEMS THIMBLE TUBE WEAR TENDON INSPECTION STEAM GENERATOR TUBE INSPECTION O -
1 l
i
- _ -___---_--__ _ _- _ _ __ _ _ _ A
ur
. l
( ..:
MAJORLDOCUMENTS SUPPORTING LICENSE RENEWAL RULEMAKING L 'o . RULE
. o- STATEMENT OF CONSIDERATIONS o REGULATORY' ANALYSIS o REGULATORY GUIDE (S) o STANDARD REVIEW PLAN
() o GENERIC ENVIRONMENTAL IMPACT STATEMENT ,
o . REGULATORY POSITIONS ON INDUSTRY TECHNICAL REPORTS o REGULATORY POSITIONS ON TOPICS RE
. LEAD PLANTS e
1 Q .-
L-l_----__.----.-- - . . - - . _ _ - - - . - . . - - - - . . - = - - - _ _ _ . ._ ._.. _ _ _ _ _ . _ . - _ _.
gf x
l,h MAJOR MILESTONES FOR LICENSE RENEWAL RULEMAKING-PROPOSED RULE PACKAGE-COMPLETE FOR REVIEW: 2/90 PROPOSED RULE PACKAGE TO ACRS/CRGR 3/90 PROPOSED RULE PACKAGE TO COMMISSION 4/90 PROPOSED RULE PACKAGE PUBLISHED 5/90
~ DRAFT RGs,_SRPs, AND DRAFT GEIS PUBLISHED FOR-CMMENT. 12/90 FINAL RULE PACKAGE PUBLISHED li/ 92 e*
O -
__----.____.._____._._m._ -
Aby Y[ ,,
INTERNATIONAL DEVELOPMENT AND USE OF EVENT SEVERITY SCALE O Jack Heltemes Deputy Director, AEOD Presentation to ACRS O 8*P'** b*' 7 '989
90 BACKGROUND
=
Many countries desire to improve public communication on operating events Severity scales offer a proposed solution similar to Richter scale for earthquakes
= mergen y resp nse and ther regulatory O
functions considered to be separate functions in some countries O
_- o
OL STATUS OF DEVELOPMENT AND 1 USE OF SEVERITY SCALES
=
France - Six-level scale in trial use since April 1988 i
= Japan - Nine-level scale in trial use since June 1989 0 . U.K. - Scale being considered a FRG - Scale being considered i
=
USA - Four-level scale in use for emergency response
= NEA/lAEA - Sponsored assessments and meetings O
O CHARACTERISTICS OF AN "lDEAL" SEVERITY SCALE
=
Be simple and intelligible
=
Applicable to any incident or accident Allow prompt classifications (within hours)
=
Provide consistency in event classifica-O tion Give good resolution of incidents and accidents
=
Have a sound technical basis Be consistent with emergency planning and notification system
=
Assure that a reasonable number of events are "on-scale"
~
=
Properly reflect severity of past events l O I
9 ELEMENTS INVOLVED WITH SEVERITY SCALES Amount of radioactive material released
- May not correlate with harm
=
Offsite radiological impact
Needs defined methodology
- Onsite radiological impact O
=
- Public impact needs to be defined )
=
Economic impact due to damage or contamination 4
=
- No clear relationship to health l effects -
1
=
Potential for more serious consequences
- remaining margin of safety Considers near-misses O
d
Y v
SEVERITY SCALE FOR RATING NUCLEAR POWER PLANT INCIDENTS AND ACCIDENTS LEVEL.l DEFINITION - C R I T E R I A' EXAMPLES 6 Major accidents External release of a significant fraction of the Chernobyl,1986 -
core inventory in the form of fission products (equivalence m terms of iodine 131 : several hundred thousand to several million curies).
5 Accidents giving rise to Accidents necessitating off-site protective mea. Windscale,1957 off-site rislis sures in the event of re8 eases or the threat of Three Mile island,1979 releases equivalence in terms of iodine 131 :
several thousand to several ten thousand
- curies).
- l l 4 Accidentsin the Accident giving rise to external releases of the Saint Laurent A2,1980 installation same order of magnitude as the authorized an- (cf t
- riletmSNNo 74) nual limits, involvmg no significant health risks forthe public and/or partialcore damage and/or irradiation or radioactive contamina.
. tion of workers, at a, level requiring specialized medicalcare.
3 incidents affecting incidents giving rise to releases greater than or Sc;ey 5,1964 safety equal to one tenth of the authorized annual (cf. bulletins SNNo 40 limits &f6) and / or significant internal radioactive leaks and/or degradation of the safety barriers or
! systems a-and / or irradiation or radioactive contamination of workers to a level greater than the authori-zed annualdose 2 lacidentsliable to give incidents with potentiel consequences for sa- Fuel storage drum of
,, rise to subsequent fety i:i; :. ts Creys Malville,1987 and/or necessitating prolonged repairs or (cf. bulletins SNNoS6,60
. works. 4 v3) 1 Operationalanomalies Deviation from the domain authorized by the Tricastin,1987 technicalspecifications (cf. bulletin SNNoSS) and / or iustified use of safety systems.
O
,,..b en_ _ - -
ses* Inuesmer sungston eseny newwenso s pubb. -
ehed by vie nunmer m charge of maustry tmnus. Caude ROELS (comral wat for the sainy of 101.sve se Grenede 75007 Para dFrancet nuomarinstamanonu.
' se se rseduene et de ramenasemeu su ternup. Tel :(1) 45.%A93.
eif.101, me de Gsensee.15?IB Parn (Franet).
Dissantafdie : Pruducson : Denbunon uDocurnemamenFrances.
155N :01:24441 Midm!!,A
,, g held af sie(EnWEl 93rWttIOr Sie ,Quhan (Ppf (uninsuimen and conununicuson ges_prosentamon n*1 _ - _
.- Evatstien sen3e for Inef dor:ts and Failures 9f Nuclear Fowe _
Scale Criterion - 1 O- rar2o == < " *' 'iv-Critories - 2 Criterion - 3 c='2 == 4 <=0 ==> ' 5* *== r a *=>
Materials to the Outside Workers estated in of Reactor Facility Facility <
- Radiation related Works Case of ne significant _ _ .
Unplanned esposure dose .
rulsase of radioactira of workers essaged in Event which does not Level mazarials due to the ,related radiation related worka ' of reactor to the safety event to the outside ' facility 0 of reacter facility (hereafter called as
'uaplanned exposure")
le less than sesy Case of release of "Capleanal exposure" is radleactive saterials than Satt and less Event which does not Level due to the event to the morethan teste influence on the outsida af reaeter safety of reactor 1 facility and predicted facility but any radiation esposare dose relate to it at the outreatsding asalterlag area boundary is less thaa 0.03alv Level Predicted radiation "Unplaaned exposure" is saposure dose at the Event which does act 2 more t.han 10msv and less larlsence on the surroundlag asalterfag than 50aSt
- safety of reactor called as *pr'e(dictedarea boundary karoafter facility but relates 9 espoeste") is more than Oselate and less than to it
~0.08a&v ^
Level "Fredicted esposure is "Unplanand exposure" is 3 .
more thaa 0.0SaSe arid less thaa 0.!a89 more than 50 sty and less : on Event which influsaoss the safety of thaa 0.187 reactor facility Level
- Predicted esposare" is .
4 ' Unplanned esposura" is Event which emceeds
. more than 0. lass and loss thes last more than 0.15v and less the event of level-3 than 0.tSte Level l " Predicted exposure" is 5 " Unplanned exposare" is more than late and 2ess more shas 0.258v than 8str .
Level "Fredicted exposured is '
6
,j more than SaBv and less than least Level "Fredicted asposure' is _
7 more than 10msv and less thta 0.187 l Level *hwileted esposars" is g 8 ears than 0.357
O W 5 SNIS C PS C O I
1 E R O E PtA ND UI P P S
E I
O G 0 R P D N 0 RN R C
E S I
S' I D D 'I F OA FI O
F
'1 I Y A R P S S Y Y ESG ICN W ED E D B L Y OI P O RN C I
A P RBD A I D N E A E A E T RR Y F
A WFE C A EI P ,
OOI D C WU EI S P EK R I
D 0Q FG F FRN 1E AI O OII O N O NN IO E R SSE
/
A IS C I I NT ND N N SI A PF FT OIW O SAT CO OC ISO I
FS I
T DFA I E LI NUS N TED NOE H SU AFI O I R D' H A FS SF UOU IYC EIF F FI D I
I A I IF I
CFS I TRA R DWO O O R O AEU G
B N R AO'I DVQ D TAS SESO
'ICS OS SSN AOE RCI SISJ JS CSA GSA XDD EII IAIM OTDA AD NI ODL EIN BIP DDI N YY A OL DD I SA R RC DD II E EI T
I A XE PD EE II L FIDM DO G IE OEE P MR fU A A A TINT VIE A MM N / / / EPNIY /
E OS N N N CIST N MM SO RAMFI EE V RF SOAFL RR E EX A PE NIrOI ADf C 55 F I f 2 O RT RA0DAF IR0'I X I -
r L C I T I A E R
I K
GPC 3 P I
A I I R /
P S
H U N E
U NF TSW D U E I GD I I I O Q M E A' CO MIO M G D E R E M RO 0IA TO E I
C I
> O VCX >
B A NR OE P
U KYD
>L KE II L A
/
A
/
T E TD K ES N N II SR M ATE AU CNS A UE SR EID ICA EF AIA E FR IA E L O E ITI%LU FB R SP AR S0
% IDt DAO D
C CAH RCI C
R1 ARN R(I iM1.I 0I A RL0F D D E E
T Y G %'
A D C J
A R
I C
O E Y BY P I E I D R S X V R O ) EA) RE A I E BYE IDE I OI S V RI OMIT G N E I
ERT E EG O R T
CE I S MuS OMT M DFF t
T NI0IR I
R 2TU E AS S
) C E OM AO R OA IE MEF CO EEO B t I
E M
P B PRH RERI O P
DI M G MPG I S ISAN1 AE EEA SA T 1 AAPE 2 RR E CR RTP I>
0 P 0T< 0 0
E YLXNE NE OV 0 7
1S( 5A( 1 T AR2CO 5 R E GYC Y Y O T I C C 1 AR I NS AELN N IUr P EE E
( ) DOK R GS ERRG G -
T RP 3EHu O RS EAR N 20R 0 M4m EDEA NE SEN URADC GD I E IEE STRM CAE NE E V
l 7.0 C
@1P f3R E
- 4. I 2 H
$0** )
{
TABLE 1.
CMPARISCH OF FRENCil SEVERITY SCALES AND US SYSTEi45 FRENCH SEVERITY US REPORTING REQUIREMENT / EMERGENCY CLASS SCALE 50.72- UNUSUAL ALERT 50.73 SITE GENERAL 20.403 EVE!!T AREA EMERGENCY EMERGENCY 5
X x x
-O X X X
3 X X X
- X 1 X X BELOW ECALE X O ,
r____.__
- s. 3 J# *m.
L.J l
TABLE 2 US EVENT CLASSIFICATION
SUMMARY
(1)
I EVENT CLASSIFICATION YEAR 1983 1984 1985 1986 1987 1988 l 30 DAY WRITTEN --
2462 3034 2889 2908 2424 REPORTS (50.73)
UNUSUAL EVENT 205 224 312 209 231 212 r'h
()
ALERT 7 8 11 9 9 6 SITE AREA EMERGENCY 0 0 0 0 0 0 GENERAL EMERGENCY 0 0 0 0 0 0 Q
D E 4
4 .
- _ _ _ . _ _ _ _ . . _ _ . .Q
- a. -
1 4
O.
PRELIMINARY CONCLUSIONS
=
Scales can serve a useful purpose
Provides per.spective on safety importance Could. assist in comparing and communicating incidents
=
identical international scales are O unlikely Countries have differing needs and views Different scales already in existence Existing scales or incident reporting i
systems should not be changed e* Reeducation of public media and utilities
=
- Two scales could cause confusion O
O PRELIMINARY CONCLUSIONS (CONTINUED)
Parallel scale not needed in U.S. for public information purposes
= Raises opportunity for confusion Utilities and NRC have credibility with media O
Media understands current emergency classifications
=
- All event information available in PDR
- Rulemaking may be needed to assure participation O
G PROPOSED U.S. POSITION ON SEVERITY SCALES :
. The U.S supports such scales for countries without public notification systems L '
Public. information scales and emergency response scales should be O consistent
. U.S. has:
Established scale for emergency ,
response j
= = Open and prompt public i communication l
=
Thus, U.S. is unlikely to adopt another system for public information purposes O
F ;
.O U. S. NUCLEAR INDUSTRY ACTIVITIES FOR RESOLUTION OF SEVERE ACCIDENT ISSUES PRESENTED TO THE ADVISORY COMITTEE ON REACTOR SAFEGUARDS O
BY WILLIAM H. RASIN, DIRECTOR TECHNICAL DIVISION NUCLEAR MANAGEMENT AND RESOURCES COUNCIL SEPTEMBER 8, 1989 Q
NUMARC SEVERE ACCIDENT ISSUE ACTIVITIES o SEVERE ACCIDENT WORKING GROUP o INDIVIDUAL PLANT EXAMINATIONS (IPE) o IPE OF EXTERNAL EVENTS FIRE EVENTS O -
SEISMIC EVENTS OTHER EXTERNAL EVENTS l
o CONTAINMENT PERFORMANCE IMPROVEMENTS PROGRAM l
o ACCIDENT MANAGEMENT o CLOSURE PROCESS O
l
n L
, Q NUMARC SEVERE ACCIDENT WORKING GROUP i MISSION STATEMENT TO COORDINATE INDUSTRY ACTIVITIES AND SERVE AS THE FOCAL POINT FOR INDUSTRY /NRC INTERACTIONS IN' ATTAINING RESOLUTION AND CLOSURE OF THE SEVERE ACCIDENT' ISSUE, INCLUDING:
0 INDUSTRY RESPONSE AND IMPLEMENTATION OF THE ERC'S GENERIC LETTER ON IPES O
O DEFINITION, DEVELOPMENT AND IMPLEMENTATION OF SEVERE ACCIDENT MANAGEMENT PROGRAMS l
0 CONSIDERATION OF THE NEED FOR INDIVIDUAL PLANT EVALUATIONS OF EXTERNAL EVENTS; AND THE DEVELOPMENT AND IMPLEMENTATION OF APPROPRIATE METHODOLOGIES, IF NECESSARY THE WORKING GROUP WILL ALSO FOCUS ON INDUSTRY /NRC DIALOGUE AND DEVELOP INDUSTRY POSITIONS, AS NECESSARY, FOR: CONTAINMENT PERFORMANCE, SAFETY GOAL IMPLEMENTATION, AND SOURCE TERM RESEARCH.
1
NUMARC SEVERE ACCIDENT WORKING GROUP MEMBERSHIP o MR. CORDELL REED, SENIOR VICE PRESIDENT, COMMONWEALTH EDISON COMPANY, CHAIRMAN o NR. JOHN C. BRONS, EXECUTIVE VICE PRESIDENT-NUCLEAR GENERATION, NEW YORK POWER AUTHORITY o MR. JAMES C. DEDDENS, SR. VICE PRESIDENT RIVER BEND NUCLEAR GROUP, GULF STATES UTILITIES DR. STEPHEN P. SCHULTZ, VICE PRESIDENT, YANKEE
(]) o ATOMIC ELECTRIC COMPANY o MR. HAROLD W. KEISER, SR. VICE PRESIDENT-NUCLEAR, PENNSYLVANIA P0k!ER & LIGHT COMPANY i
o DR. RICHARD E. SKAVDAHL, SERVICES GENERAL MANAGER-ENGINEERING SERVICES, GENERAL ELECTRIC COMPANY o MR. EDWIN J. WAGNER, DIRECTOR-NUCLEAR ENGINEERING, BOSTON EDISON COMPANY ,
-Q
lO menc '
SEVERE ACCIDENT WORKING GROUP MEMBERSHIP (CONTINUED) o MR. KENNETH S. CANADY, ENGINEERING MANAGER- 4 NUCLEAR ENGINEERING, DUKE POWER COMPANY !
o MR. GARY FADER, PLANT ANALYSIS DEPARTMENT MANAGER, INSTITUTE OF NUCLEAR POWER OPERATIONS o MR. WILLIAM J. JOHNSON, MANAGER-NUCLEAR SAFETY DEPARINENT, WESTINGHOUSE ELECTRIC CORPORATION i
o MR. S. JOSEPH K0WALSKI, VICE PRESIDENT-NUCLEAR ENGINEERING PHILADELPHIA ELECTRIC 0 COMPANY o DR. C. FREDERICK SEARS, VICE PRESIDENT-NUCLEAR
& ENVIRONMENTAL ENGINEERING, NORTHEAST UTILITIES SERVICES COMPANY o MR. JOHN J. TAYLOR, VICE PRESIDENT-NUCLEAR POWER, ELECTRIC POWER RESEARCH INSTITUTE o MR. BART D. WITHERS, PRESIDENT & CHIEF EXECUTIVE OFFICER, WOLF CREEK NUCLEAR OPERATING CORPORATION O l
o
.b SEVERE ACCIDENT ISSUES IPE IMPLEMENTATION (INTERNAL EVENTS) o INTERACT WITH NRC STAFF TO CLARIFY INDUSTRY CONCERNS ON GL 88-20, IPE METHODOLOGIES SERs AND NUREG 1335 o UTILITIES TO EXPEDITIOUSLY BEGIN IPEs, CONSISTENT WITH SCHEDULE IN GL 88-20 o EACH UTILITY TO DEVELOP DECISION CRITERIA FOR IMPLEMENTATION OF CHANGES. NRC STAFF TO JUSTIFY OTHER CHANGES VIA COST BENEFIT ANALYSES O
o GUIDELINES WHICH PROVIDE A METHODOLOGY FOR EVALUATION AND DISPOSITION OF IPE INSIGHTS AND IDENTIFICATION OF POSSIBLE PROCEDURAL AND/0R HARDWARE ENHANCEMENTS o INCREASE NRC STAFF AWARENESS OF IMPROVEMENTS MADE TO MAAP CODE SINCE IDCOR-NRC TECHNICAL EXCHANGES o IDENTIFY LEAD PROJECTS FOR EARLY SUBMISSION OF IPE REPORTS AND OBTAIN NRC COMMITMENT O FOR PROMPT REVIEW
1:
'b SEVERE ACCIDENT ISSUES IPE OF EXTERNAL EVENTS EXTERNAL EVENTS CATEGORIES o FIRE EVENTS o SEISMIC EVENTS o OTHER EXTERNAL EVENTS EXTERNAL FLOODING l -
HIGH WINDS O -
MAN-MADE HAZARDS E.G., TRANSPORTATION IDCOR POSITION ON EXTERNAL EVENTS o POTENTIALLY IMPORTANT EXTERNAL EVENTS CONSERVATIVELY TREATED IN DESIGN BASES OR EXAMINED EXTENSIVELY AS A GENERIC ISSUE o OTHER REGULATORY PROGRAMS ADDRESSING EXTERNAL EVENTS O
SEVERE ACCIDENT ISSUES IPE OF EXTERNAL EVENTS (CONT'D)
NRC INTERACTION ON EXTERNAL EVENTS o NO REQUIREMENT TO CALCULATE CORE DAMAGE FREQUENCIES o DEVELOP ALTERNATIVE METHODOLOGIES FOR IPE OF EXTERNAL EVENTS IPE OF SEISMIC EVENTS:
Qo EPRI SEISMIC MARGINS EVALUATION METHODOLOGY ACCEPTABLE WITH "SOME FINE TUNING" o NUMARC/NRC TO DEVELOP METHOD FOR DETERMINING A SINGLE SITE SPECIFIC REVIEW LEVEL GROUND MOTION o NUMARC/NRC TO EVALUATE THE EFFECTS OF HIGH FREQUENCY GROUND MOTION AND AGREE ON APPROPRIATE DISPOSITION o NUMARC/SOG DESIRE SEPARATE CLOSURE OF EASTERN SEISMICITY (CHARLESTON EARTHQUAKE) ISSUE O
l SEVERE ACCIDENT ISSUES IPE OF EXTERNAL EVENTS (CONT'D)
IPE OF FIRE EVENTS:
1 o UTILITY TO PERFORM AN EVALUATION OF EACH PLANT'S VULNERABILITY TO FIRE EVENTS o " COOPERATIVELY" DEVELOP WITH NRC STAFF AN ALTERNATIVE FIRE EVALUATION METHODOLOGY o CONTINUE DIALOGUE WITH NRC STAFF TO INTEGRATE INTO FIRE IPE CONSIDERATION OF APPROPRIATE SANDIA FIRE RISK SCOPING STUDY FINDINGS .
O IPE OF OTHER EVENTS:
o PERFORM SCREENING OF THE FOLLOWING OTHER i EXTERNAL EVENTS: HIGH WINDS, TORNADOES, FLOODING AND TRANSPORTATION l
o DEVELOP SCREENING METHODOLOGIES TO EVALUATE ON A PLANT-SPECIFIC BASIS THE EFFICACY OF THE EXTERNAL EVENT DESIGN BASES o REQUIRE NO SCREENING OR EVALUATION FOR ,
EXTERNAL EVENTS OTHER THAN SEISMIC, FIRE AND THOSE IDENTIFIED AB0VE O
O '
SEVERE ACCIDENT ISSUES CONTAINMENT PERFORMANCE IMPROVEMENT PROGRAM o RECOMMEND PLANT CONTAINMENT PERFORMANCE ISSUES BE SUBSUMED INTO IPE Qo NRC STAFF GENERIC CONTAINMENT PERFORMANCE IMPROVEMENT PROGRAM NOT APPROPRIATE o
o_
1 SEVERE ACCIDENT ISSUES INDUSTRY ACCIDENT MANAGEMENT APPRDACH o USE IPE RESULTS AND OTHER INFORMATION (E.G.
IDCOR, EPRI, NRC) AND UNDERSTANDINGS AS A GUIDE FOR INTEGRATED DEVELOPMENT OF PLANT-SPECIFIC ACCIDENT MANAGEMENT PROGRAMS o UTILIZE RESOURCES KYATLABLE TO PLANT STAFF, I E.G.:
(]y -
SUPPLEMENTAL TECHNICAL STAFF TRAINING NON-SAFETY RELATED EQUIPMENT UTILIZATION REC 0VERY OF FAILED EQUIPMENT l
c_--
l
-( I SEVERE ACCIDENT ISSUES ACCIDENT MANAGEMENT o NRC GENERIC ACCIDEPP' MANAGEMENT STRATEGIES TO BE EVALUATED AT THE SAME TIME AS IPE INSIGHTS o SCOPE OF ACCIDENT MANAGEMENT TO INCLUDE ONLY I THOSE ACTIONS TAKEN AND/0R PREPARATIONS TO I SUPPORT ACTIONS TAKEN DURING THE COURSE OF SEVERE ACCIDENTS BY THE PLANT STAFF o GUIDELINES WHICH PROVIDE A METHODOLOGY FOR EVALUATION OF A UTILITY'S ACCIDENT MANAGEMENT l CAPABILITIES AND IDENTIFICATION-OF FURTHER g POSSIBLE PROCEDURAL AND/OR HARDWARE ENHANCEMENTS o EACH UTILITY TO DEVELOP OWN DECISION CRITERIA FOR IMPLEMENTATION OF ACCIDENT MANAGEMENT ENHANCEMENTS o TECHNICAL GUIDANCE AND/0R METHODOLOGY FOR HANDLING SPECIFIC ACCIDENT STATES BEING DEVELOPED, AS APPROPRIATE, SEPARATE FROM THE NUMARC ACCIDENT MANAGEMENT GUIDELINES o IDENTIFY LEAD PROJECTS FOR EARLY IMPLEMENTATION OF ACCIDENT MANAGEMENT PROGRAMS AND OBTAIN NRC COMMITMENT FOR i
() PROMPT REVIEW
4
^
' ~
SEVERE ACCIDENT ISSUES SEVERE ACCIDENT CLOSURE PROCESS o ACHIEVE PRACTICAL CLOSURE OF SEVRE ACCIDENT ISSUES o CONSIDERATION OF INDUSTRY-WIDE CLOSURE CRITERIA Q -
QUANTITATIVE PHILOSOPHICAL l
o CONSIDERATION OF PLANT-SPECIFIC CLOSURE CRITERIA l
- - - _ _ . - - _ _ - _ - _ _ . _ _ _ _ . _ _ _ _ _ _ _ - . . _ _ -