ML20249C435
| ML20249C435 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/1998 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3044, NUDOCS 9806290334 | |
| Download: ML20249C435 (155) | |
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The: contents of.this transcript of the proceeding--
.of1EheL: United. States. Nuclear Regulatory Commission. Advisory t
b.?(
Committee'on ReacboriSafeguards,.taken on' June 19, 1998,o as reported;herein',Vis a' record of,the di'scussions recorded.at o
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..the: meeting' held.on.the~above.date.
Ll; This-transcript.:had not.been reviewed, corrected
.and edited and it.may contain inaccuracies.
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UNITED STATES NUCLEAR REGULATORY COMMISSION O
2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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' SUBCOMMITTEE ON
-5 PLANT OPERATIONS 6
7
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'8; U.S. Nuclear Regulatory Commission.
9 Two White Flint North 10 11545 Rockville Pike 11
.Rockville, Maryland 20852-2738 12 13
. Friday, June 19, 1998 14' i 1
15 The Committee met pursuant to notice at 8:32 a.m.
16 17.
MEMBERS PRESENT:
18-JOHN BARTON,. Chairman,.ACRS 19E DANA A.
POWERS, Member, ACRS 20
' ROBERT E. UHRIG, Member, ACRS 21-ROBERT L.
SEALE, Member, ACRS
'22 DON W.. MILLER,-Member, ACRS 23 GEORGE E. APOSTOLAKIS, Member, ACRS 124 MARIO'FONTANA, Member, ACRS 2 5_ -
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PROCEEDINGS 2
,_s l
[8:32 a.m.]
b 3.
CHAIRMAN BARTON:
Good morning.
The meeting will
~4 now come to order.
This is a meeting of the ACRS 5
Subcommittee on Plant Operations.
I am iohn Barton,
.6 Chairman of the Subcommittee.
7 ACRS members in attendance are:
George L
8 Apostolakis, Mario Fontana, Don Miller -- who will be~
9'
. joining us shortly, and Dana. Powers, Robert Seale, and l
1'0 -
' Robert Uhrig.
11 The purpose of.this meeting is to discuss proposed 12 changes to 10 CFR 50.59, status of resolution of issues 13 identified in the March 24th, 1998 Staff Requirements 14-Memorandum related to SECY-97-205 and related matters.
The r~Y 15 Subcommittee will gather information, analyze relevant
'3'~)~ ~.
16 issues and facts, and formulate proposed positions and 17 actions, as appropriate, for deliberations by the full 18 Committee.
Michael Markley is the cognizant ACRS Staff 19.
.EngineerLfor this meeting.
20-The rules for participation in today's meetings 21' have been announced as part of the notice of his meeting 22' previously published in the Federal Register on May 22nd, 23-1998.
24 A transcript of.the meeting is being kept and will 25 be made available, as stated in'the-Federal. Register notice.
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It'is requested that speakers first identify rm j )
2 themselves and speak with sufficient clarity and volume so 3
that they can be readily heard.
4 We have received no written comments or. requests 5
for time to make oral statements from members of the public.
6 As you can tell prior to even starting the 7
meetings, the Committee has got a lot of interest in the 8-status of the changes that are being proposed to 50.59 and I
. ould also tell you I think to some degree there is some 9
w 10 frustration on the Committee's part with respect to seeing 11:
progress being made to try to resolve this issue.
12 We have had several meetings with the staff.
We 13 have written letters to the EDO and reports to tbc
- airman 14 on this' issue, made some suggestions on which way to 15 proceed.
SRM was issued in March, which kind of was in line 16 where ACRS was at the time.
17 Subsequent to the SRM, we have reviewed the 18 Staff's response, which was described in the May 27th, 1998 19 memo to the Commission, and I think the disappointment in 20 the way the Staff had responded to the SRM in most cases is 21 obvious to the members of the Committee.
22 We can understand your point with respect to 23 accidents of a different type and that response, but most of
'24 the other issues that came out of the SRM you have taken 25 exception to, and decided either not to do anything or to do ANN RILEY & ASSOCIATES, LTD.
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1 something different than what tas submitted in the SRM, so l
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2 at this point I think the Committee is waiting with baited
'l' ' '
3' breath as to whether-are you really going.
l 4
This is an issue which we really didn't think
'5 needed a heck of a lot of fixing, and yet we can't seem to 6
see the path that is going to try to come to closure and get E
7 this-behind us.
8 George I think alluded to some suggestions we may 9
have.
We are trying to help this thing come to some kind of I
10 closure, so you may hear today some suggestions from the 11 Subcommittee that's going to make you think about a
'12 different approach or something, but at this time I will 13 turn it over to Eileen McKenna, and you are on the hot-seat 14 for telling us how you are going to solve this simple 15 problem.
16 MS. McKENNA:
I'm glad it's so simple.
As you
)
17 mentioned, I am Eileen McKenna, in NRR's Generic Issues and 18 Environmental Projects Branch.
We also have other members 19 of the branch with us today who may participate when I need 20 some help.
I have Tom Essig, who is the Acting Branch i
21 Chief, and Stu Magruder and Tom Bergman, who are two members 22 of the Branch.
l i
23' As you know, this is an issue that we have been 24 discussing for some time and I think at our last meeting 25 there was some expression that maybe it was appropriate to
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5 have a little bit of background discussion about where we l
1 2
have been and how we got to where we are.
The first couple 3
of slides I have were an attempt to do that, to kind of 4
recall what the role of 50.59 was in the regulatory process, 5
that it was meant to be a process for controlling changes y
6 that a licensee may make that would impact their licensing 7
basis and the. determination of whether the change was of a 8
nature that required opportunity for staff review, not of 9.
determination of whether the change was a safe or acceptable
-10 change to make.
i 11 I just had some bullets on the page and I'll ask I
l 12 l
you to refer to'your handout copies, because I think the 13' projectionist is not going show you, but I was trying to indicate here that the evolution of how these requirements 14 15 evolved.
Back in the '60s -- you have hazard summary 16 reports -- and in terms of the other column -- we got to the 17 point where there was -- because of all the -- the entire 18 hazard summary report in many cases became part of the 19 license, any change required an amendment and when it got to i.
20 Vallecitos it was a. license condition added that allowed 21 ~
1anguage somewhat similar to what the current 50.59 allows i
E 22 to allow for the licensee to make certain changes without 23 review provided the conditions were satisfied.
24 I think 1968 was a major date in the regulatory 25 process when the rulemaking was issued that both established ANN RILEY & ASSOCIATES, LTD.
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I think in large part how the licensing basis is defined by
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2 giving revised rules on content of FSARs, content of 3
technical specifications as in 50.36 and focusing on design 4
bases margins and the safety analyses for design basis 5
events, and at the same time there were revisions to the 6
50.59 rule that had been issued earlier that baiically 7
brought it up to the present day language that we see for 8
what constitutes unreviewed safety questions.
9 On one column I am changing I just noted a couple 10 of things with respect to the process by which changes to 11 the licensing basis occur, typically those were through the 12 license amendment process.
13 In terms of the other column, I think after '68 14 what you saw in practice was a lot of things going into tech
()
15 specs and there was a desire to control changes to certain 16 information.
That information was placed in the tech specs.
17 The tech specs grew and in some cases contained 18 information that really was not as suitable for the 19 operators in making their day-to-day operational decisions 20 as it may have been for other purposes, so as time went on 21 we came into the mid '80s, there was a re-look at what 22 belonged in tech specs and there were split reports in terms 23 of breaking apart the current type of tech specs and 24 retaining certain information in the tech specs and placing 25 other information in the FSAR.
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1 That then revitalized, if you will, the importance 2
of 50.59 process because that information was now in the
-(si
'~l 3
FSAR as opposed to the tech specs, so the process by which 4
changes would be controlled with 50.59, and that is really 5
what led to the development of guidance by the industry to 6
strengthen that process.
7 I have listed here in the column on establishing l
8 licensing basis a couple of areas where things started to 9
evolve from the deterministic design basis type approach on 10 establishing requirements to having some reflection of risk l
11 information.
The ATNS rule and the station blackout rule 12 were really promulgated largely on the basis of risk 13 information and I just had a note at the bottom that there 14 were other approaches to looking beyond design basis and
(~3 15 severe accident but they were not in generally made part of V
16 the licensing basis.
They were other issues that the licensee was asked to look at and see what kind of -- you 17 18 know, the IPEs and severe accident management type of 19 issues.
20 That kind of brings us up to the present day of we 21 had the guidance from NSAC that was being used.
Staff had 22 not converged on endorsement.
We got up to a few years ago 23 when questions about how the process was working, how well 24 the guidance satisfied the rule, and in looking closer at l
25 the language and how it was implemented, we got to the ANN RILEY & ASSOCIATES, LTD.
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issues that we saw that the rule as to the language as
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2 written was not the way it was maybe being implemented in 3
practice and then the question of how to resolve that 4
dichotomy arose.
That is where we are now at with respect l
5 to rulemaking.
6 DR. APOSTOLAKIS:
But I thought that there was 7
agreement between the Staff and the industry that the rule l
8 worked very well, so both the Staff and the industry did not 1
i i
9 apply'the rule the way it was written?
l 10 MS, McKENNA:
I think they perhaps in certain 11 instances that may be true.
12 DR. APOSTOLAKIS:
Which part of the rule was not j
)
13 applied the way it was written?
l 14 MS. McKENNA:
I think in certain aspects with the O)
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15 criteria as to when the review was required -- the 16 unreviewed safety question criteria.
17 DR. APOSTOLAKIS:
So as I recall, the rule says 18 that the probability and the consequences of accidents 19 should not change --
20.
MS. McKENNA:
That's. correct.
21 DR. APOSTOLAKIS:
That means and the lawyers
.22 interpreted that as zero change.
l
-23l MS. McKENNA:
Well, the words were --
24 DR. UHRIG:
Increase.
j>
25 DR. APOSTOLAKIS:
Do not increase.
I'm sorry --
1
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do'not increase.
2 MS.'McKENNA:
-- that there is an unreviewed 3
safety question if --
4 CHAIRMAN BARTON:
And that was interpreted as'zero 5
Lchange.
6J
'DR. APOSTOLAKIS:
By the lawyers, b
7 MS. McKENNA:
-- probability and the consequences
)
8 may be increased, yes.
-9.
'DR. APOSTOLAKIS:
Pardon?
10 DR. SEALE:
To be a little --
11:
DR. APOSTOLAKIS:
No, no.
I am confused now.
12' They should not' increased.
13 MS. McKENNA:
Right.
It would be considered an
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11'4 unreviewed safety question if the probability and
~ 15
' consequences may be increased is p;he' language.
16 DR. APOSTOLAKIS:
So was that the'part:that was 17 not really implemented that way?
18 MS. McKENNA:
That's-in large'part yes.
Yes.
'19 DR. SEALE: LI recall an original presentation we
~
1 20.
had on this topic in the recent past.
1 21 MS. McKENNA:
Yes.
'22 DR. SEALE:
In the member of sitting members, 23 okay?
24 MS. McKENNA:
Yes.
25 DR. SEALE:
The specific comment was that the NEI Q
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had some guidelines that I guess originally were whatever 2
the previous organization --
3 MS. McKENNA:
Yes, NSAC-125.
4 CHAIRMAN BARTON:
NSAC-125 was their first l
l 5
document.
6 DR. SEALE:
-- and that in general whenever the utilities followed NSAC-125 they kept their nose clean, and 7
8 it was only when they not only played fast, perhaps a little 9
fast and loose in interpreting 50.59 itself, but also when 10 they were cutting corners on 125 did you find situations 11 where you felt the interpretation was inappropriate and 12 there had been a failure to really review pertinent safety 13 issues.
14 Now that was what I recall from presentations a 15 year and a half ago --
16 MS. McKENNA:
Correct 17 DR. SEALE:
And at the time we raised the question 18 then, well, why don't you clean up any untidy parts of 125 19 that the Staff may worry about and use that as the vehicle 20 for arriving at a workable, mutually satisfactory approach 21 to the problem.
22 I guess that is as close as we have gotten to 23 agreement on anything.
24 MS. McKENNA:
Okay.
Just one clarification.
I 25 think --
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1 DR. SEALE:
Sure.
2 MS. McKENNA:
-- the message was that in general 3
following the process would lead to the right answers, but 4
there may be issues, cases even when they followed the 5
guidance that we would disagree with their conclusion.
6 For instance, the questions on increases in 7
consequences where the guidance would suggest that --
8 DR. SEALE:
Yes.
That issue didn't come up in i
l 9
sharp definition at the time --
10 MS. McKENNA:
No, correct.
- Correct, f
11 DR. SEALE:
-- but on the other hand, I don't i
12 recall that there were any examples cited where' utilities i
131 had followed 125 and still had had their wrists slapped 14 because they had not reviewed safety questions or whatever.
(
15 MS. McKENNA:
I would say that we have had some 16 cases, as I think we have talked abaut before, the more 17 common situation where licensees have'run into trouble is 18 when they have not performed evaluation at all.
19 CHAIRMAN BARTON:
Either haven't done one or --
20 MS. McKENNA:
Or it was inadequate in certain i
21 respects, right.
22 DR. SEALE:
And that is clearly not doing what the 23 requirements say.
24 CHAIRMAN BARTON:
Or missed the USQ in their 25 interpretation --
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1 MS. McKENNA:
Yes.
(\\ '
4 L
2 CHAIRMAN BARTON:
By doing a preliminary. screening
- l..x) 3e evaluation, missed a USQ --
4 MS. McKENNA:
That's right.
.5 CHAIRMAN BARTON:
So then there's been some of l
6
- those, j
7 DR. APOSTOLAKIS:
You audit those analyses that
'8 utilities do?
'9 MS. McKENNA:
Yes, our inspection staff or our 10.
project managers will review the 50.59 evaluations that' l
11 licensees have done both from their day-to-day as they are 12 following issues and looking at changes and then looking i
l 13'
.back to the packages to see how they occurred and also on an l
1 14 audit basis just to look at their process and pull' files, if Ag ~
15 you will, to see whether they implemented the rule I
'16 appropriately.
17 DR. UHRIG:
De the resident inspectors also take a 18, look at these?
.19 MS. McKENNA:
Well, that is what I was referring 20 ito in terms of kind of the first category is as --
L 211 DR. UHRIG:
Oh, okay.
l 22 MS. McKENNA:
-- as issues arise in day-to-day l-"
23:
operations where there may be a need for a licensee to 24 perform an evaluation, the residents would be reviewing did l
l 25 ~
theyLdo the evaluation, you know, what were the answers, but j
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t.
1 I was also indicating'there is a more programmatic, if you l
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2 will,. sampling review of evaluations performed over time.
3 DR. APOSTOLAKIS:
How many~of these does a plant 4
have' typically a year?
5 MS. McKENNA:
I'd say on the order of hundreds.
6 DR. APOSTOLAKIS:
So how long does it take 7
typically to do one of those?
j i
8 MS. McKENNA:
To do the inspection?
l i
l 9
DR. APOSTOLAKIS:
No, for the industry to actually
'10
-carry out 50.59 evaluation?
11 DR. UHRIG:
27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> I think is the number that is p
12 in the --
l 13 MS. McKENNA:
That was the number that was mentioned I believe at the Commission meeting --
14 n)
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15 DR. UHRIG:
Right.
16 DR..APOSTOLAKIS:
Is this the average?
17-MS. McKENNA:
As an average --
l'
~18 DR. UHRIG:
That-was an industry number.
19 DR. APOSTOLAKIS:
27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br />.
20 MS. McKENNA:
Obviously there is going to be a 21 range depending on the extent of the change.and what is 22 involved.
23 DR. APOSTOLAKIS:
And that includes everything, 24 documenting it'and --
25-DR. SEALE:
And the legal review and everything
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else.
2 CHAIRMAN BARTON:
Yes, preparing and reviewing the 3
safety evaluation.
j I
4 MS. McKENNA:
Yes.
5 DR. APOSTOLAKIS:
So in the large majority of 6
.these cases, it is obvious that the three requirements are 7
met?
i 8
It takes just a few minutes for people to say 9
feah, none of the three requirements of the rule is 10 violated?
1 l
11' MS. McKENNA:
I don't know an I would characterize 12 it as large majority.
I think there's again -- that there's l
1 13 probably some that it's very obvious, just the nature of the I
14 change and it's moving in a more conservative direction or
{
15 it is not impacting safety systems or those kinds of things 16 where you may be able to tell fairly quickly that it doesn't 17 relieve them of the responsibility to document the 18 evaluation but the extent of what needs to be examined could i
l 19
.certainly be less than if they were making a modification, 20 say, to a system that has a safety function, in which case 21 there may be more extensive evaluations that would need to 22.
be done to make sure that all appropriate interfaces in the
-23 interactions may have been considered in their evaluation.
0 l
l 24' DR. UHRIG:
There's even cases where utilities L
-25
.have been -- 50.59 reviews on change of personnel in the l/
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plant.
.2 MS. McKENNh:
That came up, I know, at the 3
Commission meeting.
I am not aware -- I have never seen 4
anything like that i
(
5 CHAIRMAN BARTON:
No, I'll tell you there's one 6
right now, and it is changing the plant manager at Fermi.
7 He was promoted to Vice President, no they are putting in a 8
license change because of that.
9 MS. McKENNA:
- Okay, I think there is a 10 difference.
I know this did come up at the Commission 11 meeting, that there may be a license change because the tech 12 specs may have established an organization chart or position 13 titles, that kind of thing, and if they are changing that k
14 L would involve a license amendment by virtue of it being in 15 the tech specs.
16 CHA7RMAN BARTON:
And that is the Catch-22.
It is 17 in their tech specs.
18 MS. McKENNA:
Yes -- but that is a little 19 differen'; from saying they needed to do an unreviewed safety 20 question evaluation of a change in --
21 DR. UHRIG:
They do that on all the license 22 amendments automatically.
23 MS. McKENNA:
I'm sorry?
24 DR. UHRIG:
You do --
25 DR. SEALE:
Yes, that is part of the rule.
f)*
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DR.2UHRIG:
-- 50.59 automatically on any license 2
c h a n g' e.-
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MS. McKENNA:
Okay.
Let me put it a little 4
differently-- 50.b). is trying to determine whether you need j
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'a license change and that maybe it involves a tech spec or
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6-because it involves an unreviewed safety question,' and if 7
-they are-in those two categories, then a license amendment U
d-is required.
l 9
DR. SEALE:
It strikes me that if the numoer, if
'10 the. overage number is 25 h'ours and recogmzing what it takes 11 to prepare the documentation to allow a bros.dly drawn group' 12
'of individuals -- that is, people from different-13 disciplines -- to understand the problem, to prepare.the i.
i 14.'
. documentation, to make that case regardless of the
)
15 disposition of the problem probably takes 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.
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16 Regardless, and then you ta?.k about the time it L
l L
17 takes to review,.and if that review is an intelligent j
.18 review, that has got to five, considering just the number of
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t it 39 people involved, additional' hours.
So there's a majority of n
L 20'
'the average time is spent on thi.ngs which are ultimately at t 21 a'very low level of review, dispositioned as not
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. constituting a 50.59 action.
Q 1:
23 The thing that bothers me is that if we come up 1
-24
'with a revised process that changes that review time by even 12 5 as much as 10 percent, we have imposec u.u_w.ificant. burden, p
i ANN RILEY & ASSOCIATES, LTD.
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when you consider the total number of items that have to be gr~3-2 reviewed, a significant incremental, additional burden on
> )i 3
the industry, and I think they have justifiable reason to 1
4 scream.
5 MS. McKENNA:
I am eaying if that we were imposing
'6 an additional burden of what is --
l I
7 DR. SEALE:
If it takes 5 percent more time, or 10 l
8 percent more time to prepare the basic case, then it does.
{
9 MS. McKENNA:
I guess I would argue that 10 preparation of the basic case is unchanged.
What we are --
11 most of the changes we are talking about in the rule are i
12 with respect to the criteria and, in general, they af.e 1
13 f somewhat more relaxed so that the burden should not really l
14 be there.
They still need to do the same evaluation they l
1
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1
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15 needed to do before.
The difference may be that the answer i
- u) i 16 they come to may be -- you know, be more instances where 1
1 l
17 they can proceed with the change rather than needing to get j
I 18 the amendment, s
19 DR. SEALE:
Well, my concern is --
i 20-
.MS. McKENNA:
It's a valid -- yes, I mean if it
- 21 were --
22 DR. SEALE:
It'b the enormity of the package and
'23 the investment in it that as as much a consideration as the 24 specifics of the one or cwo outliers Clat require detailed b
25 comprehensive and ultimately, essentia.lly, SAR amendments I-rN ANN RILLY & ASSOCIATES, LTU.
(
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Court Reporters
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1025 Connecticut Avenue, NW, Suite 1014 2
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and so on.
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2 MS. McKENNA:
I do think you have to keep in mind NJ 3
that there is a range of types of changes that are --
)
4 DR. SEALE:
There are sure are.
5 MS. McKENNA:
And some of them are going to be j
6 fairly simply, you know, a minor change to procedure or 7
something like that, where it will be straightforward and 8
far less than the tens of hours that you were referring to.
l 9
On the other hand, you know, there are many, many more 1
i
)
10 significant modifications where that time frame would 1
11 clearly be quite a bit more, and appropriately so because of 1
12 the scope of what is involved.
]
13 DR. SEALE:
Sure.
No argument whatsoever on t. hat.
)
i 14 MS. McKENNA:
Yes.
Yeah.
~s J
(
)
15 DR. APOSTOLAKIS:
Now, is this whole appronch 16 consistent with the performance-based regulatory systen?
j l
1Y Which we don't have yet.
But would it be consistent in the l
1 18 future?
19 MS. McKENNA:
To think about -- I am not sure that 20.
the rule by its nature really is performance-based.
It 21 really is a process to evaluate and I am not sure 32 performance-based --
23 DR. APOSTOLAKIS:
It is really process oriented?
24 MS. McKENNA:
It is really process oriented.
25 DR. APOSTOLAKIS:
Yeah.
So one would expect then,
./' ~N
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1 l
f 19 l
l' as the system becomes more and more performance-based, these
(~N 2
things to acquire less and less significance.
50.59, I mean N.
3 in an ideal performance-based system, you wouldn't need l
4 50.59, would you?
You would need something else.
5 MS. McKENNA:
You would need something else.
6 Yeah, and I am not sure what that would be.
7 DR. APOSTOLAKIS:
I mean in case the performance I
a criteria are exceeded ano so on.
9 MS. McKENNA:
Yeah.
I think going back to my q
10 first comment about what the original role of the rule was, j
11 was to control the changes and determine the need for 1
1 12 review.
It's a little different from perhaps a
]
13 performance-based approach to the world.
I 14 DR. APOSTOLAKIS:
Okay.
r(y 15 MS. McKENNA:
This next picture I just put up j
16 because I wanted to -- I'm sorry.
l l
17 DR. APOSTOLAKIS:
I have one more question.
18 MS. McKENNA:
Yeah.
1 1
19 DR. APOSTOLAKIS:
Has there ever been a case where i
20 the utility used 50.59 to make a change that really impacted 21 risk?
I mean it is one thing to violate 50.59 and then 22 argue about it, and quite another to say, look, in this cane 23 they did something that was not reviewed by the NRC and had 24 an impact on safety or on risk.
Has there been a case like 25 that?
(]
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1 DR. UHRIG:
Oh, yeah.
2 MS. McKENNA:
Yeah.
Yes.
('
i 3
DR. APOSTOLAKIS:
Where?
i l
4 DR. UHRIG:
Certainly.
l 5-DR. APOST0LAKIS:
Like what case?
l 6
DR. UHRIG:
Well, the one that I remember was 7
after Three Mile Island, there were a number of changes made L.-
8 in safety systems that were made in a rash -- or a rush, l
9 trying to respond to what had happened at Three Mile Island, l
i
)
10 and some of them were later judged inappropriate, in fact, j
11 unsafe.
l 12 DR. APOSTOLAKIS:
And they were --
l 13 DR. UHRIG:
They were subsequently fined, the 14 cases that I recall.
It was done under a 10
/%
15 DR. APOSTOLAKIS:
But was it a misapplication of U
16 the rule?
l 17 DR. UHRIG:
I don't remember.
I 18 DR. MILLER:
That was before NSAC-125.
l 1
19 DR. UHRIG:
Oh, yeah.
Yes, it was.
l 20 MS. McKENNA:
Yes.
It could have been.
i 21 DR. UHRIG:
This is a long time ago, 22 DR. MILLER:
That was before NSAC-125.
Maybe we 1
23 could restate the quertion.
Ask George's question, have any 24.
of them been -- has any of that occurred after NSAC-125?
l 25 DR. UHRIG:
Well, I think if you look at the l
l l
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fines, you can pretty well figure -- zero in on anything
)
involving 50.59 that had a fine with it, then probably the 2
3 answer is yes.
(
4 DR. APOSTOLAKIS:
The fine is not really a good 5
indication.
6 MS. McKENNA:
Well, I mean it is some --
7 DR. UHRIG:
It's a level of pre-violation, 8
probably.
9 MS. McKENNA:
-- indication of safety 10 significance.
I think it has only been in more recent times 11
-that we have really particularly looked at enforcement 12 actions with respect to how they impact risk.
Safety, for 13 instance., we have some issues on swap-over on ECCS from 14 injection to recirc, changes in settings on the tank levels
()
15 and operator actions where, in some cases, you would not 16 have had enough time to perform the swap-over.
17 Now, in risk space, that may not be significant 18 because the probability of large break LOCA is so low, but 19 from a safety significance perspective, certainly, you know, 20 we see those as a concern.
21 So I would agree the population is not large, but 22 there are instances.
23 DR. APOSTOLAKIS:
And your inspectors review all 24 the 50.59 actions?
25 MS. McKENNA:
No.
No.
O.
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l 22 1
CHAIRMAN BARTON:
They spot.
They do an audit 2
spot check.
(-
3-MS. McKENNA:
It's an audit.
4 DR. APOSTOLAKIS:
So the real impact on risk 5
consists of two parts.
First, the utility does something L
6 that has an impact.
And, second, the inspectors don't catch 7
it.,
Because if they catch it, you know, they --
8 MS. McKENNA:
Sure.
19 CHAIRMAN BARTON:
Or the utilities QA oversight 10 groups didn't pick it up either.
11 MS. McKENNA:
Yeah, I mean there's --
12 CHAIRMAN BARTON:
Because that's part of their
(
13 function.
14 MS. McKENNA:
Yeah, I think this is where we
- (~N 15 talked about before in terms of the screenings and they do 16 the evaluations, that if they do the evaluations, there is a t
17 much. greater likelihood that the licensee's review process, 18 including their plant safety committee,'would recognize that 19 there were elements of that change that perhaps needed to be i
20 refocussed.
But that sometimes if you didn't get into the i
21 review process, then things would be missed.
i 22 And you are right, if that kind of slips through j
l L
23 either because the evaluation was incomplete or some aspect l
wasn't recognize, and the staff'doesn't happen to look at 24 that one, then there may be something out there.
But I l
25 l
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23
.1 think the checks and balances are such that we don't think
.2 there's a-lot of those'out there.
3 DR. SEALE:
At the risk of beating a dead horse, 4
-with regard to your comment that Bob answered citing cases l -
5-in connection with Three Mile Island, I think we also would j
~
6' have to recognize.that a comparable level pre-screening and 7
-judgment was exercised in putting some of the items that 8
wound up on the Three Mile Island action list that the NRC 9
-put together, which were later judged to be perhaps adverse
' n'their overall impact.
i 10 11 DR. APOSTOLAKIS:
I would exclude Three Mile j
i 12 Island.
-13 DR. SEALE:
I think we should because there is j
l 14 clearly a wild card in everybody's deck.
1 15 MS. McKENNA:
Yes.
16 DR. APOSTOLAKIS:
Yeah, I think Don's adjustment 17 of the question was probably -- I mean under normal 18 conditions after --
19 DR. UHRIG:
Well, Three Mile Island at this point 20 is ancient history.
21 DR. APOSTOLAKIS:
Huh?
I'm sorry.
22 DR. UHRIG:
It's ancient history.
'23 DR. SEALE:
That's right.
24 DR. APOSTOLAKIS:
It is ancient history.
- But, 25 now, you know, the industry is --
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DR. UHRIG:
We don't want to forget it.
/~T 2
DR. APOSTOLAKIS:
-- using NSAC-125 and so on.
So NY.
3 I am just curious what kinds of issues we are talking about.
4 Some of them, the impression I get is that some of them l
5.
could have an impact on risk.
6' MS. McKENNA:
Yes.
7 DR. APOSTOLAKIS:
But also there is another 8
safeguard, you know, the NRC. inspectors may' catch it.
Or 9
the utilities QA program and so on.
10 MS. McKENNA:
Okay.
I just. wanted briefly to i
11 touch on one point that we had discussed at our last.
12 meeting, and this was really kind of the relationship j
l 13 between where we saw the 50.59 process and the Reg. Guide l
l 14 11.174 type of. review.
I just have sort of a little decision (9
15 tree here, and this is kind of cribbed from other sources in
, ;% )
16 terms of a licensee determining -- evaluating whether they 17
.want to make a change, and'that's kind of their first box.
1 l
18 Should they make this change?
What are the benefits of j
19 doing the change, what are the down sideF?
Are there better i
20~
ways of doing it?' And that's, you kr w, a decision ~ process 21.
that involves engineering evaluations, could involve PRA and L
i l
22 other techniques to decide whether the change that is being i
23 considered is a good change to make.
l.
24 The second box is the box that we are really 25
. talking about.
Do they need to get NRC review for that?
p)
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And I have listed 50.59, there may be other elements.
You 2
know, is it something that is in their QA plan or the
,g 3
license condition, or whatever?
But, in general, I think we 4
.are looking, you know, 50.59.
Does it involve a tech spec 5
change?
Does it involve the unreviewed safety question type 6:
of criteria.
i 7
If it is in that space where it needs review, then 8
'the basis upon which they would seek the approval could --
9.
DR. APOSTOLAKIS:
Could be, l.
10.
MS. McKENNA:
Could be based upon 1.174 approach.
11 Whether that is a hybrid look at deterministic changes and 12-risk solely on deterministic is kind of a question that the 13-
-licensee could consider.
14 DR. FONTANA:
Now, I think there is a region in
/~N 15' 1.174 where you don't need a review.
h..
16-DR. APOSTOLAKIS:
No, we do.
17 MS. McKENNA:
No.
18-DR. APOSTOLAKIS:
1.174 always requires reviews.
19 MS. McKENNA:
Essentially, by definition, l
20 DR. FONTANA:
Down at the bottom of the --
21 DR. APOSTOLAKIS:
Always.
22 MS. McKENNA:
The space on the bottom I think 23 really is I guess is the degree of review that is required i
'24 and whether -- and where the licensee is with respect to I
25-
'their base line on core damage frequency.
But the set of l
i
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changes that Reg. Guide 1.174 applies to are those where the
["'
2 licensee needs NRC review, either because it involves tech L-3 specs,-ISI-IST programs captured by the regulations, QA' 4
plans, things like that.
So that even in that negligible 5
band down at the bottom, --
6-DR. APOSTOLAKIS:
It requires a review.
'7.
MS. McKENNA:
-- it still requires review.
8 DR. APOSTOLAKIS:
Now, the question is, though, 9-why chould it?
I'mean if it is so small.
That would go 10 beyond what 50.59 allows now.
But if we look at figure down
'11 there.
-12 MS. McKENNA:
Yes.
13 DR. APOSTOLAKIS:
See.
14 MS. McKENNA:
Uh-huh.
Yeah.
()
15 DR. APOSTOLAKIS:
One, two, three are the three 16 regions.
17-MS. McKENNA:
Right.
18-DR. APOSTOLAKIS:
Three is the region you just 19 described.
We could visualize a green region four there, 20;
.which is -- we don't know where it is, but even if the mean 2 11 risk, or CDF or LERF, changes by that much, you know, maybe
'22 it'shouldn't require NRC review.
23)
Now,.a consideration of this type would go way 24-beyond what we are doing now, or could it be part of the 25 package?-
N ANN RILEY & ASSOCIATES, LTD.
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27 1-MS. McKENNA:
Yes -- well, no, it would not be d(~%.
2 part of this package.
Because, as I indicated, the Reg.
l 3
Guide 1.174 is kind of your starting point into the process.
L 4
It's something that needs approval because it is of a l
5 particular nature.
And let's take tech specs as an example, i
i 6
I think that is kind of the easiest one.
That regardless of 7
the change that is being made to the tech spec, by the why 8
the regulations are set up, it requires NRC review.
Even if l
9 it is down in that little region four.
10 DR. APOSTOLAKIS:
Right now that is the case.
11 MS. McKENNA:
Yes.
Yes.
12 DR. APOSTOLAKIS:
But I am saying could we. change l
13 that?
I mean could this --
14 MS. McKENNA:
Certainly.
I mean it's possible, r
-(
15 but I think then you are into all these questions about the 16 use of PRA and what kind of a PRA, how that fits-with their 17 licensing basis.
How you calculate numbers down in that 18 range.
It's a bigger change to the process that I think the 19-Commission is ready to go --
20 CHAIRMAN BARTON:
George, just take tech specs as 21 a given, because I think.that is going to be hard to do 22 that.
Take tech specs as a given, so we got tech spec, they 23 do a 50.59 evaluation.
But take all the other stuff which 24 isn't tech spec, you know, the couple of thousand issues you 25 are talking about a year that go through the screening l-(~}
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28 1-process, you know, tech specs is probably a couple of 2
handfuls as compared --
3 MS.'McKENNA:
'Yes.
4-CHAIRMAN BARTON:
-- to the day to day procedural 5
changes and the title changes, organization changes.
6 MS. McKENNA:.Right.
7 CHAIRMAN BARTON:
All that kind of stuff is where 8
you spend a lot of time going through this process, and it i
means really nothing for risk, minimal risk, and that is 9
10 maybe where you apply this philosophy.
And can this 11 approach make it a lot easier than what we are struggling 12 with?
13 DR. APOSTOLAKIS:
Yeah, that is the whole point.
'14 CHAIRMAN.BARTON:
And just give tech specs -- give 15 them tech specs.
We'll do the 50.59.
16 DR.~APOSTOLAKIS:
Yeah.
Yeah.
I l
~17 DR. FONTANA:
But the reason you have to make a l
18 review in that green region, is that because 50.59 as 19 interpreted does not allow any increases whatsoever?
20 MS. McKENNA:
No, it is really because the rest of 21 the regulatory' process defines what elements of their 22 licensing that require. approval.
And tech specs --
23 CHAIRMAN BARTON:
Changes FSAR, I think is in 24 there.
25 DR. FONTANA:
Oh, yeah, all those.
/~'
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29 1
MS. McKENNA:
Yeah, they are in there.
But I am i
i
/).
2 saying the way that Reg. Guide 1.174 was structured was V
3 change-to licensing basis that required the approval, 4
because the guidance is all premised on what information the 5
licensee presents as their basis by which to request that l
6 approval.
7-CHAIRMAN BARTON:
The changes to procedures, 8
tests, just look at the definition, on everything you do 9
with a procedure, so every one of them goes through the I
1 1
10 screening process.
So, in effect --
l l
11 DR. APOSTOLAKIS:
So maybe then we would revisit 12 this issue when 1.174 is reviewed again in a year or so, per l
l 13 the Commission's --
l l
14 DR. SEALE:
Direction.
A
(
)
15 DR. APOSTOLAKIS:
Direction.
That may be part of s-16 it.
Now, you know, it does not have to be -- not all the 17_
changes have to be reviewed.
Because if it is done to 10 to j
18 the minus 8, for heaven's sake, or 9, who cares.
19 CHAIRMAN BARTON:
But I think the other issue you 20 would have to address, because the staff would come back and 21 say, well, they are concerned about cumulative changes.
22 DR. APOSTOLAKIS:
Yeah, I know.
I know.
That's 1
23 24 CHAIRMAN BARTON:
And the other piece of the --
25 MS. McKENNA:
That's another --
[~]
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30 1
DR. APOSTOLAKIS:
Sure.
Sure.
And that would be 2
used for that.
Because this is cumulative, this is not O
3 individual.
But coming back to the point you made, Eileen, 4
about if we do this, then all sorts of issues arise, you 5
know, the quality of the PRA and so.
Well, I think those 6
issues are not new.
I mean when you ask people to make a 7
determination that the probabil ty of the accident has not 8
increased, why is that easier and is not subjected to the 9
same review as when they use a PRA?
I mean it is the same 10 thing.
The subjectivism is there.
11 Now, in one case we formalize and call it a PRA 12 and we have all sorts of requirements on it, but when people 13 are doing on a quick and dirty way, then it is okay.
But I 14 think, in other words, that argument can only go so far.
15 MS. McKENNA:
Yeah.
16 DR. APOSTOLAKIS:
I mean I do appreciate that the 17 PRA has to have a certain quality.
But the truth of the 18 matter is that 50.59 requires a lot of judgment.
19 MS. McKENNA:
Yes.
3 I
20 DR. APOSTOLAKIS:
And PRA structures that i
21 judgment.
22 When we structure, we have so many requirements of 23 that structuring process that we say we don't want to use 24 that, it is better -- we are better off not usi7-
.lua 25 structured approach and that is a little diffict. c to ANN RILEY & ASSOCIATES, LTD.
O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.
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31 1
accept.
Now, this is not -- I mean this is just for the 2
record.
3 MS. McKENNA:
And it is noching to say that the 4
licensee could not use a model to help them make a decision 5
on the change they are making and how it might impact on 6
particular accidents or failure modes.
It's certainly a 7
tool that could be used.
I think it is the decision making 8
that you come to as to --
9 DR. APOSTOLAKIS:
Right.
10 MS. McKENNA:
That comes into play as to whether 11 you are going to base it on a delta CDF, in that range.
12 DR. APOSTOLAKIS:
That would be too big, I think, 13 considering the current scope of 50.59.
14 DR. SEALE:
It would take a great deal of
()
15 partisanship to argue the case that the majority of issues 16 that fall t ithin the 50.59 umbrella even show up on the 17 numerical PRA screen.
So I think it is very important that 18 we remember that when we talk about the use of structured 19 methods to evaluate risk associated with 50.59 type changes 20 and use PRA as a shorthand way of saying that, we are 21 talking about the structure, not the specifics of a detailed 22 numerical evaluation necessarily.
23 DR. APOSTOLAKIS:
And I don't expect this kind of 24 thing to be needed for all the several hundred cases.
25 MS. McKENNA:
Oh, no, of course not.
O ANN RILEY & ASSOCIATES, LTD.
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32 1-DR. SEALE:
And like anything else, I
/
2 DR. APOSTOLAKIS:
The majority --
-t 3
DR. SEALE:
-- some things are susceptible to a 4
deterministic evaluation, bang, and that's the end of it.
5 DR. APOSTOLAKIS:
Yeah.
The majority of them 1
6-should be screened out early on.
But there are maybe 7
several of them where there are doubts.
q l
8 DR. SEALE:
Yeah.
9 DR. APOSTOLAKIS:
And that would give -- in other i
10 words, that would be a nice graded approach to 1.174.
j l
11-DR. SEALE:
Exactly.
i 12 DR. APOSTOLAKIS:
Where you are down at the noise
'l 13 now, a lot of stuff, you know, can not even_ measure.
Fine.
14 Then as they begin to be measured, you say, okay, I measured
/~N 15 it,,or I calculated it, but it is so small that I' don't need b
'to review it.
And then as it becomes larger, you enter --
17 MS. McKENNA:
Into those other regions, yes.
18 DR. APOSTOLAKIS:
-- region three, and' region two l'
19 and region one.
And you have a nice shaded approach.
i f-20 Okay.
But, so the message then is that if we want
{
21 to do that to 1.174, we have to do it in a different form.
22-MS. McKENNA:
In a different form.
And I think i
23 the other --
l j
24 DR. APOSTOLAKIS:
Okay.
25 MS. McKENNA:
Other point we have talked about f"g '
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1-
-before with' respect.to the 50.59 process of'the information-
'O
(/
2 that it is looking at in the FSAR, it is a certain set of I
3 accidents'that are design-basis accidents that are laid out 4'
in the FSAR, that you are looking at impacts on changes and 5
probability of their consequences.
And that, again, is i
6' different from looking at a change in core damage frequency l
.7 '
which has a different 1
\\
8 DR. APOSTOLAKIS:
Right.
i 9'
MS. McKENNA:
-- scheme, shall we say, w1*h what 10 Lkind of accidents you are.indeed considering.
And that it f
11
'is'hard to make one change without going further in respect j
'12 to that, l
13 I think the other thing going back to my little
~
11 4 table chart was'that, in terms of the process being -- 50.59 15
'being risk-informed, I think'we had said before that it is 16 risk-informed, by and large, to the extent that the
~17J
~ requirements imposed on the licensee are themselves 18 risk-informed and that by making changes through 1.174 or 19 other methods as to what requirements they have to meet, i
20 then',. overall, the approach to licensing is more 21
. risk-informed,.Init you don' t achieve it through - the 50.59 22 change process.
23 DR. APOSTOLAKIS:
Okay. -So I see what you are 24
'saying, that 50.59 itself is not risk-informed.
25 MS. McKENNA:
Correct.
O)
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DR. APOSTOLAKIS:
However, the requirements that i;
2 you are supposed to meet eventually, through the use of
' ~
3' 1.174, will-be risk-informed.
]
L 14 MS.-McKENNA:
Yes.
Or other, for instance, 5.
DR. APOSTOLAKIS:
So that is the point.
6 MS. McKENNA:
Or other rulemakings, for instance, 7
that.the' Commission may undertake on a risk-informed basis.
8 DR. APOSTOLAKIS:
Okay.
Why don' t we move on.
9 MS. McKENNA: ~ Okay.
1LO DR. APOSTOLAKIS:
Well, you have only four or five 11 slides.
l
.12 MS. McKENNA:
Yeah.
And these will look familiar, 13 I think we --
~
14 DR. APOSTOLAKIS:
One hour on each.
i O(_/
. 15 CHAIRMAN BARTON:
Tony's coming, he will take up 16 the rest,of the morning.
.17
[ Laughter.]
18 MS. McKENNA:
That's right.
I am sure he will l
19 have plenty to offer.
In looking at the agenda that was 20-laid out, it asked a couple of different things in terms of,.
21' why are we going -- the question was, Why are we going to 22' rulemaking?
Well, I think the answer was refocusing and
~
23 re-evaluation of-the process kind of highlighted the fact 24 that there were still areas where we in the industry had not 25 converged on what the appropriate interpretation of the rule 1
l l,'
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was.
2
\\g In some. areas the rule language is somewhat
' ")
3 confusing and there is also I think a sense that we are 4
.seeing, clearly from the Commission, that the threshold 5
established by the present criteria, at least as we believe 1
6 that the rule language should be interpreted, is too low, l
,7 that it was really requiring a view of things that were of 8
such minor significance that they really shouldn't have 9
needed to come in, but the criteria would not screen them
)
10
'out.
l 11 IMt. APOSTOLAKIS:
Eileen, why -- let me play i
l 12 devil's advocate here, why can't I simplify the whole thing
~
13 and say the only time when NRC review is needed is when you
-14 have to'go to 1.174?
Anything else -- anything else they
)
j 'y 4
15 do, if it does not force me.to go into 1.174, I.will not I
v 16 review, because it is risk insignificant.
Why would that be 17 the wrong approach?
l 18 MS. McKENNA:
Well, I guess it would be whether we 19 could reach the point of agreeing that if it did not fit 20 within the envelope of the 1.174 changes, tech specs, other 21 things, that changes to it would not be risk significant.
22 And in --
23 DR. APOSTOLAKIS:
Well, the point is, what I am 24 saying is that unless the mean CDF or the mean LERF 25 increases, by whatever much, see, that is conservative, l
1 1
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1
'unless I have a positive delta CDF or delta LERF, I will not
-O 2
review the change.
V l
3 No, I mean-I -- yeah, they don't have to come to 4
me, we will.still have our --
5 CHAIRMAN BARTON:
You still have to do the review'.
6 DR. APOSTOLAKIS:
Sure.
Oh, yeah.
7 CHAIRMAN BARTON:
But you don't have to come --
8 DR. APOSTOLAKIS:
The audits.
9.
. CHAIRMAN BARTON:
Yeah, it is not an NRC review, 10 it is a'USQ kind'of issue.
.11 -
DR. APOSTOLAKIS:
So the rule is reduced down to 12 one sentence,.maybe with a common in between.
13 (Laughter. ]
14 DR. SEALE:
George, I applaud your --
tQ zj 15 MS. McKENNA:
Simplicity.
16 DR. SEALE:
-- quest for brevity.
But I think you l
l 17 are presuming a level of. quality and sensitivity that does 18
'not exist in every case.
19 CHAIRMAN BARTON:
In everybody's PRAs, you mean.
l 20 DR. SEALE: 'In everybody's PRA.
And, furthermore, 21 there are certain issues where we use things like the FIVE 22 methodology, which are really not quantitative at all.
L i
23 DR. APOSTOLAKIS:
No, but they can bound things.
i 24 So if you can use FIVE and bound it and show that it is 25 below regulatory -- I don't want to use the word l
l
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conservative.-- but', no,' you'see, the advantage of that-
~ 2_
Lapproach-would be brevity.
':F DR. SEALE:
Sure.
4 DR.-APOSTOLAKIS:
Okay.
Inter alia, it would be 5
6' DR. SEALE:
Ipso facto.
7 DR. APOSTOLAKIS:
No, it's --
j 8
DR. POWERS:
That constitutes one of your usesfof.
9 Latin, George.
You are now down to two.
210 DR. SEALE:
We'are keeping count.
111-DR'. APOSTOLAKIS:
It is in the staff's review, did 12-
.you notice that?
- 13 MS. McKENNA:
Yes.
1 l
114 DR. POWERS:
I have no control overLthe staff's V ;10
.t 15~
' misuse of the Latin.
16
'D:R. APOSTOLAKIS:
On page 2-of May 27, 1998,
'17 memorandum to'the Commission, the word inter alla is on.the 18
. third ~line, 19-MS. McKENNA:
Yes.
20 DR. APOSTOLAKIS:
So I think the' record should 21 show that.
22 CHAIRMAN BARTON:
That's just another thing we 23L don't like about that memo.
24L
[ Laughter.)
25 MS. McKENNA:
We will try to avoid Latin in the L.
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' :1 future.
l
)
2 DR'. APOSTOLAKIS:
Now, you said that several 3
licensees, or lots of them, or whatever, don't have a very 4
good IP.
This would be a good incentive for them to 5
upgrade.
See, remember, this is all optional.
You don't 6
have to'do it.
But if some people start doing it and they 7
.see that, you know, it is really the better way.
See, the
- 8 only way to' sell PRA is to show that it helps people to do 9
things better.
10 DR. SEALE:
I agree with that.
Certainly.
11 DR. APOSTOLAKIS:
Okay.
So you can have --
12 DR. POWERS:
George --
, :L3
-DR. APOSTOLAKIS:
I think it would be nice to have
- 14 a 50'page document describing the new 50.59 and then, as an 15
' alternative,.one sentence.
16 DR. POWERS:
George, I am not.sure that the 17.
mission _of.the Committee, or anyone else, is to sell PRA.
,18-DR. APOSTOLAKIS:
No, because we do -- it is not 1
19
.to sell it, but I think we are for risk-informed regulation.
20 So, you know, there is an implicit endorsement there, if the 21 tool for that is PRA.
But it seems to me that such bold 1
22:
steps should be part of the process'because what happens, L
- 23 you look at history, the first time around they are 24l rejected, but then, you know, next time, they are actually
]
25-implemented in some form.
So it is the responsibility of
,b
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the licensee to keep track of the changes, and if the mean 4
2 value becomes positive, the change, then they have to go and 3
. apply 1.174.
And you guys will do your audits as you j
4 usually do, and if you find that a licensee has violated 5
i that, then you have certain procedures to' follow and --
6 CHAIRMAN BARTON:
Enforcement action.
7 DR. APOSTOLAKIS:
Yeah, enforcement action.
It l
l 8
seems to me that is the simplest way, especially the way the 9
budgets are going within the agency.
So it will relieve you 10 of a lot'of burden of reviewing these things.
That's a I
11 thought.
L 12 MS. McKENNA:
Just a point, I think that, you 13 know, whatever -- it may be that it would be an option or a l
l 14 process that may be attractive to certain. licensees, but a L/
15 question of whether we change the rule to say this is now iC j
16 the way you must perform your evaluations is --
17 DR. APOSTOLAKIS:
No, no, I.didn't say that,
'f 18-Eileen.
I don't say-that is the way you must.
But in the 19 new document, there may be a place.to give an option like 20 that.
'l 21 Now, have you thought about it and rejected it?
)
22 Or is it the first time that --
l i
23 MS. McKENNA:
No, I think that there had been some 24 consideration.
Going back to our SECY-97-205, I think we i
i L
25 had thought about these things as options in parallel and I'
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things like that.
But, you know, then you raise the l
. (']
2 questions that were probably in many cases down in those
\\~s 3
lower bands and then the issue is about are ready to say j
4 licensees go forward and use your PRAs to evaluate all --
f various kinds of issues without our involvement and, 5
at the I
l 6
time at least, I don't think we were there.
{
7 DR. APOSTOLAKIS:
Well, would you be agreeable to l
B having a pilot project on this?
If a licensee steps forward j
l 9
and says, yeah, we would like to try this.
For a period, 10 say, of a year or two?
11 MS. McKENNA:
I can't speak for thL whole agency, i
12 certainly, bat'I would say that --
i 13 CHA!hMAN BARTON:
That may be something we want to j
14.I suggest in our letter.
]
x.
1 l'
15 MS McKENNA:
Maybe something --
j N_/
i 16 DR. APOSTOLAKIS:
No, but -- yeah, I want to know 1
17 how Eileen feels about it, though l
l 18 MS. McKENNA:
I mean I am not -- you know, I am 19 not the risk-informed part of the agency, so I can't speak 20 for how they might view that.
4 21 DR. APOSTOLAKIS:
Okay.
That's fine.
That's 22 fine.
J.
23 MS. McKNNNA:
Maybe in the spirit of pilot i
24
. applications.
I think the question of how you would 25
. implement that or whether they would require an exemption or i.
l f'N.
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r 41 (1-something like that would come to bear.
And I don't know
)
.2 whatfdegree of interest there might be in that kind of an 3-approach.
l 4
DR. APOSTOLAKIS:
Well, we don't either.
ls b
5-(Laughter.)
,6 DR. APOSTOLAKIS:
It seems to me, you know, the g
7.
reason why I am saying this is'that we tend to extrapolate l
l 8
from what we are familiar with and, you know, try to change l
9.
a little bit here, a little bit there, and it seems to me 1
10 that the times are requiring more drastic and bold steps.
~
11
'So in the spirit of that, I am just raising the issue.
Why (12 '
not;say,.you.know, forget about it, we are really wasting
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.everybody's time, and we already have rules that will J[p
' satisfy, youLknow, the ultimate objective, which is 14
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i:18
. minimal changes.
L
- ,19, MS.'McKENNA
I think that some are minimal and S
I.
,,20 some are -
'I won't say minimal.
Some are little, some are 21 bigger.
l 22; DR. SEALE:
'Some are more minimal than others.
t' L7
'23 MS. McKENNA:
Yeah, right.
~24 DR. APOSTOLAKIS:
Well, we want the maximum L
25;
'minimorum.
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1 MS. McKENNA:
Yes.
Just a couple of other --
l
'2 DR. APOSTOLAKIS:
That was Latin, inadvertently.
<. IN j
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3 MS. McKENNA:
Just a couple of other comments, I L
4 think, from the draft agenda we had, that, you know, you 5
mentioned, I think, that we did have the March 24th SRM I
6'
-which we did respond to and accepted certain of the 7
direction and some of the areas where the Commission asked
,8 us to consider particular things, provide in our response.
l
-9 The' Commission has not yet acted upon the memo of either 10 telling us to proceed or to provide -- giving us other l
11
' direction.
12 CHAIRMAN BARTON:
The Commission is probably the 13 same place we are.
Where do we go from here?
14 MS. McKENNA:
Perhaps.
I think, as was mentioned,
~ f~')I 15 we did have a meeting with the Commission on June'4th, both
\\_
16 NEI and ourselves were present where we talked about where 17 were on 50.59 and FSAR updates, but it'really was more in a L
18 status --
l 19-CHAIRMAN BARTON:
There was no clear direction 20.
came out of that meeting.
4 21 MS. McKENNA:
No.
No.
That is correct.
22 CHAIRMAN BARTON:
I was hoping you would provide 23
- today where --
24 MS. McKENNA:
Yeah.
Well, we just have not t
25 received that.
There was some good discussion, questions (N
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43 l
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and answers back and forth, but we have not gotten any kind i
<^x i
(
)
2 of SRM or other guidance from the staff -- excuse me, from 1
l v
3 tne Commission'as to uhich way to proceed.
l 4
DR. APOSTOLAKIS:
Is our letter going to have an S
influence on that?
They may decide tomorrow, in which case, 6
a letter --
l 7
CHAIRMAN BARTON:
Yeah, I don't know.
You would 8
hope it would, but we don't know when the Commission is 9
going to act on --
i l
10 MS. McKENNA:
I mean I think -- right.
11 CHAIRMAN BARTON:
We don't know when the 12 Commission is going to act.
13 DR. SEALE:
No promises, George.
14 DR. APOSTOLAKIS:
I know, I know.
,~
k_,s) 15 MS. McKENNA:
I think with the -- having with the 16 COMSECY and some of these other issues, that the Commission 17 has a range of options, they could give some specific 18 direction in areas.
They could say, go ahead, staff, 19 proceed and bring your best product and we'll weight in on 20 that.
And depending on which approach they take, the I
21 feedtack from the Committee, you know, how it would 22 interplay, you know, would make a difference.
If they are 23 giving us some direction now, it may not play in.
But if 24 they tell us, well, you go ahead and come back with your 25 best shot, then it probably would be a little different.
l
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)
1 DR APOSTOLAKIS:
I read the transcript.
1 l
/~T 2
MS. McKENNA:
Yes.
t 4
l -. '~/
o r 3
DR. APOSTOLAKIS:
And it seems to me that you were 4
discussing with the Commission different issues from the 5.
ones we are discussing today.
6 CRAIRMAN BARTON:
Well, it was the differences --
l 7
no, the tie of the 50.71 and the FSAR and into this process.
8 DR. APOSTOLAKIS:
That's right.
l 1
9 MS McKENNA:
Right.
That's correct.
l 10 CHAIRMAN BARTON:
A lot of time was spent on that l
11 issue.
12 DR. APOSTOLAKIS:
We haven't talked about it yet.
13 CHAIRMAN BARTON:
As oppose'l to purely the 50.59.
14 MS. McKEtiNA:
That is correct I think that was l [,x
)
15 the major difference with respect to the Commission meecing.
i
%.J i
16 DR. APOSTOLAKIS:
So we will come to this today?
i 17 MS. McKENNA:
It was not our intention to --
28 l
DR. APOSTOLAKIS:
Because I want to understand it.
19 MS. McKENNA:
-- speak.
Okay.
20 CHAIRMAN BARTON:
Tony, are you going to address 21 that piece?
l 22 MS. McKENNA:
I may put Tom on the spot over 23 there.
l 24 DR. APOSTOLAKIS:
Tony is not here.
25 MP. BELL:
I am Russell Bell with NEI.
My r~3 ANN RILEY & ASSOCIATES, LTD.
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colleague, Tony.-Pietrangelo,-is planning to present our h
-2' Lvicws later on the~ agenda-and would no problem or difficulty-
?
3; addressing our views on the, I guess, convergence of the 4'
FSAR issue and this issue.
'5' DR. APOSTOLAKIS:
But what is the issue?
lV L6' MS. McKENNA:
Let me'give.it a try, and, please, 7-Tom Bergman in the individual primarily responsible for l
8
. developing.our guidance on FSTiR updating.
I mean 1 think
(.s 9!
the!1ssue io, the language in 50.59 talks about the facility s
10-'
and procedures as described in the FSAR.
So that is the set
- 11 of information that ' kind of forms the scope of when they 12 need to evaluate things.
So,.chviously, the question of 13 what information resides in the FShR then becomes,ixpcortant 14 to when 50.59 evaluations are necessarj.
u.
15 The guidance that we were working on in terms of 16l
- updating 'wa~s to give sona assistance iw deterd.ning what 1
17 kinds of things need to be updated in the FSAR.
You know, 18 there is originally, the FSAR, they submit as part of the
-19 application, get the license.
Things change over time, 42 0,
there are license amendments, new rules, changes they make t
1' 21' under.50.59.
These changes are supposed to be.up -- the L
i l
l-22 information updated back into the FSAR, so you keep a l
23 current representation of your facility in that document.
]
l-hA
. 24-CHAIP. MAN BARTON:
This is what, is it annually, 25,
' biannually?
.It's on some kind of schedule.
l p4 i
4 M(,l "
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MS. McKENNA:
It's up to a two year schedule, j
1
('T 2
There's some -- some plants are still on an annual basis.
N-]
3
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CHhIRMAN BARTON:
Utilities have to --
l 4
MS. McKENNA:
On scme on a --
5 CHAIRMAN BARTON:
-- subr. lit a revision on that 6
schedule.
j 7
MS. McKENNA:
It's kind on a refueling outage and B g then, you know, with some additional time to, essentially,.
l '
i to be included in the updated FSARre That there had not 15
%/
i 16 been definitive guidance eatnblished and the practice, 17 particularly with respect to new scaues that arose, was l
18 variable.
So the issue with respect to 50.59 is that, to ftheextentthatinformationisnotin the FSAR, it could
.s. 9 20 affect whether changes to it are then evaluated under 50.59.
21 i
Tom, do you want to say anything further on the 22 updating?
No.
Okay.
23 MR. BERGMAN ~:
No, you have captured it.
24-MS. McKENNA:
Okay.
25 DR. APOSTOLAEIS:
So what is the disagreement with l
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the industry?
[ffi' MR..MARKLEY:.' Scope, isn't it?
2 A_
L i3 DR. APOSTOLAKIS:
Scope.
What does that mean?
4
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- ",, Ji' ^
- 4, -
CHAIRMAN.BARTON:
I think the -- yeah, Russell, 1
lL 45r.,-
7 y can you address that?
-MR'. BELL:
The issue.I'think.is that:for 30 years, 6
2 p
7-
'I, guess, the.FSAR,.as Eileen has mentioned, has been used-to
, L8
' define'. basically theiscope'of what is covered by the 50.59 i.
19-
' regulation,~which-changes in your facility need'to be
-10
- evaluated lto those criteria.
k:.
111.
!DR. APOSTOLAKIS:
So if:something is not in the lg y -:q 12:
FSAR, I don't even have to consider 50.59.
13?
MS. McKENNA:
The.way the rule is written, that;is 14:
true..
ca N s t....
d' '%, s] ;-- 15 s.
MR.EBELL:
By the rule, that is true, t
u l
c161 CHAIPMAN-BARTON:.Righc..
If; 'it is not-in the ; FSAR il?'
, tech specs, you don't!have to consider it.
a-
- 180 DR.-APOSTOLAKIS:
Okay.
1 19' MR. BELL:
What has happenedJis,thatlutilities 20.
have conservatively interpreted that. aspect of-the rule and 21
.do consider ~ additional documentation ani so forth in 22 evaluating changes to determine whether prior review by the 123
- "NRC is needed.
a,.
K J24 And you'enn imagine that by thinking in terms of L
s a
25 an early plant.SSAR that'has three volumes of information (Q ' -
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1 versus a later plant that might have 30 volumes of j
i i-%:
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That.later plant, maybe everything he needs to
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consider is between the covers of those 30 volumes, whereas L
4-an older plant has supplemented their SSAR with other L"
5
~ documents and other information over the years and would j
\\
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Eneed to consider more things than their SSAR I
1 7
So some plants, in~ general, the rule is 8:
conservatively implemented, and the SSAR, and people look b
i 9
beyond the SSAR in terms of what changes to be considered l
10 iunder 50.59.
So in one respect,' the scope -- defining the l
11 scope as the SSAR is too narrow, in that' respect.
In the
~ 12
. respect that the SSAR COntains a whole lot of information-l 13 that is not terribly safety-significant, or even f
and we would view the SSAR as 14
- regulatorily-significant, 15.
perhaps too' broad a scope,- in that respect, and at.the same
.16-time it is too narrow in the other.
L '
l l
'17'
'Our conclusion is then that the SSAR may not be
- 18-the best way to defi'ne the scope of this regulation, What l
19' is it about the SSAR, what information in it is appropriate L
[s S20-to consider under 50.59?
Or is there some other way to II 21?
define wh'at is truly the important information that ought to l
22 be evaluated to determine whether prior NRC review is iI-23 needed?
24 We think that there is likely to be a more l
W of 25 efficient, effective way to define the scope of 50.59.
What
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we have proposed to do is to evaluate that over the next 2
period of time.
The Commission SRM indicates that they r3
\\')
3 would like recommendations in that area by --
4 DR. APOSTOLAKIS:
You, yourselves, don't know yet 5
how to define the scope?
l 6
MR. BELL:
We have proposed and are evaluating l
7 internally the notion of focusing on the safety analyses.
8 DR. APOSTOLAKIS:
The safety analysis.
9 MR. BELL:
The safety analyses in your SSARs form
{
l 10 the core of the information in the SSARs.
l l
11 DR. APOSTOLAKIS:
For a part of the SSAR.
12 MR. BELL:
Right.
Right.
Now, we are pulling 13 I that string and testing that approach out now in a couple of l
l 14-actual plants SSAR, and we will continue to test that.
And
{
(}
15 if it holds up, we will likely come in and want to talk with l
\\~?'
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I 16 the staff more about that.
What we said on June 4th is that 17 there are issues that we really need to resolve right away, i
18 and that the scope question could reasonably be separated l
19 away from these issues about what the -- how to clarify the l
20 criteria and that the schedule proposed by the Commission, l
21 their SRM, is an appropriate one for --
22 DR. APOSTOLAKIS:
But again, the utilities have 23 spent a considerable amount of money and effort doing the 14 IPEs and IPEEEa, Why on this part of your thinking, I mean 25 where you reconsider the scope, I mean they have them now.
l
. (M*,) '
Court Reporters ANN RILEY & ASSOCIATES, LTD.
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l This old notion that, boy, we have to do a risk analysis.
1
)
2' Thatfis not there anymore.
Now they have it.
In fact I 3
Jthink in~most cases they are on PCs.
l 4
Have you thought about trying to take advantage of
]
5 that information perhaps in defining the scope of 50.59 or j
[
6 uis that'something that still people consider as something t;
l
.7 separate?.
J r
8 DR. SEALE:
Too new.
l i9 DR. APOSTOLAKIS:
Too new, yes, too new.
10 DR. SEALE:
Twenty years is not a short time.
11 DR. APOSTOLAKIS:
Well, but for the utilities it
(
12 is not 20 years.
13 DR. SEALE:
I know.
Let me ask you --
14 DR. APOSTOLAKIS:
Well, he's thinking. He's j )
15 thinking. Let the man answer.
l
-16
'MR.
BELL:
Well, I liked the answer --
17 (Laughter.]
I 18 MR. BELL:
-- that he gave.
You know, that may-19 be;-- right now'there's certain things we need to resolve
- 20 Land ~as quickly as we can because'there's some confusion out H21 there and.then we think that there's an improvement that y
22 could-be made in the way you define the scope, even if it is l
23-deterministically.
24 That may be another phase of improvement in this 25-process, but what you are getting at may be something that l
h l o /~'.
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is the next step and I think we would all be interested in h
(~')
2 continuing to improve ourselves in this area.
l
(/
3 DR. APOSTOLAKIS:
Well, first of all, I am not 4
suggesting that you should do what I suggested earlier about j
l 5
the mean value.
I think that is clearly something for the 1
6 future, but there's still a lot of information in the IPE J
7 and IPEEE that you could take advantage of and already in i
1 8
your document you are talking about PRA.
I 1
9 It is very interesting.
The moment the word PRA i
10 comes up -- period.
But it is not necessary.
Every single l
11 time "but you are not required to do that."
1 1
12 Okay.
One day perhaps you will drop that, okay?
13 it's like the Staff always says to the extent practical, to 14 the extent supported by data.
Okay.
You know what that g( )
15 means --
16 MR. BELL:
Understood.
17 DR. APOSTOLAKIS:
We really don't like it.
- Well, l
18 I mean inter alia that is what it means.
j 19 DR. POWERS:
That's two, George, by the way.
You j
20 are down to one.
1 21 DR. APOSTOLAKIS:
I would propose it later to 1
22 Eileen but it seems to me there is a lot of information 23 there that could be usefully employed right now to make this
'24 50.59 more rational and more informed.
I don't want to say i
25 risk-daformed, more informed, but we will come back to that, I
~t' )
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~right?
j-2-
HDR. SEALE:
I wanted to ask one question.
There's
. V) 13 another phrase that so far we have scrupulously avoided 4
using, which I think is relevant to this discussion of what 5-constitutes the difference between a three-volume SAR and 6 volume SAR,' and that is what constitutes the design 7-basis.
When you say if it is in the Safety Analysis Report, 8
do you really mean whether or not it is in the design 19 basis -- that is, the Safety Analysis Report plus the 10-
' reviewed and accepted amendments and so forth and responses l
11 to. rule changes that the NRC has come up with and so on, l
12 which I presume is the thing you are expected to respond to j
13.
in order to be in the magic word " compliant."
14.
Is it. essentially the compliance issues that you
'yN 15 are talking about?
jV
-16
.MR. BELL:
I don't want to punt but I wonder if 17 you could just rephrase your -- first, and the question is J
R18 '
design basis.-- that's an excellent question.
We think I l
- 09 mean the SAR is the. appropriate place that your design basis
?20-ought to be.
We need to work out with the Staff exactly --
21 DR. SEALE:
It is clearly amended, certainly in i
22 the case of the three volume SAR.
If nothing else, history 23 has transpired.
24 MR. BELL:
Under the FSAR update activity, both we l
25' andithe Staff agree that to the extent there's new design l
l.
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1 basis information, that needs to be supplemented in there.
/
)
2-DR. SEALE:
You are saying then is that the R. J r
3 basis -- the 50.59 requirement definition includes --
l l
4 MR. BELL:
Design basis.
I 5
DR. SEALE:
-- appropriate status information 6
beyond what is in the initial SAR.
7 MR. BELL:
That's true and through 50.71(e) and 8
the update process, that is absolutely true.
i 1
9 DR. SEALE:
Okay.
10 MR. BELL:
And I think the design basis is 11 encompassed by that and any approach that is on the table 12 right now will be, even in the -- even if it is the safety 13 analysis some day in the future and that is the focus, we i
14 think the safety analyses are clearly performed consistent j
15 with the design basis and so I think even that concept it 16 would be captured under that approach that I mentioned we i
17 are thinking about.
18 DR. SEALE:
I would hope so.
Otherwise there is 19 not much point in doing it.
20 MR. BELL:
Right.
Thank you.
21 MS. McKENNA:
This may be a good point to -- the 22 very next topic I had in mind was this very one I think that 23 we were talking to with respect to change to the facility as 24 described in the Safety Analysis Report.
25 The issue that was being alluded to is what rx l f j
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l 1
information in the FSAR should require an evaluation if the l
l
T 2
change they are making would impact upon it, and we were (V
3 trying to focus that.
I think this is another way of kind l
4 of getting at what NEI may have been suggesting with 5
focusing on safety analysis, of trying to understand what 6
does it mean " facility as described" -- what does that l
7 include?
9 That is where we came up with the proposed i
9 definition that " facility as described" includes the 10 systems, structures and components, there is clearly no i
11 question.
The other element of that was to the extent to 12 which changes to information about those systems, structures 13 and components, the design basis requirements they are 14 supposed to satisfy, the analytical basis on which they were s~
/
15 determined to satisfy regulatory requirements that if those l
16 types of information are being changed, that should require t-17 an evaluation becauce -- to support why those systems, 18 structures, and components were acceptable in the first 19 place.
l 20 So that was the intent of having the definir. ion of 21
" facility as described" was to include that type of
~
22 information and to exclude the information that otherwise I
23 was being referred to as perhaps descriptive information 24 that really did not impact upon how the facility performs 25' but by virtue of it being in the FSAR it could be argued to q
l f/~S[
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be -- well, it's facility as described, f-~
2-It says that it has a particular configuration or O
3 particular descriptive information about, you know, they are 1
4 six feet tall or whatever, but that really was a detail that 5
didn't need to be there.
i 6
I'll just comment, going back to the FSAR for a 7
moment, that the guidance we are trying to provide on 8
updating, it does indeed focus on the information like 9
design basis, the safety analysis, the limits of operation 10 that we think is the important information that needs to be 11 in the FSAR and the guidance does allow for removal of 12 information that really perhaps was excessively detailed 13 that doesn't contribute to providing that kind of 14 information provided it is done through a controlled and
)
documented process such that it is understoed why that 15 16 information is removed from the FSAR, so I chink that the 17 two pieces may fit together or having the FSAR contain the 18 right information and not some of this excess information 19 and then if. things are being changed that impact upon that 20-information that it needs an evaluation.
21 The second point I think I mentioned at our last 22.
meeting was this question of additions.
It is not explicit 23 I think in the way people kind of think of change right now.
24 I would say in practice this probably by and large is done, 25 but not consistently, so we were trying to through the
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1 language make it clear that we consider that additions to
~~
( ';
2 the facility are changes -- I think the confusion sometimes V
3 arises from the "as described" part, that if you're adding i
I 4
something'that is not already described, you are not 5
changing what is in the FSAR, but the addition of something i
6 to the facility could well have an impact on other things 7
that are in the plant because of how it is -- where it is 8
located, how it relates to other parts of the plant.
9 This was really more I think of making an explicit 10 statement that we feel really could have been inferred there 11 but if we are doing a rulemaking it probably would be 1
12 appropriate to be clear.
13 We had suggested also -- which I didn't put on the 14 slide -- but I'll just carry on, that we perhaps are doing a (A) 15 parallel definition on procedures.
Sometimes it is not J
16 clear what's facility versus what's procedures if you are 17.
talking about how a system is operated.
18 You know, what is that, is that facility or 19 procedures we are really trying to capture or both?
20 The other thing we were looking at with respect to 21 procedures was whether we could clarify another point of 22 confusion I am not sure is the right word but to make clear 23 an area where there's some overlap, that there are 24 procedures that are related to quality assurance and to 25 emergency planning which by the regulatory language are to
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be included in their FSAR, so to the extent they are 2
procedures described in the FSAR they would require a 50.59 l'
3
-evaluation.
L 4
Those type of procedures you have separate l
5 regulations in 50.54 that provide. criteria, reporting, other j
6 requirements on it, so we are looking to say that you don't 7
have t'o do both.
What we are proposing is they would use 8
the 50.54 process rather than 50.59 -- rather than have them j
9 do both, because presently they have to do the 50.54.
The 10 area of grayness is whether they would also have to do a 11 50.59 -- don't feel that needing to do both is really 12 necessary.
13 The other definition we offered for comment was 14 with respect to tests and experiments.
It was kind of I) ~
15 parallelism.
If we were going to give a definition on the V
16 other parts of when the evaluations were needed, we'd look 1
17 to see whether we could do a definition on test and 18 experiments.
The other thing we were trying to do, to see 19 whether there was a way to bound which tests or experiments 20 would require ~ evaluation and whether we could give some 21 guidance, if you will, a screening of certain tests or 22 experiments could be screened out and not need an 23 eyaluation.
24 The specific language that we had proposed for 25 comment or suggested was a little too small, that it was
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58 l'
narrowed in on - ' kind of that if it met that definition, it
()
L 2 might even involve an unreviewed safety question so that we 3'
.are looking at whether we can adjust the language to be a i
4 little more useful as a screening tool or'whether to drop 5
from consideration providing such a definition.
6 Another topic I think we had talked about last 7
time was where we are on minimal -- with respect to 8
probability and consequences and I will get to this in a 9'
little more detail in a moment 10 The other area,'and this is one we are still 11 wrestling with to a large degree, is exactly what to do on 12 margin'of safety.
There's a whole host of phrases embodied j
~ 13 -
in that part of the language.
Margin of safety,is defined 14 in the basis for any tech spec and there's many different i
15 interpretations that can be drawn on those and we have
~
16-
. offered:some proposals in the paper, commenters suggesting.
l l
17-that there's still-some disagreement as to how to implement 18 this.
J 19 You know, we talked before I think with respect to 20-consideration of acceptance limits.
I think there is 21-
- disagreement on what are those acceptance limits, SAR e
l 22 values, SER values.
In some cases.what would be viewed as 23
_ acceptance limits would be regulatory limits and there's 24 concerns that do you really want to allow changes that would
.25 take you.all the way to the regulatory limits without i.
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-59 c.
1 review.
'/~'i 2
I think the other part that we have wrestled with,
^
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3 with respect to margins, are more in the space of shall we l
4 day ---
)
5 DR. APOSTOLAKIS:
Eileen, excuse me.
6.
MS. McKENNA:
Yes.
7 DR. APOSTOLAKIS:
But isn't this-argument the same 8
one.we were facing when we were developing 1.174, do we want 9
to allow changes that will take every plant to core damage 10 frequency equal.to the goal, and I thought we had resolved.
11 that, that we want to go slow.
12
-MS. McKENNA:
Yes.
13 DR. APOSTOLAKIS:
Am I right?
14 MS. McKENNA:
Well, yes, and I think that is why
' O).
(
15 we are wrestling with whether to, if you use acceptance 16~
limits to say yes, you can go all the way in one bite to the i
17
' limit versus some smaller increments.
18 I think the other thing we are wrestling with'is 19 with respect to -- again we are looking at-things that are
.20 associated in some manner with the tech specs, so.that there 21' are both the outcomes of safety analyses, safety limits 22 kinds of things that relate to tech specs, but there's also, 23.
if.you will, the inputs -- the input assumptions in terms of l
24 establishing LCOs for' equipment and things like that and how 25 the concept of margins really applies to the inputs to 0
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60 l
':L analyses.that establish those tech spec values or limiting
' ~T
'2 conditions needs a little thought.
f
( ).
3 Do we say that if it fits in that space, you know,.
4 there's absolutely no change allowed or is there room for a 5
notion o'f minimal -- and we:made an attempt to get to 6
closure on this, but from our internal discussions it's 7
clear that we are not there yet and we are having additional.
8 discussions and dialogue to try to reach a conclusion.
I 9
I think there's different schools of thought with 10 the Staff and, you know, we're planning to have some 11!
discussions at the high levels.of NRR to really come to 1
12
. grips with where do we-go with this and make a proposal, so 13' I am not prepared today to really give you the answer on 14 where we are on margins.
l
-[~)
15 It is a difficult issue and it's one that I-think l
v 16
'has caused us probably the most difficulty over time of 17 really what-it'means and I thin the fact that we are still I
18 wrestling'on it is a' reflection of some of those 19 difficulties.
.I 20.
MS-. McKENNA:
These are just the other topics that j
iI 21.
we hadLeovered a'little bit the last time that
)
22.
DR. APOSTOLAKIS:
So are we done with the minimal
.j J
23 probability and --
I t
224
-MS, McKENNA:
No.
I'm going-to come back to 25 minimal in a~ moment.
Just to kind of pick up on this,.I l
I
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think we talked about these before, the one on 5071(e), I
- l..Q(\\.
think we had mentioned before that we were -- with respect 2
j
~
3-to the - 'this is where we get into the minimal information l
4 of'how to capture the accumulative effects of multiple 5
changes.
We feel that through the 5071(e) update where the 6
update is-to reflect the effects of changes made-to the E
i 7
facility, that that's the place that these cumulative l
\\
,[
8 effects can be captured.
9 DR. APOSTOLAKIS:
So how can you track cumulative 10 effects when they are not quantified?
- 11 MS. McKENNA:
I don't think we can if they're'not E12 quantified, and maybe it would be good to move to where we
.13-are on minimal to --
14 DR. APOSTOLAKIS:
- Yes, j )
15 MS. McKENNA:
Which is the next page, to deal with 16 that.
.17 I mentioned this last time but maybe didn't stress 18 it enough, that since the increases in probabilities and 19 consequences criteria are really -- if you -- with the
~
20 minimal concept applied'is really an extension of current 21 process where its probability of consequences may be 22 increased, that the -- in most cases, the changes would --
23 kind of the same rules would' apply.
You would look at them
~ 24 qualitatively and make the determination based en, I think 25-we mentioned last time, the attributes was the word that was p
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62 1
used of what the change is and what it does to the system 2
structure and components of the other information, and 3
therefore, they would be qualitatively evaluated.
4 It really just was a question of once you move 5
past that, may be increased towards some possible minimal 6
increase, you know, where is too big?
And I think we had 7
mentioned before -- had offered some attempts on 8
quantitative numbers.
I think the feedback we have was that 9
while numbers may be useful, that particular numbers we had 10 were too small, and that the numbers that other people might 11 offer, if they -- in some cases, it would be a probability 12 of certsin accidents, you know, a 100 percent increase in 13 the probability of design basis accidents may not be risk 14 significant, but to say that we're going to accept 100
(
15 percent increase in the probability of accidents is --
16 doesn't look like good regulatory policy.
17 So at this point, what we're -- we're not 18 proposing to offer numbers, offer the qualitative guidance 19 that we had discussed in the statement of considerations, 20 although we would expect it would end up in the appropriate 21 regulatory guidance, whether that's a modified version of 22 9607 or in a staff reg guide to be determined.
23 The other suggestion that was offered from 24 commenters and others was that perhaps this is an area 25 that's best treated through examples of kinds of changes O
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63 i
i i
that people would conclude to noc -- or minimal increases in 2
' probability is.something we're exploring, and we hope
(
3 perhaps_it will be an area that we would include, I think, 4
in. our reqtiest for comment, asking for examples to help i
5
. people decide whether what they're doing really -- how it 6'
really is impacting probability.
t 7
In contrast, I think consequences is an area where' S
-- it is amenable to a quantitative criteria because it's an 9
area'where they,arel qualitatively calculated and, therefore, 10'
,you.could apply a numeric to.give some guidance on what's 11 minimal or not, and'I think, as noted in the discussion, 12
'we're looking'at both a flat -- I think half a rem was the 13-number that was suggested in the draft you received, or a
-14 more graduated approach that would look at kind of how much 15 remaining margin you had to the-guidelines, and that as-you 16
'got closer, the amount of change that would be allowed would l-17 get smaller.
l 18-DR. SEALE:
You know, to the extent that all of us u
l 19 have a little bit.of a lazy streak, the phrase " work smart" l-L 20 has a kind of a universal: appeal, and one of the things that j
21 strikes me is that as.we talk about trying to evaluate the
?22 cumulative'effact and so on, I think we have to be'very.
23-
-careful.
24-
~The; reason I say that is that I know that 25t
=somewhere back out in some office around here somewhere, pp..
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'l somebody is scratching their head over the question of a l, }'
2 cumulative -- or a living PRA, and --
3 DR. APOSTOLAKIS:
As opposed to a dead PRA.
i 4
[ Laughter.]
5 DR. SEALE:
Yes.
Or moribund, anyway.
6 DR. APOSTOLAKIS:
Comatose.
l 7
DR. SEALE:
And I can imagine that if we get too 8
zealous in trying to come up with rules to do a cumulative 9-
-- I mean -- yeah, to keep track of changes, that we're 1
10 going to find ourselves in absolute conflict with what you i
11 would ultimately want if you 1 coked at the larger question 12 of a living PRA.
So I think you want to be very careful 13 about how'you attack this probl'em, because I don't think you 14-want to get yourself into the corner of having a body of
()
15'
' usage that accumulates because you attacked this little 16-problem, which now works against the acceptance of a more 17 global approach as.would be involved in a living PRA.
18 So -- and I don't know, I can't think of all of 19 t'he details, butLall I'm saying is, let's be careful, we 20' want to'fix:what we're trying to fix, because, you know, E
1 21:
it's like be sure you know what you're-doing when you ask
.,h.
22 for: something because you may do it.
j 23 '
CHAIRMAN BARTON:
You may not'like the answer.
-24 '
DR. SEALE:
Yes.
And we may get something-here
~
L.
- 25' twe're not particularly happy with if we're not careful.
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l 65 i
'l DR. APOSTOLAKIS:
Isn't -- I'm sorry, you want to 2
respond to that?.
L 3:
DR.'SEALE:
I'm through.
4 MS..McKENNA:
I think what we were suggesting with 5
respect to cumulative is where it's quantitative at the FSAR 6
would reflect the net effect of quantitative changes.
The 7
question in probability space is a little harder to deal 8
with,.and that, I think, is more germane to where you were 9
going with your comment that -- I think that's why, you 10
-know, we need to try to be smart with what guidance we give 11 on what minimal increases in probability and, you know, in a 12 manner suchTthat people don't go too far afield with that.
13 DR. APOSTOLAKIS:
I think all this would go away, 14 of course, if we just said-do whatever you like, but where
- 15-the CDF becomes positive, come to us.
16 CHAIRMAN BARTON:
It's a very simple approach.
17 DR. APOSTOLAKIS:
It would go away. 'Yes, it l
18 would.
Period.
19 Now, let's. talk about something else.
20 MS. McKENNA:
Okay.
21
-DR. APOSTOLAKIS:
The issue of minimal, as we all 22 know,- is -- I mean, the word is really relative.
23 MS. McKENNA:
Yes.
Absolutely.
-24
.DR. APOSTOLAKIS:
What's minimal here may be large t
25 there.
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66 1
1 MS. McKENNA:
Correct.
2 DR. APOSTOLAKIS:
So trying to define it or even 3
with examples I think is difficult, is very difficult.
4 Now, again, the licensee has the IP.
How 5
difficult would it be to say, okay, I'm making a change that l-6 affects components X, Y,
Z, I push two buttons and I get the 7
minimal cut sets that involve these components.
Let's say 8
now in an extreme case, my overall core damage frequency is 9
ten to the minus five, and this particular minimal cut set 10 is ten to the minus seven.
Even if he does something that 11
-raises that five times, it's still negligible in the bigger 12 picture.
So in that case, a factor of five is, in fact, 13 minimal.
14 If on the other hand that minimal cut set is among I
1 i
15 the. major contributors, even a ten percent change might be 16 significant.
17 MS. McKENNA:
Yes.
18 DR. APOSTOLAKIS:
So now we have a frame work 19 within which minimal doesn't even have to be used, and we 20 can appreciate the changes in the bigger picture of things.
21 Now, if the licensee has a distribution for the 22_
frequency, so much the better, because then they can even 23 argue qualitatively, they don't have to quantify things.
24-MS McKENNA:
No.
No.
25 DR. APOSTOLAKIS:
People get scared'when they hear
(]
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about numbers, but:you can give a qualitative argument.
You
\\.
)
x 2-know, the distribution might chacqe a little bit here, but l
3
'it's not important.
Or even if-I have a point estimate, 4
yeah,.I can't quantify it, but I don't think it's more than
)
5 a factor of two -- you know, these kind of argument.
And l
16L
'for. consequences, why not use LERF and do the same thing 1
7 with the accident sequences and argue about the frequencies?
8 So'I don't have to worry about consequences, I l
1 1
9-don't have to calculate them.
I'll say again the same thing I
10
-- push a button, this is. the accident sequence that leads 11' to LERF, and now'how does my change affect that frequency?
12' As~sn' example, NEl'has on page 2-3 a change.to a 13
. cable tray that may affect the redun:!ancy of separation of 14 systems assumed'to be redundant in the SAR.
They say this
()
. 15' falls under 10 CFR-50.59.
16
~ We'have the IPEEE.
You have used five, you have 17 screened-out the location.
The fact that you changed it a 18 little bit using the guidance EPRI has given all these guys, 19 it's a trivial. matte to determine whether that change in the 20
. cable t' ray, okay, if it's' separation, for: example, between
'21 two trays, whather'that. thing has any impact.
22 HMS.LMcKENNA:
Yes.
23 DR.'APOSTOLAKIS: ~Anybody who has done a fire PRA 24.
~knows that.
-25
_MS. McKENNA:
Well, I-think this.is:the kind of I
l 1
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68 thing.that I~think would fall within the set of what we're
.1 f
[. "4 talking about in. examples.
One of.the examples might be 2
W 3
very much what you were saying in terms of if you're looking 4'
at probability of equipment relfunction, for instance, that 5
an argument or an example that -- if you looked at that t
D',
6 equipment malfunction through a PRA or other technique 7
that's modelled-on that and determined that the increase b
18 that you might see from your change is a factor of two and a 9 d factor.of five would have no impact on your core damage-
~
10 frequency or your most signific6nt sequences could certainly 11 be a basis for making a minimal conclusion.
t.w
[
12.
i DR. APOSTOLAKIS:
Yes.
13 MS. McKENNA: 'Yes.
g (:
14 DR. APOSTOLAKIS:
I think that would be great.
In O
h.
[ s_hl 15 fact, again, I want to make it very clear that this last 16 comment.is separate /from what we were discussing earlier.
17 MS. McKENNA:
Yes.
No, I agree.
You're right.
18 Yes.
to 19 DR. APOSTOLAKIS:
So I think both -- I mean,
]
h 20
/whatever agreement you come up with NEI at the end, the IPEs s
2 11
.should play a bigger. role than currently are assumed to be 22
. playing,'and I'm willing to go along with two footnotes on m m.-
23 every;page to; satisfy.you guys,.one for you to use IPE to l
n 24 tihef entent practicable, 'and one for them, you don' t have to j
]
doLit, it's optional.
25
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'l MS. McKENNA:
Yes.
O 2-DR,. APOSTOLAKIS:
So everybody will be happy.
V 3~
Right, Tony?
~
And'I think the other point to keep
~4-MS. McKENNA:
4.
,'5
'in mind with respect.to'the question of examples or.some
.[<m-
'6'
, guidance and.such, that that, you know, if it's --
q
.7 J DR. APOSTOLAKIS:
I think it's there.
I'mean, we m
O' have tliem.
They're computerized.
In the vast majority of
'9' cases,fthe evaluation, the. qualitative. evaluation should be-10 trivial.
11" MS. McKENNA:
Yes.
K 12-DR. APOSTOLAKIS:
Now, as we become more i.
{
L 13 sophisticated,..we may, later, you know, in five years,. start 14' using risk achievement work to determine what's important j(jh
/~
15 and so on.
But right now, I' don't want to push it too far.
16 MS '. McKENNA:
Sure.
Just in terms -- I'm saying, I
17:
in terms of, say, an example or some guidance along those d
j '
I 10i lines --
i g
' 19
'D'R.
APOSTOLAKIS:
Yes.
That would be nice, as 20 MS. McKENNA:
I think the other point to keep in 21 mind'is that we.do~have to have something that's capable of
-l 22 c'ommon' understanding between --
l 23 DR. APOSTOLAKIS:
Sure.
' 24 MS. McKENNA:
-- licensees and staff such that if G
25 we say, okay, as long as it's -- there's no increase in CDP i
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s(b 70 or within this order'of magnitude or whatever, that we would 2
-all agree --
3 DR. APOSTOLAKIS:
Good.
L
' 4 iM S. M c K E N N A :
-- it's not -- it's not -- it's less L
- 5 than -- it's minimal, perhaps that could be an approach.
i 6
Then, of course', you'always will come back to questions.
7f about'do we agree that they did-the evaluationlin an i
L 8'
appropriate way,.but',-you know --
9 DR. APOSTOLAKIS:.Yes, but, you know,.that's there
)j x10 anyway.
117 MS. McKENNA':
.Yes.
_Sure.
l-12 DR. APOSTOLAKIS:
See,.let's not forget that, I
13 That's there.anyway.
. I i
14 MS. McKENNA:
Yes.
I
-(N
' 15_
DR. APOSTOLAKIS: :But you don't have time to.do g.
I 16 this by the 10th of July, do you?
l l
17-MS. McKENNA:
No.
No.
No, we' don't.
1 i
18 CHAIRMAN BARTON:
If they work this weekend,7 they l
19
- might, 20 DR. APOSTOLAKIS: 'Well,'but that bothers me, 21-
.though, because I think it should be there.
H 22' CHAIRMAN BARTON:
YeF.
I.*
23 DR. APOSTOLAKIS:
So we should perhaps --
in i
ic.
- 24:
CHAIRMAN BARTON:
Let's make a strong suggestion:
- 25 along those lines.
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l 71 I
F.
1 DR. APOSTOLAKIS:
-- make a strong statement and
)
2 see what happens to it, because, you know, this is something 3
you have to think about, obviously.
l l
4 MS. McKENNA:
Yes.
And I say, we certainly would 15 not be adverse:to'more time to deal with this.
I think l
[
6 going in, July 10th we saw as a very' difficult schedule to l-7 meet, but we were not given any relief from the Commission, 1
8'
'so we have been endeavoring to meet that.
I
-9 DR. APOSTOLAKIS:
But the thing is, we shou 3cn't j
J 10 really spend our time and effort.trying to define things 11 that are inherently indefinable.
Minimal change in this,.
)
'12 minimal change in that -- it's the context that determines what's minimal.
i 13 L.
.14 MS McKENNA:
Yes.
(,,/ -
515 That's -- oh, I'm sorry.
Go ahead, Stu.
t 16 MR'. MAGRUDER:
This is Stu Magruder from the 17, staff.
18 I just wanted -- Gary Hollahan's not here and I'm
-19 sure he would want somebody to say that the IPEs were l
l L
20
-reviewed in varying degrees of rigor and they weren't 21-
. reviewed with this purpose in mind, and that we probably 22-
- have many years' review to go before we could even allow-a 23' licensee to voluntarily use IPE for this purpose.
I don't e
E 24 know a lot of details about that,'but I-can imagine Gary 25?
saying that, a
l J
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L 72 1
DR. APOSTOLAKIS:
I know.
And let met cite our
' (~}
2 letter of the 16th of December of last year, Observation 1.
l
%J
\\
3 When we talk about using IPEs or PRAs, immediately the 4
questions of quality come up and so on in the absolute, in 5
an absolute sense.
l l
6 MS. McKEtiNA:
- Right, j
7 DR. APOSTOLAKIS:
The right way to approach it is l
1 l
8 to ask yourself, if I do it in a different way, like I
i l.
9 qualitative evaluations and all that, is that better?
1 L
l 10 That's really the question, not whether the IPE has been i
l 11
. reviewed to everybody's satisfaction.
12 It I bring information from the IPE into what I'm 13 doing now, am I going to improve things, okay?
So I think 14 if you look at it that way, the answer is yes.
Even though I
A
.iv) 15 the IPEs are not up to the standards of the best PRAs and so 16 on, they can't be worse than just looking at the thing and 17 making an evaluation, you know, qualitatively.
That's my l
18-point.
19 MS. McKENNA:
Yes.
20 DR. APOSTOLAKIS:
December 16th, Observation 1, i
i 21 got us into trouble with the Commission.
I I
22 DR, MILLER:
I would say we would want the I
23 industry to quote on that conclusion.
I l
24 DR. APOSTOLAKIS:
I'm sorry, what' 1
25 DR. MILLER:
We would want the industry maybe to 1
I l
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u y 73 j
- .),
1
. makeycormnent on that concibsion.
(
.2.
DR.-APOSTOLAKIS:
Oh, I'm sure that when they sit f
3.
'there, they will.
+
.l 4
So are we --.
J w
5 DR. SEALE:
You know, you're talking about x
y f6}
- comments you migh$ makelto'the Commissio'n and so ca.
i k.L 1
',7 : -
'DR. APOSTOLAKIS:
No, I~didn't.
,L 8 t CHAIRMAN BARTON:
.Yes, you did; You 'said-'--
1 q
59
.DR. SEALE:
It strikes me that one of the real~
~
i;$d
.10f
[ problems?here is that there is, in fact, an awful 1.'ot of
)
.sq r
? interaction here with other things, 'and we need to-be very ilt
' 12 eareful~that we address thefissue fully and not go'out and c
13 ~
-find a'"so)ution":that really~provides - -or develops real A ;34
- problems for other parts of the process, and in that regard,
~
,JT, 1S ij "when and.if Gary, decides-he_would like'to share with us.some di6:(
thoughts on these' tiiings,oI'mlsure we would be very 1
117.-
intierested$in hearing 1what, they are.
So, you know --
w 04
[18':
l DR; APOSTOLAKIS:
Good.
. s*.
19.
CHAIRMMUBARTON :
Let's take.a break'for about 15 i
s,
- 20 minubes.
Weill be back at 20:after ten.
L21
'(Recess'.}
A,7. <,. 2 2 i:l CHAIRMAN BARTON:
Let's go'back in sassion and let
$$34 LEileen, finish up'her presentation'so we-call grill her till g
97 :.
I:2i 11:15 becaus'e-NEI.is.not ready until 11.:15.
25 DR'. MILLER:
9
_ John', could I R
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1 CHAIRMAN BARTON:
Yes.
George isn't hero.
You
(')
2 wanted te ask about something George said?
V 3
DR. MILLER:
I wanted to comment on a comment that l
(
4 George made, but he's not here.
1 could sti.11 pick up that,
{
l 5
I suppose.
l l
l 6
CHAIRMAN BARTON:
Do want to wait until he ccmes l
7 back so you guys can go at it -- we need some time filler
)
i B.
here.
9 Go ahead, Eileen.
We'll wait until George comes l
10
- back, i
11 DR. MILLER:
I would like to come back to that I
I 12 slide is all.
I i
i 13 MS. McKENNA:
Okay.
I'll leave it on then.
I l
I 14 think that I covered the major points with respect to the
.fx
)
15 rule.
There were some other topics that were discussed in
\\_/
l 16 there.
We calked about these before -- the USQ term and I
17 cafety evaluation, calling it evaluation, and trying to j
18 clarify a little bit about safety analysis report and things l
19 like that.
20 The other thing I'll'just comment, I think you saw 21 in the package that we are trying to do a Part 72 change to 22J
' conform the requirements for the ISFSI-MRS storage cask 13 facilities.
Thereis going to be, I think, some additional 14 tuning of that language to make it match a little'better 25 with some of the unique aspects -- the language of exactly
[]
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l',
how you phrase the definitions and the criterie will be 4 fm 2
'slightly difforent.
h o
3, There may be'a few other changes to capture some l:
l, 4L issues.they are working with.
For exampln, for the
'S
' reporting requirement the reference right now is to where to e
a;
.6
-file the report is kind"of an obsolete, old reference, so 7
that pick up that as part of this package, so I when't 1
8 planning to go into much detail on that but just to note p
- k..
9.)
that that'is the current plan to do a.Part 72 change in 9
10:
. parallel, i
11 CHAIRMAN RARTON:
And that's it7
/
l 12 MS. McKENNA:
Unless there were other, questions i
133
- about elements of 'the rulemaking package of 'what-we were 14 trying'to accomplish.
L
' 15 -
CHAIRMAN BARTON:
Well, at'least.what I think I-516-got out of this, statement of considerations and a page, 17 page and a. half which talks about rule language as proposed' l
18-and there's a 50.59. piece of:that, which is about a page and
-19'
'a half, and.it goes'to 50.56'and up and up and up; 20 MS,LMcKENNA:
Yes.
'21 CHAIRMAN BARTON:
And this is what you are L.
22
. proposing to be the rule change for 50.59, right?
23
-MS.~McKENNA:
Correct.
Right.
L CHAIRMAN BARTON:
And if I look at;page 2 of that,
-25
.I' guess it is-Item 2, paragraph 2?of whatever, it' talks u
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about licensee shall obtain the. amendment to the license 2
pursuant to -- that is S0.90.
3 MS.,McKFNNA:
50.90 is the part of'the regulation
- 4.
that describes --
5 CHAIRMAN BARTONE The significant hazards and that
'6 kind of stuff?
'7 MS. McKENNA:
50.92 is the significant hazards,
- g 8
CHAIRMAN BARTON:
50.92.
9' MS, McKENNA:
The set of 50.90 through 50.92 10 define how a licensee requests an' amendment.
'11 This was one of the changes that I~ kind of i
L 12 referred to as formatting --
1 13 CHAIRMAN BARTON:
All right, but it still talks l
1
.14
,about probability of occurrence, accident PC evaluated is f[ )-
l15
,more thanl minimally -- here we have.got a whole bunch of l
- s-l
'16 minimally increased, which I take it are new words.
17 MS. McKENNA: L Ye s. >
, 18 :
CHAIRMAN.BARTON:
And but yet we are struggling l
191
'with defining minimal, right?
Didn't I also hear that?
{
20 MS.-McKENNA:
Well, I think that the --
21 CHAIRMAN BARTON:
So what does this mean? -- the
- 22
. probability of-the occurrence of an accident previously 23 tavaluated'is more'than minimally increased.
e a
24 Did we define someplace " minimal" -- did I miss 25 it?-
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MS. McKENNA: 'That'was the guidance about minimal
',/7' 2
'in;the statement of considerations, the qualitative view of t\\
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3 - = theLainimal'beingfsmall enough that it would not have
)
s 4
affected the basis for licensing and then the guidance that l
5 attempted to amplify how that applied to probability and
)
~
1 54 6~
consequences.
- q. J 7
DR. MILLER':
Somewhere I thought in there it was 8
minimal is described as more than negligible.
l I
9' CHAIRMAN BARTON:
Yec, that's --
i
- t 10 '.
MS. McKENNA:
Yes.
That was --
n 11' CHAIRMAN BARTON:
That-is what-I am looking for.
l 12 MS. McKENNA:
-- going back to the SRM.
,. 13. -
CHAIRMAN BARTON:
That was in the SRM.
.14 1DR. ' APOSTOLAKIS :- That surely bounds it.
v.
-15 MS, McKENNA:
It would be.more than minimal and 16 less than significant.
17
,DR. MILLER:
I had trouble dealing with that.
L18' -
MS. McKENNA:
Well, that is why I said we had s,
,19 -
wrestled with it a little bit ourselves.
I think one of the 20 things we are trying to say is that by shifting from the 21' language of may.be increased to no more than minimally 22 increased,-you have removed some of that uncertainty band, 23:
sthat'if somebody really looked at it a particular way they 12 4 might think it may be increased but by no stretch of the 25 imagination'could you call it as'more than minimally i
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increased and that those' changes you would proceed.
)
i )
^2
,I think that's clearly a set of changes where
\\m) l L
L3 everyone would agree that it is definitely more than minimal
)
1 4-and it's -- there's always a difficulty with:this process is
{
5 drawing that line, because that really is what the process
-6 requires a licensee to do is to say -- make a yes/no 7
answer -- yes, I can proceed without approval or no, I 8-can't.
-9 The rule language would allow them that
'10
~ flexibility.
If they chose to follow-the guidance they are 11-using now of no increase, then that would certainly meet the 12-flanguage.
11 3 DR. APOSTOLAKIS:
Now with.IPE though Inthink you
-14 have a nice definition of what is minimal.
It depends on 15
.the context of what --
.16-MS. McKENNA:
Yes, I think it does depend on --
17 DR. APOSTOLAKIS:
-- the accident sequence.
-18 MS, McKENNA:
I would agree it' depends on the 19 context.
I think the criteria.that we are referring to are 20~
.still based more in.the licensing basis analysis --
21 DR. APOSTOLAKIS:
I know.'
22 MS. McKENNA:
-- that is provided and you have to 23 make that connection.
- 24 DR. APOSTOLAKIS
That is where the IPE I think-25:
can'really be useful,.so you don't have'to-worry _about
(
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actually defining minimal in an absolute sense.
The minimal D
[b -
2 cut set will tell you what is minimal and what is not, so l
l 3
that could be the way out of it.
{
l 4
.MS. McKENNA:
I think~it can help in terms of 5
looking at whether the accident probability has increased or
~
6.
the particular equipment malfunctions that may have been
-7 affected by your change, but it is a more -- it is a limited i
l 8
set obviously that you are looking at.
m 9
DR. MILLER:
George, I did want to pick up on your 10 conclusi~on there, just maybe it into question slightly.
11 You drew the conclusion, which you are following 12 up on, that the use of IPE is always going to be superior to
'13-qualitative-judgment or minimal.
I am not certain I am i
14 ready.to buy in on that because the IPE=is still based upon 15 qualitative judgment someplace.
16 DR. APOSTOLAKIS:
The judgment is always the same.
' 17 -
It just gives you a context within which to make that 18 judgment.
-19 DR. MILLER:
But you are still saying --
20 DR. FONTANA:
There is also more rigor in making a 21.
judgment 1
22 DR. APOSTOLAKIS:
Yes, because a minimal cut set I
23 that is negligible because frequency is' negligible, the 24 minimal change there could even be an order of magnitude.
25-It is still negligible.
- [^ -
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'80 l
1 A minimal cut set that is contributing to the core rw 2
damage f requency now in some way -- maybe it 's a maj or b
3 contributor to risk or'one of the second tier -- then 4
minimal acquires a different meaning there.
See?
It gives 5
you the context within which you make that judgment, but the 6
judgment is still needed.
7 It is not a quantitative evaluation.
8 DR. MILLER:
No, I understand it is not l
[
9
' quantitative.
It's just the -- in the essence you are 10 in'dicating that independent of quality IPE would be superior 11 to qualitative judgment of an engineer on site.
12 I am not certain that is necessarily always true, i
13 I think it would be very helpful to have that, and maybe in 1
-14 most cases it would be true.
[~T 15 DR. APOSTOLAKIS:
In most cases you don't need the
(
16 IPE.
Still, you are still screening --
17 DR. MILLER:
Right.
j l
18 DR. APOSTOLAKIS:
-- using current criteria,
)
1 19 because in most cases a decision is easy, but when the 20 decision is beginning to be a little more involved, then you
\\
21 go to the IPE, so it is not in lieu of, it is an additional
'22 element that helps you in some cases where your judgment may 23 be called to question.
That is all I am saying.
24
'DR. MILLER:
Okay.
That didn't come through.
It 25' came through that you would say it's always superior --
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.: 1 DR.'.APOSTOLAKIS:
Oh, no.
No.
-:2 DR. MILLER:
I would say it would definitely be a
- 3' contributor to.the qualitative judgment that Eileen has on 4-the slide thee.
l L
5-
.MS. McKENNA:
I think:the other point I'd make is 6
.I think this,may be an area where the guidance could evolve
. 7 that the rule change to' minimally increase, at~ this point we R
8-may be dealing with qualitative kinds of arguments and could 1
9 develop a'more specific type for. equipment malfunctions that-j
~10 is based on some estimate, shall we say, of how it-
'11:
contributes as-one way of approaching a minimal.
Certainly
~
12-that is quite a~ good possibility.
_13 DR. MILLER:
By the way, on the concept of minimal j
'14 the-*e was some discussion at the' ANS meeting recently in m
!(
)
15
> Nashville on this whole issue.
%f 16'
-MS. McKENNA:
Yes.
9 17 DR. MILLER:
I have'to say all the discussion was
-18 somewhat over'the map but there was the' number.
Minimal
'19 mightlbe defined as 1 percent of core damage frequency and 20
-there is a lot of discussion of once you put a number on l
21 this minimal, is there any view from-the Staff on putting a l
22:
' number to minimal?
I can tell you what it would'be for 23 industry but I'll let them tell you.
1
~24-MS. McKENNA':
Let them tell us.
I think, as I l
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' mentioned earlier, we originally had thoug e about doing i
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.12 that with probabilities'and the numbers were in the range D( )
2:
that you mentioned.
3.
In discussing it with others among the Staff I 4
'think there was kind of two schools of thought..One is that 5
having some numeric is.useful because at.] east it gives you 6-a target to shoot at.
The other point was that the 7
numbers -- I think this is the kind of contextual thing --
l8
'is that the number,.it may be too small and it may vary, 9'
-depending on a' number of different factors, and therefore I 10 think the consensus was that it was not going to be useful i
111 to=try.to.have those kind.of absolute' type of numbers with 12
. respect to probabilities.
L 13 DR. APOSTOLAKIS:
See, when you discuss-this thing L
14 tyou'are~now going way ahead,.because you are trying to l f%.
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15 define the green region there.
l 16-MS. McKENNA:
Right.
17 DR..APOSTOLAKIS:
And there are two distinct L18
' issues 1here'..One is, forgetting about 1.174, I am doing it
'19 thefwayfI am'doing-it now.
In some cases I pull out the L
'20 minimal cut set and I make'a judgment, okay, and minimal is L
relative then.
I
' 21 '
'22 What we are going to have in five years will be 23 performance-based,.in which case we will modify 1.174.
We 24 haveLthe. green region there and we are saying even if there p
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83 1
whatever you like but when the delta CDF and delta LERF
[J) 2 becomes positive or greater.than 1 percent or whatever, then 3
you enter 1.174, in which case we have to review it.
1
)
4 So there are two separate things using the minimal
)
5 cut sets versus defining one percent or whatever, because 6
you don't need the green region there to use the minimal cut 7
sets in the current 50.59 application to make a better 8
judgment, and I want to make that very clear, that we are 9
talking about two different things.
10 The green region is something for the future 11 because I don't think that the industry or the Staff are 12 prepared or willing to go that far right now.
13 IHl. MILLER:
Well, I think that part of it was
?~
there were those that are extrapolating between minimal, 14
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15 defined here, and what was in 1.174.
16 MS. McKENNA:
Very small, yes, negligible --
17 correct.
j l
18 DR. MILLER:
I think that was one of the issues j
19 that came up.
j 20 DR. APOSTOLAK19:
But eventually I don't think i
n 21 that we have to review all the changes in delta CDF and 22 delta LERF, because if they are minuscule, why?
23 DR. MILLER:
Kell, many made comments again at 24 these meetings which say one percent is not definable 25
.because you can't measure it.
.[
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DR. APOSTOLAKIS:
I don't know if it is one 2
percent or will be a shaded region with fuzziness -- but 3
that is something for the future.
4 As Eileen pointed out earlier, that is probably 5
more appropriate to investigate in the context of a revision 6
of 1.174, rather than 50.59.
7 DR. MILLER:
I just hope we don't revise -- once 8
we get dono this time, I hope we don't revise 50.59 for a 9
long time, yes.
10 CHAIRMAN BARTON:
It withstood 30 years and we're 11 mucking with it now.
12 What is your plan, to take this proposed revision 13 to 50.59, statement of considerations and put it out for 14 public comment?
Is that where you --
15 MS. McKENNA:
What we would propose is that --
16 CHAIRMAN BARTON:
Yes, what is your bottom line, 17 here?
18 MS. McKENNA:
It's to make some modifications 19 based on the comments and some in the areas that I mentioned 20 today, get the concurrences within the Staff, send it to the 21 Commission for their review, and if they approve, to publish 22 it for public comment.
23 I think some of the comments we made earlier is 24 that there are some lingering issues, and I think it was 25 alluded to with respect to the COMSECY and that we don't l
1 9
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~
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1 know where the Commission is at this point.
That may affect J '"%
2-that, but thatLis kind of our game plan would be to proceed f:u-)
3 to move this package with the modifications I indicated l
f4 forward to the Commission for their consideration.
5 DR. APOSTOLAKIS:
So we will not have a chance to 6
review that package then, is that right?
l 7
MS. McKENNA:
It is -- it would not be dissimilar 8
from this.
9 CHAIRMAN BARTON:
Pass this over to George.
You 10-probably got it.
Just give me that back -- just to 'show you 11 what --
12 DR. APOSTOLAKIS:
Oh -- do I have that?-
13 MS. McKENNA:
Yes.
14 MR. MARKLEY:
Yes.
,-~
15 CHAIRMAN BARTON:
Of course you do, George.
It
.16 came with a --
17 MS. McKENNA:
-- a memo --
'18 CHAIRMAN BARTON:
-- memo.
19 DR. APOSTOLAKIS:
Okay, but they will not have the 20 benefit of our letter from the July meeting because our 21 letter will go to the Commission later than the 15th or the 22 10th.
23 CHAIRMAN BARTON:
We are meeting on this subject
'24 on the 8th.
25 DR. APOSTOLAKIS:
On the 8th.
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CHAIRMAN BARTON:
This is on the agenda for the r-l 2
8th.
So the letter would be out on the 10th.
Our letter 3
would leave here on the 10th.
4 DR. APOSTOLAKIS:
Eleventh, 12th, 5
CHAIRMAN BARTON:
So they would get it the I
6 following week.
7 DR. APOSTOLAKIS:
Yeah.
8 MS. McKENNA:
The schedule is a difficult issue 9
right now.
l
.10 DR. APOSTOLAKIS:
Yeah, because --
1 11 MS. McKENNA:
I think I had mentioned, you know, 12 we have an SRM date of July 10th that is right on our 13 doorstep and we are not ready at'this point, I think, to 14 really satisfy that schedule.
We are doing the best we can
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15 to get as close.as we possibly can, resolving the issues 16.
that have been put forward and finalizing the package.
17 Getting everybody's concurrence is no small task, and I
.18 think where the Committee's letter will play in is really 19 going to be a function of the progress we can make, whether l
20 we. hear anything further from the Commission, and those 21 kinds.of issues.
22 CHAIRMAN BARTON:
This package is the product of 23' your -- of the Callan response to the Commissioners, that is l
24 what this?
25 MS. McKENNA:
Yes.
It is, it reflects what we
/ N.
l 1
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have proposed to the Commission.
(~'s 2
CHAIRMAN BARTON:
What you have proposed to the V
3 Commission.
4 MS. McKENNA:
Yes.
So that's why I say, if we get 5
feedback from the Commission that, no, we disagree, you 6
know, we want to see this, consequences having acceptance 7
limits or whatever, that we obviously need to modify the 8
package to respond to their directions.
So that's what I am 9
saying, there's a degree of uncertainty about exactly when 10 we can have something that is ready for the Commission to 11 act upon.
12 DR. APOSTOLAKIS:
Well, the point is that you will 13 not have the benefit of our letter.
14 MS. McKENNA:
Correct.
At least in that time --
I
)
15 unless, you know, so depending on how our schedule really a
16 plays out, I think there is certainly a good likelihood that 17-it is going to be on the table at the time we are still 18 finalizing our package.
To the extent to which your I
19 comments would lead us in a different direction is obviously 20 something that would have to be taken into account.
- And, 21 hopefully, we can get a sense from where we are today.
22 Maybe -- I think some of the introductory remarks, you had 23 indicated that you had some disappointment with where we 24 were with the COMSECY and perhaps you could --
25 CHAIRMAN BARTON:
Yeah.
With your response to the i
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SRM.
That's right.
- ~
l 2'
,. (_)
MS. McKENNA:
-- share with us where you think we 3.
were falling short.. We can take that into account if there
~
is points you wou1d think that we are not being responsive 4
.5 to what was asked for or were taking the wrong approach.
-6 MR. MARKLEY:
Before you jump into that, 7
MS.-McKENNA:
Sure.
8 MR. MARKLEY:
Can I ask, is the Regulatory Guide
.9 going to be going up at the same time with this, or when is l
10
.that going to become available?
11
. CHAIRMAN BARTON:
-Oh, this.is the one that ties to 12 the 96-07 document?
13-MS. McKENNA: ; Yeah.
The Regulatory Guide is a bit 14?
- of problem for us because we are endeavoring, as was
.,3 i )
15.
mentioned earlier, to endorse 96-07.
I think many of the
.16-changes that we are making will make that easier, because we 17 will be' converging on.the positions that they espoused.
18,_
There are some areas that, obviously, the 96-07 l
.19 might need to be adjusted depending on exactly what rule t
[
.20 changes go forward.
For. instance, if the rule language is j
21 more1than. minimally increased, that would need to be 22~
. reflected'in'the document, at least as what the rule 23 language.provides.
It may or may not affect the guidance i
< 24-that is provided, but at.least'the-language would need to be L25~
included-therein.
So, obviously, some of those kinds of
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1 issues wculd need to be. addressed.
i.
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2-
.I think we mentioned earlier the question on
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3 consequences, that what.we are proposing'is minimal increase L
4 in consequences, that scenario, that the guidance may need l
5-to'be adjusted.. Margin of safety, depending on exactly 6
where Sne come out on that, there may need to be some 7-adjustment to the-guidance.
8 I think the other area in 96-07 that we have been 9
wrestling.with, as you recall, we did send comments out in 10
. January _and have not really had a sit-down to discuss the 11 comments and how they relate to these things.
12 CHAIRMAN BARTON:
You haven't met with NEI since 13.
.then?
14 MS McKENNA:
Not on 96-07, no.
One of the issues
^/
!,~._,)
that we are trying to understand in the guidance is the 15 16 relationship, the guidance on: screening and the guidance on-17 changes that require evaluation.
There's a question in our 18 mind as to whether the screening is both a screen as to 19 whether.it fits within the scope of the rule, and a screen 20
-as to significance.
Some of the words would lead us to 21
~ suggest that, which we are not sure is consistent with what 22 is required, but it is something, you know, I think we 23 needed to explore a little more before we could say what j
24 exactly we would -- whether we would agree with that in the 25 Reg. Guide or would want to make some clarifying comment.
I j] -
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i 90' I
1 CHAIRMAN BARTON: 'The letter.you are referring to, l
. ("
/2 is that the Collins-letter?-
1 I
3 MS. McKENNA:
Yes.
Yes.
4 DR.' MILLER:
Is that the only issue -- those are N
5
-the issues you are --
l 6'
MS. McKENNA:
I think that's -- there were some 7
other more, I guess I will call them editorial or clarifying 8
kinds of questions that may arise.
9 DR. MILLER:
So this Reg. Guide could endorse 10 96-07 but with probably --
'll
-CHAIRMAN BARTON:
Some exceptions.
12 MS. McKENNA:
Yeah, some exceptions.
13 DR. MILLER:
-- some exceptionE.
It sounds like.a 14 fair number of exceptions.
1 J
15 MS. McKENNA:
No.
Well, I mean I think there's 16 certainly a question as to when NEI sees the rule. change-17
-language'that is being offered, they may, some of those may 18 be willing to make in their document and others they may not 19 and that would, of course, influence what kind of a 20 Regulatory Guide we could offer.
21 CHAIRMAN BARTON:
In other words, they would look' 22 at the rule and then you all might get together they might 23-change 96-07 again.
'24 MS. McKENNA:
Yeah.
In certain respects, and
~
there may be others where tb-x'). act agree with us and l
'25 L
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1-not;want to change their document.
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2r CHAIRMAN BARTON:
Then that would identify the
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=3 4
'MS. McKENNA:. Yeah.
Then the Reg. Guide would 5"
'have.to'say moreithan,just:we endorse the document.
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l 7
DR. MILLER:
I. thought one of the differences was
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- 8 When'you' change a component within a system, whether you a
(
9'
~ evaluate the effect on the system or the effect 10 CHAIRMAN'BARTON:
Versus the component.
i 11 DR. MILLER:
But that-was also one.of'the l
1 Y12 differences between your position, the staff position, and D'
13 also the 96-07.
i
> 141 JMS McKENNA:
Well, I think that was --
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15 DP. MILLER:
Maybe they would come to closure on
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16'
'that one.
j l
17-
~MS. McKENNA:' Well, I think that was withLrespect to' malfunction of a different type, was'really where that l
18 19
- arose, l
20 DR,' MILLER:
Right; L21 MS. McKENNA:
And the Commission also asked us to 22" look into the question of malfunction of a different type, 23 jand I think we, in doing that, agreed that the type maybe i
24-
.was not the characteristic of the malfunction that was what l
<251 was really'important-from the perspective of impact on the p
[].
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r-l 92 1
1
' safety'and licensing' basis of the plant, that it was really L j-(
'2 whether the' outcome of the malfunction had already been
]
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considered and evaluated.
So - -
74 DR.' MILLER: 'It's'close to the 96-07 position.
l 5-MS. McKENNA:
Yeah.
And.that's -- so that what we 6
proposed in the rule package'was to adopt the language of i
J.
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g 17 malfunction'with a different result, which.will lesson some
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8 of:those concerns'about system versus component because you
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9 are focusing more on the outcome on the facility, rather i
10 than did the component fail!from a different mechanism, 1
J 11 Yes.
l
=12 DR. MILLER:
Okay.
1, 13' MS. McKENNA:
1-think we have talked about the 1
l 14-other things that were on the agenda.-
I think the question j
p
' 15..
of what we -- the benefits'of the rulemaking:was, hopefully, I
4 L\\_/
16 if we-can reach a common understanding of the requirements, l
17 that'that'will be a benefit to all concerned.'.
J!
118' Contribution to safety.
I think that to the 1
19 extent'that the process-is rigorous, that it allows changes; 20 that are not significant to proceed without our review and'
'21
-approval and allows everyone to focus on what.is important, 22 will all be benefits.to safety that we hope will be achieved
- 23 through completing this rulemaking.
g 024 I think we have talked already on the schedule, l
25 which.is a.little hard for me to be definitive on, for the L
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- jg 93 1- ' ~ reasons that I'have already mentioned.
And I apologize.that
-2
/we.can!.t be a'11ttle more definite on that, but there's too b
- 3 -
nuny_variablus to really make a good prediction, j
44
.And'that was what I wanted to present to the 4
5!.
Ccamittee, and certainly.there's too much time left on the L
s L
6
' agenda for' questions.-
'7 JR. APOSTCLAKIS:
That's fine.
That means we can 8-think.
l i?
9
'MS.-McKENNA-Yes.
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' 10.
DR. APOSTOLAKIS:
Ergo, we exist.
11' CHAIRMAN.BARTON:
There you go with that Greek 12 again.
13-DR.'APOSTOLAKIS:
So what are gcing to do, Mr.
14' Chairman'.
Another. break?
- 15.
CHAIRMAN B'ARTONi Tony,'are you ready,..or do'you s
l' 16
'need -- are you ready?
4 17-
'MR. MARKLEY:
I'm.reany.
- 18 CHAIRMAN BARTON:
My lawyer over here --
Es i -
- , 19 DR. APOSTOLAKIS:
.It's beautiful.
Dreak then.
l-
- 20 DR. SEALE:
What'were you going to. break, the i
L, 21 lawyer?
h,'
22 j MR. MARKLEY:
John., are there things you would 23' like her to address at the full Committee?
I JR. SEALE:
That's a good point.
25=
CHAIRMAN BARTON:
Yeah, I think for the benefit of
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1 h'
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other members that are not at this meeting, probably at the l
(~/}
2 full Committee -- no, you can't go through this because it
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3 is not a public document, a public --
4 MR. MARKLEY:
They can talk about it, but, you 5
know, sharing the written information is different.
6 MS. McKENNA:
Which is partly what we attempted to 7
do in many respects today with --
8 CHAIRMAN BARTON:
But it is not really as --
9 talked about today isn't really as well defined or as clear 10 as to what -- what are the word changes in here.
11 DR. APOSTOLAKIS:
Eileen, could you --
12 CHAIRMAN BARTON:
Can you talk about that in the 13 July 8th?
To kind of give us a real feel as to what is 14-really going to change.
~s
/
)-
15 MS. McKENNA:
Okay.
I think with respect to the
%)
16 rule language that you see here, tue changes that we are 17 likely to see are, I think on the definitions that we are 18 looking for some minor changes.
You know, like, for 19 instance, that the change facility is defined, and there was 20 modifications, subtraction, correction, supplementation, 21 say, well, that's a little wordy, we are going to streamline 22 that a little bit.
23 The other area is I think the actual rule language 24 on margin of safety is up for grades as to -- I think what 25' we offered was margin of safety associated with any tech
(~N ANN RILEY & ASSOCIATES, LTD.
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1
~ spec, but that is kind of tied in with exactly what margins
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2-we are.trying:to ensure are evaluated through this process
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.and'that may nded,.;particularly in the definition, may need 4
some adjustment.
That is an area where I think the rule U
5 language itself would likely. change.
6 i
1 DR. MILLER: >But those changes, we will not see in 7
July, though?
8 MS. McKENNA: ' You prdoably will not see them in' 9
time to really review'for the July meeting, let me put it.
10 that way.
I think --
f 11 DR. MILLER:
So they would be able at the July 12-meeting, though?
'I realize that is the commitment on 13 schedule you mentioned.
14 MC; McKENNA:
Yeah, I.am not sure I'can promise 1
' [
15 that.
< \\_/
16
'DR. MILLER:
- Okay, i
17 DR..SEALE:
Well, we.have been known to slip in a 18
. thought-or two as aLresult of the presentation at the 19.
meeting.- 'So if.you'would like feedback on some of those 1
20 issues, I would urge you to try to be able to be a little 21 specific at that time.
22 MS. McKENNA:
Yes.
As I say, we will attempt to, I-23 it is just'that that is not that far away,.and I can't l
24.
really commit that we will have reached closure on that i
25 issue.
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96 1
CHAIRMAN DARTON:
I think what I would like is a
, ('T, 2
clear road c.ap from what you were requested to do, what you 3 _)
x l
3 think your charge was, and what you did with respect to the 1
1 4
SRM and then, you know, how does that all play out, how does 5
affect the rule change, and here is what I am going to see j
l 6
in this rule I am uending out for comment.
If you can kind l
7 of road map us or lead us through that so we can see, you
,8 know, here is what you were requested to do, here is what we 9
did, and here is how this is going to look, here is how it l
l 10 is going to affect the rule that is out there now.
If you 11 can kind of lead us through that, I think that would maybe 12-give us a clearer pictures.
l 1
13 MS. McKENNA:
I may just -- give me a minute here.
14 DR. APOSTOLAKIS:
You mentioned that you may
)
, '( s) 15-define things by example.
Do you think you can have --
t x/
16 CHAIRMAN BAFTON:
And some examples, yeah.
17 DR. APOSTOLAKIS:
Of using the IPEs and IPEEEs, by q
l 18
. July Sth.
Or even preliminary.
I mean they don't have to
{
19 be --
}l 20 UI McKENNA:
I will take that as an action to see l
l 21 what we can do.
22 DR. APOSTOLAKIS:
Okay.
l 23 MS. McKENNA:
We need to rely on our other staff 24 to provide that who are more risk-informed in the details i
25 than I am, and whether they can provide that --
I
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1 DR. APOSTOLAKIS.:
Or you can take what NEI has in U f' 2
their document, you know, the cable trays, and they have a l
13 '
3 couple of other examples, and see how these could be used in 4
connection with --
l 5
CHAIRMAN BARTON:
What document are you referring j
I 6
to, George?
l 7
DR. AVOSTOLAKIS:
The NEI document.
8 CHAIRMAN BARTON:
96-07?
9 DR. APOSTOLAKIS:
Yeah.
10 CHAIRMAN BARTON:
Okay.
Yeah.
l 11 DR. APOSTOLAKIS:
They talk on page --
12 CHAIRMAN BARTON:
Yeah, I just wanted to make sure 13 that Eileen got the specific document.
14 DR. APOSTOLAKIS:
Yeah.
Page 2-3.
They talk l
[d~D 15 about the cable trays, as I mentioned.
Then they talk about 16 the installation of a non-seismically supported piece of 1
'17 equipment.
Okay.
Changes invalidating the environmental in qualification of components, and-so on.
19 Oh, by the way, this -- I forgot to mention that 20 in the context of the IPE, the equivalent to what you have
.21 now that says, you know, there is a new accident, 22 MS. McKENNA:
Uh-huh.
23 DR. APOSTOLAKIS:
-- is that you have a new 24 minimal cutset, right?
And even that you can evaluate in 25 the context of the IPE.
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MS. McKENNA:
I don't -- I am not sure.
I think 1
73 2
the accident of a different type, I am not sure how that
(\\~)
l 3
plays out with having a different cutset.
But, ngain, I am i
4 not the right person to really try to answer that.
5 DR. APOSTOLAKIS:
Anyway, that is what it means in 6
that context.
7 MS. McKENNA:
Okay.
1 8
DR. APOSTOLAKIS:
So still you have a context i
9 within you can evaluate that.
10 MS. McKENNA:
I have a comment I will just make, I i
11 think some of the examples that you are referring to in i
12 96-07 cre with respect to issues that would require review j
13 to determine whether -- what the impact is.
They are, I 14 think, not so much a decision-making as to whether the
(~'i 15 change can proceed or not without the approval.
i V
16 DR. APOSTOLAKIS:
Why not?
I thought that ---let 17' me understand that a little better.
It says a change to j.
18 a cable tray that may affect the redundancy or separation of f
8 j
'19 systems assumed redundant in the SAR falls under 10 CFR 4
20 4
50.59.
L 8
'21 MS. McKENNA:
Right.
i 22 DR. APOSTOLAKIS:
So can we have now a couple of 23' concrete examples where the use of the IPEEE will help me or i
24 will help us deal with 50.59 in a better way?
-25 MS. McKENNA:
Let's take your cable tray example,
- r3 ANN RILEY & ASSOCIATES, LTD.
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1 where you are changing the redundancy.
Somehow you would j
[']
2L have to through'whatever, the FIVE or whatever the
, N_/
3 appropriate fire
- have some determination that the fact 4
that they are not redundant was not significant to the 5
' response to fire or something like that and therefore was 6
acceptable.
7
'DR. APOSTOLAKISt Yes.
The first step would be to l
8 go to the IPEEE and find exactly where these cable tray i
l 1
9 appear and then take it from there.
You're right.
You j
l 10 start thinking the way you just mentioned, but that would be
)
I 11 a useful thing to see.
I 12 For example, if FIVE has dismissed that as being 13 completely negligible, that tells you something.
4 14 MS. McKENNA:
But again you run into the
,,2 \\..
15 situations about, you know, where do you stand in the I
J
).
s_-
16 regulatory space.
If Appendix R requires them to be j
17 separated and you are going to say, wall, we are no longer 18 going to be separated then you may be able to use your IPE 19 and other information to justify why that, in that exemption 20 why that particular case that wasn't necessary but it may 21 not be something that could be done under 50.59 even if the 22 fire evaluation showed that it was not risk significant.
23 DR APOSTOLAKIS:
That is why an example will 24 really be illuminating, to see what issues arise.
25 I don't think they are referring to the case where f
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.you are. completely eliminating the separation.
, y-- r 2
I mean but, you know, maybe it-was six feet and
(
3
'somehow they make it five feet.
Now the requirement is four.
~4 feet uo you still satisfyLthe regulations but you have 5
changed it.
'6 MS', McKENNA:
And we have seen that 7-DR. APOSTOLAKIS:
Can,.fou say something of using 8
the_IPEEE will get you off'the hook?
'9.
MS. McKENNA:
Actually we had some examples with respect'to separation, cable tray separation where they may 10 11.
1have had a commitment to six feet, say, and for whatever 12 reason-they found cases where that was not the case and they 13.
wanted to justify three-feet and depending on which IpEEE 14 standard, wherever you looked at -- the older one may have 4
115 L
_said-six and the newer one may!have said three -- those-have
'16' been issues, d.7 ~.
DR. MILLER-George, you are saying that a PRA
.18 :
'would; pick up;a change between six feettand five feet of l
r19 1 separation?
20-DF. APOSTOLAKIS:
Oh, yes.
It's in the code.
The i
1
,[4 21; code doestit -- COMBURN, the separation is an input to the 22-icode.
023 COMBURN does this calculation very quickly, but lv
~24'
.you see 'he IPEEE though han much more-than just a code t
s 25 because theffirst part is screening.
.It tells you these 1
)
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. trays don't matter much, okay, so you don't even have to do 1.
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2 the' calculation because they don't affect redundant systems, V
y 3
you know safety systems,~so all that body of information is r
.4 there and-that is what I am saying.
l 5
Bring.it in.
It's not just the thermal.
[
6 calculations.
I mean that'is for rare cases.
PRA is'not 7
just the calculations of the heat flux and all that.
I mean' l
8 there's a whole screening process that takes place where you 9
identify the critical locations and so on, so if this N
110 changes not in the critical locations, why bother?
That is 11 what I am saying.
12 DR. MILLER:
You are really saying if it isn't in 13 the PRA, why bother?
1 14 LR..APOSTOLAKIS:
No.
/"'%
j (j
15 has dismissed it.
j 16 DR. MILLER:
Okay, right -- not having any 17;
~ significance..
18 DR. APOSTOLAKIS:
Because'it does not affect any i
19 safety' systems.
So I mean' people have invested a lot of 20' effort in screening for the IPEEE and all I am saying is 21 take advantage of it, bring it in -- they have already done 22 it.
23 MS. McKENNA:
I just wanted to go back to your 24 comment about the roadmap for a moment.
25 I think we tried to do this to a certain extent l
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the last meeting by looking at what the -- this is not in 2.
your package.
It is a' slide we used last time.
0- CHAIRMAN BARTON:
At the.last meeting, we didn't 4
have the benefits of these documents, I don't think.
.5 MS. McKENNA:
I.think you had them but maybe did
)
I 6-not have enough time to digest them.
'?
This is what was in the SRM of March 24th.
There 8
were other matters that we had raised in the'SECY paper that 9
the Commission did not weigh in on.
10' CHAIRMAN BARTON:
Right.
q i
11 MS. McKENNA:
For example, what the terminology on 12 unreviewed safety question, for example, and so the package
- 1. 3 '
you'see reflects kind of both of those-kinds of issues that i
14 we were taking on the specifics of minimal increases in l
i,D 15 probability and consequences.
Q)
'16 -
In the'COMSECY we spoke to the question of 17 reduction in margin and we are'still contemplating that to
~
~ 18 define minimal in a clear and practical manner, well, we i
J ' 19'
.have:done our best shot on that.
I won't promise that we i
~20 have been clear or practical but we did what we could.
I 21/
The interaction with-NEI -- well, that's something 22_
.we have yet to be'able to complete.
23 To evaluate certain other changes was again the 3
24 issues.in the COMSECY about'the accident of a different type 25 with minimal safety impact or the malfunctions of a e
L_m ANN RILEY & ASSOCIATES, LTD.
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'different type:which:- -
7 3
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' CHAIRMAN:DARTONi{ LOkay.
I think you'should'go.
i 1
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through that and then show the endproduct ofLthat.
?
s 4
M3. McKENNA:
Yes.
'5.
?CRAIRMAN.BARTON:' To kind of give us a-picture of 6.
how'this thing floated'and where'you ended up as opposed to 4-
'7 at the start point and where we are now.
~
8 MS. McKENNA:._Okay -- this and then we had this 9
other.one, which kini of laid out the-COMSECY issues thatLwe 10; Lwere'. proposing to do the minimal increases in probability 4.<
,11 andEconsequencesLand the Part'72,'but we are not proposing-12
'.to do the acceptance limits and consequences for instances 13 was in that other slide we had to use, so that was at least mv
,1 14; what we have' embodied'in this package, subject to-further-
':15i
' change'as time'goes on.
16 CHAIRMAN BARTON:
Okay.
Any other questions,
'17-comments at this time?
- 18'
[No response.)
1
- 19.
- CHAIRMAN BARTON:
Thank you, Eileen.
l
'20.
MS McKENNA: -Okay.
21.
CHAIRMAN BARTON:
Since we can't start until 22 11:15, I guess we'll break until 11:15.
' 23'
[ Recess.]'
24 CHAIRMAN BARTON:
Are we legal?
Plus or minus a c, 25 minute'I guess is all right.
t ANN RILEY & ASSOCIATES, LTD.
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1 j
r i
i 104 I
1 The next presentation is from NEI.
Only two
-/y.
2
. slides -- this is half as -- oh, wait a minute, back and Md 3'
front.
Four pages.
4 DR. SEALE:
Eight of them.
I 5
DR. APOSTOLAKIG:
They are green now.
6 CHAIRMAN BARTON:
Go.
7 MR. PIETRANGELO:
Good morning.
I 8
DR. SEALE:
Is that an environmental statement?
)
9 MR. PIETRANGELO:
Yes.
Appreciate the opportunity 10 to come back and brief the Committee on this important i
11 issue.
l 12-With me is Russ Bell.
Russ manages our 50.59 task 13 force as well as our FSAR update task force.
We also have a 14 Red Process Working' Group that is kind of our policy level j
fx i
()
15 committee.to help us with not only this issue.but a number 16
~of others including'all the risk-informed applications.
17 Today we are primarily going to focus on just 18.'
'50.59 and the slides we have prepared are'really a subset of 19 what we showed the Commission on June.4th'.
20 We have not included slides that dealt with the 21 FSAR update issue but we'd be happy to talk to you about 22 them as they relate to 50.59 but I think for today's 23 purposes and given that we only have an hour, we are going i
24 to focus on --
25 CHAIRMAN BARTON:
Well, that is the generic letter 1
l
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issue, right?
I
' 7x 2
MR. PIETRANGELO:
Right.
)
~
3 CHAIRMAN BARTON:
And we -- I think the Committee 4
is on record as looking at that after public comment.
5 MR. PIETRANGELO:
Okay.
So again I think my 6
understanding just from listening into the discussion this 7
morning as some of you have probably seen the transcript i
8 from the June 4th Commission briefing and some of those 9
slides, and again, most of the material we are going to 10 cover this morning was part of the Commission briefin9 11 Briefly we will have an overview of the SRM on 12 SECY-97-205 as it relates to 50.59.
I think the last slide 13 Eileen put up really spoke to that even in more detail than l
14 we will have on our slide, but we do want to spend quite a j
'~')
15 bit of titae on use of acceptance limits.
u' i
16 Let me preface that subject just by saying I think l
1 17 there is a lot more that we agree with the Staff on than 18 disagree.
19 I gather there are a couple issues where the l
20 positions are different and I think the Commission is going 21 to have to sort that out.
We will give you our perspective 22 today and be happy to answer your questions and hear your l
23' perspective on these issues and maybe that can be reflected 24 in the letter you send to the Commission later.
25 Finally, I know Russ touched on it before, the es ANN RILEY & ASSOCIATES, LTD.
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scopeLissue.
We have a couple of slides prepared in that
- 2E regard.and we see that as kind of the second phase of this
-3
' approach to revising 50.59.
4
.The March 24th SRM regarding 50.59 we think 5
provided very important direction to the Staff -- first, to 6
expedite the rulemaking, to clarify the threshold or USQ 7
criteria.
That is the part that I think has been the 8
problem for the last couple. years in terms of predictability 9
and stability in this very important process and part of our 10
' rationale for not pushing harder ~on scope now is that we 11 didn't think it would be'possible to have an expedited H12 rulemaking if we tried to address scope at the same time.
13 We haven't changed our position at all on the 14 scope issue.
We think it's very important to make those
(
);
'15 changes laterLon, but I think'this first phase consistent 16:
with the Commission's SRM is to deal with these threshold 17 criteria first and then come back and do scope later.
18-The Commission also asked the Staff'to reassess u
i i
19
- the use of' acceptance limits, both on consequences and 20 margin of safety.
They have responded in the COMSECY that I
-21 am sure you are familiar with and again the Commission asked 22 the Staff to consider changes to the scope of the rule.
23_
All right.
Let's get right into acceptance 24 limits.
25 Let me start by saying where there is a line ANN-RILEY & ASSOCIATES, LTD.
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l 1
somewhere in the regulatory framework for deciding whether
- }
2 prior review and approval is needed we ought to use it.
U 3
rather than rely on incremental changes and words like 4
minimal and things like that.
5 Eileen started to discuss that really 50.59 is in 6
fact a procedural or process oriented rule, not a safety 7
standard and that is true certainly in whether you decide 8
you need prior NRC review and approval or not, but there is
-9 also a. premise that given that this regulation is one of the 10 most frequently used in Part 50 that there needs to be some 11 safety content associated with that decision also.
12 I don't think anybody wants from a resource 13 perspective trivial noncafety significant things that have I
14 to go through an amendment process.
That is not in the
)
l f~T 15 interest of the licensee, who has to prepare that.
That is j
l w/
j 16 not in the interest of the agency that has to review and j
17 approve'that, and really it is a diversion that hopefully, 18-if we could get to use acceptance limits, we think it would i
19 help address that problem.
j 20 We think acceptance limits can be used for both 21 the threshold criteria on increases in consequences, as well 22 as margin of safety.
We think these acceptance limits have l
23 been established through the licensing process and the l
24 safety evaluation reports that the agency issues the l
25 licensee when they make changes to appropriate parts of l
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108 t.
1-their licensing basis.
/
2 CHAIRMAN BARTON:
Do all safety evaluations have t
3 the limits broken out clearly enough and the numbers and 4
stuff in them?
5-MR. PIETRANGELO:
I think it is depending on the 6
era and the reviewer.and the licensees, but it hasn't been 7
done as. consistent as we all would have liked it to be done.
8' CHAIRMAN BARTON:
But you claim that you can still 9
use them?
10 MR. PIETRANGELO:
Yes.
Yes, and this came up in 11 the Commission discussion.
There's kind of an interim fix 12 for licensees that didn't have an acceptance limit spelled 13
.out such that over the long term I think everyone would have 14 an acceptance: limit for a particular analyses-that.was
(}
15 reviewed and accepted by the Staff in an SER.
16 DR. SEALE:
How general would the interpretation 17s of anracceptance. limit be?
In particular, is it'the body of 18 SERs relevant to a particular plant or is it the body SERs D19l that are relevant to a class of plant, or is it the body 20 that is relevant to the whole fleet of plants that would be t'e appropriate reference to define' acceptance limits?
I h
21 I
22 MR. PIETRANGELO:
Well, I think first it is 23 plant-specific, but the plant-specifier limits are derived 24
.from class-specific as well as the entire fleet, so chere's j
l
'25' consistency there.
J ll.
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l 109 1-It may, depending on where the plant was sited, L f).
- 2 there may be some differences what the limits are.
V' 3
DR. SEALE:
Well, I can think of a case where an 4
issue arises that has.already been adjudicated in the 5
context of having had an SER of a sibling plant frem, say --
6' with the!same owners' group.
7 Now is that something you could bring over, or you 8
would propose that you would bring over and have as an 9
acceptable citation to justify an acceptable limit for the 10 new plant?
11 MR. PIETRANGELO:
Yes, as long as there's no
)
i
'12 differences that would alter the conclusion.
I 13 DR. SEALE:
Okay.
14 MR. PIETRANGELO:
And we think these acceptance
.(v limits are really equivalent to the technical 15 16 specifications, which are the operating limits on a
{
17 facility, and the next chart will show that.
18 If you go into the existing language in 50.59, you 19 can make a change without prior NRC review and approval 20 unless the change involves a change to the technical 21 specifications or a USQ.
There is an equivalency with kind 22 of the threshold for where the USQ should be that is 23 equivalent to a change to the tech specs, so we think this 24 next chart conceptually is the best we have been able to 25 come up with in terms of now what are the margins, what are l..
l.
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the limits, what are the nominal values, and really this is ex 2
an offshoot of a chart from NSAC-125 that had the
/
)
s'~
3 containment peak pressure, showed where the acceptance limit 4
was, ant showed where the failure point of containment was.
5 Let me go through this.
Really the nominal values 6
that define how a plant's design and operation is the inside 7
box -- that design and operating envelope -- and that is 8
kind of your normal operations envelope.
9 Then you have the tech spec one that we just i
i 10 talked about as well as the acceptance limits, and those 11 come from the safety evaluation reports that the Staff 12 issued to the licensees and a number of cases the design 13 basis, which is the reference limit for the design 14 establishes whe:
that second envelope is.
,'~')
15 Now the gap between the nominal envelope and the QJ 16 limiting envelope is what we refer to as operating margin 17 and the gap between the limiting conditions and the failure 18 points is what we refer to as the margin of safety, and that 19 again is consistent with the NSAC-125 and how the industry 20 has viewed these margins since that time.
21 I guess part of the discussion today really 22 focuses on which lines are we talking about and which
(
23 margins are we potentially impacting when we make changes in 24 the. facility.
l 25 Now first of all -- and the reason I said before 73 ANN RILEY & ASSOCIATES, LTD.
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is our preference is where there is a line we should it --
l [)
2 is-to get out of the, I think, some of the potentially i
x_/
l 3'
long-winded discussions with would have trying to define 4
what minimal means within these boxes.
l 5
Everybody knows what the tech spec values and l
6 limits are and operators memorize those and swear that they 7
will never exceed them intentionally, and it works real well 8
in practice.
)
i 9
But again we think that these acceptance limits on
)
10 consequences is also pretty well defined and I think those 11 are derived for the most part from the Part 100 criteria and l
12 there are some GDCs that also deal with firm acceptance 13 limits.
14 So we have taken issue with, and I think if you go
/N
(,f 15 back to NSAC-125 the guidance reads as long as you don't 16 exceed the acceptance limit for consequences, and I think 17 what the Staff is proposing to the Commission is really a 18 minimal change on the inside box.
That is, if you are FSAR 19 analyses calculated a 23 rem exposure, whole body, that that j
20 is the limit and we will regulate you with a minimal 21 criteria around that 23 even though the SER says in most 22 cases that the 23 is okay because it is less than the 30 was 23 basically derived from the Part 100 criteria.
24 We didn't do this with the Commission but I do 25 want to talk about it a little bit today, you know, these I
)
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accident analyses that really form the foundation of the b(~N 2
plant's license, based on these postulated, stylized, i
i 3
design-basis accidents.
And I think if you ask most folks, l
4 and if you put a PRA perspective on many of those 5
design-basis accidents, most of them would be viewed as i
l 6
incredible today.
I l
l 7
We have learned a lot since we postulated those 8
accidents on what is likely and what is not very likely.
j
)
9 And so there is already a lot of degree of conservatism j
i 10 around where this inside box is drawn.
And so part of our 11 rationale for saying it is okay, as long as you don't exceed
{
l 12 the acceptance limit, is trying to take advantage of the
)
13 conservatism that is already in that line, and then how it 14 was established.
And to continually go to an incremental
[G) 15 approach with minimal, again, if it is trivial, why should 16 we spend a lot of time and use up everybody's resources 17 through 50.59 evaluations and, potentially, license 18 amendments to basically rule over things that are in the 19 noise level?
20 DR. SEALE:
Tony, let's try to ask a contemporary 21 version of this problem, rather than talking about the 22 continued validity of things like design-basis 23 prognostications and so on.
The use of extended life, or 24 extended burnup fuel, the rerating of certain plants, and 25 other such similar activities are generally agreed to eat f']
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'into tha' operating margin.
In particular, I think some of 2
i
./'s\\
.us have characterized those things as harvesting the margin.
i
\\-
3 You are suggesting that if I want to go to 4
. extended burnup fuel, then that may be strictly a 50.59 5
item, because it may well be -- I mean it may not avoid the 6-tech spec limit, but it could avoid a generic limit on fuel 7
burnup.
Is that an acceptance limit that you would, in 8
essence, accept and say that is something that would require 9
a specific consideration by the staff and so on?
t l-10 MR. PIETRANGELO:
That part of the -- you know, I
-11' can only answer that from a 50.59 perspective.
12 DR. SEALE:
Is that a 50.59 yes or no issue?
13 MR. PIETRANGELO:
I think it is a yes issue.
I 14 think you would have to evaluate the impact on the 3
1
^}
.15 assumptions in the analyses that form the basis for your I
s_/
l 16 operating limit.
L 17 DR. SEALE:
Yeah, but if 62 gigawatt days per 18 metric ton is an existing limit for the staff, from the i
l 19 Commission, and you found that you were going to want to 20 exceed 62, then, presumably, that would be an unreviewed 21 safety question.
22 MR. PIETRANGELO:
Yes.
j 23 DR. SEALE:
Would you agree with that?
-24 MR. PIETRANGELO:
Absolutely.
L 25, DR. SEALE:
Okay.
l l
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114 MR. PIETRANGELO:
Absolutely.
Yeah, and the next r~s 2
one on how this relates to margin of safety, we don't think s-3 there should' be any. changes, minimal or otherwise, 4
negligible, thatever you want'to call it, to this line.
All 5
right.
That is the hard line, the backstop.
All right.
6 So when we told the Commission we don't think 7
there ought.to be any reductions in the margin of safety,
.8 it's -- when we define margin of safety is the difference 9-between this line and this line, to the failure point.
.10
.Unfortunately, we don't have,the same interpretation with 11 the staff over what comprises the margin of safety.
- And, 12 quite frankly, it is disconcerting to us because this has 13
'been out there for 10-plus years now and it is troubling on 14 a number of'different levels.
(
15 DR. SEALE:
Okay.
So what you are saying then is 16 that I am modifying the design or operating envelope and not 17-the acceptance limit.
18 MR. PIETRANGELO:
That.is. correct.
19 DR. SEALE:
When'I do high burnup fuel.
20-MR. PIETRANGELO:
As long as you stay within this 21 box -- you can change this box.
-22 DR. SEALE:
Yeah.
But what I am saying, a 62 23 gigawatt days limit-is an operating envelope limit, not a 24 tech spec or acceptance limit envelope defining quantity.
25 MR. PIETRANGELO:
. Yeah, I don't know -- again, I g
i.
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115
~1 am not' familiar with that part.
,. f j-2-
DR.-SEALE:
Okay.
I.(/l 3~
-MR. PIETRANGELO:
So I. don't know whether.-- which 4-
-one itiwill be at this point.
5 IMt. - SEALE :
I guess the. point I:want to make-is 6'
that~the design and operating envelope then! includes some
-7 !
'genericulimitationsias well as things that are' specific.
81 MR. PIETRANGELO:
Okay.
Yeah, I --
1 9
10:R. ' SEALE :
And that is not clear when you first c
10; h
- ll' MR.PIETRANGELO:
- Okay, i
l 12.
MR. BELL':
It.may be that this acceptance limit is b
L13 '
the'same as your1 operating limit.
14-DR. SEALE:
It could be,-yeah.
?/~Nt 15 MR. BELL:
= V.
And in that case, you would'-- a change 16 in that or an increase would require prior NRC--- maybe 17
. folks generally are aware of the 62 gigawatt'- -
P 118 DR. SEALE:
Yeah.
Gigawatt' days per metric --
1 19 MR. BELL:
And are operating at that point.
I-20 don't know.
As Tony;is unfamiliar,1so am I, on the fuel 21
.burnup issues.
A change in increase in that would require 22 prior NRC approval.
23 MR.-PIETRANGELO:
So,'before I move on to margin sv 24
.ofisafety, just to finish the consequences, I think the 25-differencesLin'the-positions are we think that'the increase j
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in consequences ought to be able to go up to the acceptance
(^'T
?
- limit, i.e.,
this line, and the staff is looking at minimal
(_,/
4 3
around this line.
4 CHAIRMAN BARTON:
Minimal staying within that box?
5 MR. PIETRANGELO:
No, no.
Minimal increases.
6 CHAIRMAN BARTON:
Oh, just outside the box.
7 MR. PIETRANGELO:
Right.
Right.
And that is 8
defined by the value that is in your SAR, it is calculated P
in your SAR.
I 10 Let me talk about probability for a moment.
We
{
11 don't have a hard line for probability.
If you go back to 12 how these analyses were done, and you apply single failure 13 criteria, the system was either there 100 percent or not 14 there, and that was the extent of it.
And so it is
(~x difficult to, these mitigating systems, get into this what l
!v) 15 16 is a minimal increase and the probability of a malfunction 17 kind of thing.
18 So we are willing to live with minimal on that 19 simply because we don't have a line that is founded in the 20 regulatory framework right now.
Potentially, one thing we 21 have thought about is we do have, through maintenance rule 22 implementation, reliability and availability values that 23 could form a line.
These are the performance criteria that 24 are established for the risk-significant SSCs and the 25 maintenance rule.
And as long as the change didn't cause i
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1 the reliability and availability to decrease below the i
2-acceptance criteria, you know, that could be how you would
,r 3 -
4 3
define the significance of an increase and probability.of a 4-malfunction.
Now, that's just kind of food for thought for 5
another day,.but there are ways to establish these hard L
6 lines, and that may be one later on for probabilities.
7-Now, moving on to margin of safety, again, I kind 8
of find this troubling.
I am not aware of any written 9
disagreement with how margin of safety was defined in l
l 10 NSAC-125 by the NRC staff from 10 years ago.
All right.
1 11
.They knew how the industry was defining it since that 12 document was issued.
And to my knowledge, that was not the 13 rationale for not endorsing NSAC-125 at that time, there 14 were other rationales.
('
15 Secondly, if you can use -- if you are going to go A
16 minimal on probability and consequences, I don't understand 17 the position that -- but we can't do that on margin, we can 18 do minimal, I'll call that an operating margin.
The staff 19 is basically saying the margin of safety includes the 20 operating margin.
But even given that, they are not willing 21 to do minimal even on that line with margin of safety, and I 22 don't understand it myself.
23 Third, I think -- and at.least they were very l
24 frank with the Commission in the COMSECY.
It wasn't 25-responsive to the Commission's direction in that regard.
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So, again, we think there are hard limits on -- primarily 7-from:the design-basis limiting values where that margin --
2 3
what defines the operating margin and what would be the difference from the limiting value to the failure point
.4 5
would be the margin of safety.
'6 DR. SEALE:
Let me say I like your drawing, but I p
7 have problems with your language.
And the reason I say that is I believe thermal power is a tech spec limit, and 8
9-rerating is clearly asking for a change in thermal power.
10 MR. PIETRANGELO:
Okay.
.11 DR. SEALE:
And so I think your characterization i
12 as of the outer boundary of the operating margin box --
13 MR. PIETRANGELO:
Yeah.
14 DR. SEALE:
-- as involving a tech spec limit is 15 not correct.
In some cases, it may.
But in other cases, 1
i
\\
16 the tech specs, in fact, define the design and operating p
17.
envelope.
18 MR. PIETRANGELO:
I think they are more limiting 19 that some of these other values.
You know, t
i 20 DR. SEALE:
I didn't say in every case.
21 MR. PIETRANGELO:
Yeah.
22 DR. SEALE:
Yeah.
23 MR. PIETRANGELO:
And in that case, per our
~
24-drawing, there is not a hell of a lot of operating margin 25-there then.
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DR. SEALE:
Well, but the point is you are asking 2
for -- to change the thermal power.
)
3 MR.-PIETRANGELO:
No, I am saying -- I say there-j 1
4 isn't.any operating margin.
Where you are saying that this 5
line is really down here, then you have to cg) see the NRC 6
before you can make the change.
L-7 DR' SEALE:
Oh, but I think you said earlier you L
8-didn't want to change that line.
9 MR. PIETRANGELO:
Not without prior review and l
- 10 approval.
i 11 DR. SEALE:
Ah, I'm sorry.
Okay.
I'm sorry.
l 1
12 MR. PIETRANGELO:
Not without prior review and l
13 approval.
(
14 DR. SEALE:
I'm sorry.
'i
( )
15' CHAIRMAN BARTON:
You can go up to that line but 16 not --
17-MR. PIETRANGELO:
You can't go over it without 18-prior review and approval.
19 DR. SEALE:
- Okay, p
20 MR. PIETRANGELO:
That's what I -- I'm sorry.
- 21 DR. SEALE:
Well, I misunderstood you then.
l 22 EDR. MILLER:
But you can go up to it.
"23 MR. PIETRANGELO:
We think you can.
And that 24 provides the flexibility that was intended by 50.59 251 initially.
And I didn't go through the historical part, f
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but, you know, when the licensee put -- went in for an 2
operating license, they submitted this FSAR which included a 3
chapter that was the proposed technical specification.
4 DR. SEALE:
What I did hear you say was that you 5
didn't think you should change the margin of safety.
6 MR. PIETRANGELO:
That's right.
7 DR. SEALE:
Without prior approval.
8 MR. PIETRANGELO:
Without prior review and 9
- approval, i
10 DR. SEALE:
Okay.
Well, that phrase is important.
11 MR. PIETRANGELO:
Okay.
12 DR. MILLER:
But you can change the operating 13 margin without prior approval.
14 MR. PIETRANGELO:
We think you can.
We think you
()
15 can.
And chould be able to.
And, again, let me go back 16 through the historical rationale.
When the licensee went in 17 to get their operating license, they submitted the FSAR.
16 Part"of that was the chapter that had the proposed tech 19 specs, and those were, at least after 1962, I guess, lifted 20 out and said, okay, these are the ones you cannot change 21 without prior review and approval, i.e.,-the tech spec ones.
22 CEAIRMAN BARTON:
The tech specs.
23 MR. PIETRANGELO:
Right.
Now, all the rest of 24 that stuff that remained in the SAR, that used to be the 25 Hazard Summary Report and I think Eileen's slide, initial O
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1-
_ slide, really spelled that out quite well, for a while that I
2 was also part of your operating license, and you couldn't 3'
change-that stuff either.
That was really the rationale for 4
. developing--
5c CHAIRMAN BARTON:
The 50.59.
l
.6.
MR. PIETRANGELO:
Right.
But, now, I mean we do
)7'
'have this hierarchial structure and, you know, if you don't 8
-- if you treat all these as hard limits, you are really 9
making.all-those FSAR values like tech spec values.
l 10 DR. SEALE:
Yeah.
Sure.
11 MR.-PIETRANGELO:
That's the problem.
That's not 12 enough flexibility for day to day operations.
It is 13 resource-intensive for both the licensee and the agency, and j
i 14 I.think from a safety perspective it doesn't make any sense 15 to be using people's time up like that.
i 16 So, again, I think, you know, we are trying to be 17 consistent with both the probability and the consequences,
- 18 and the margin of safety discussion, and I think what the
- 19 staff has proposed is inconsistent and, again, doesn't 20-
-comport with historically how this-was all set up, because, I'
really, you are making these nominal values just like tech
~ 21 '
22 specs.
That is the heart of our argument..
l L23 DR. SEALE:
As I said, I like your boxes and I
'24
.think is a very nice way to --
.25 MR. PIETRANGELO:
Okay.
Let me move along here.
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I'll talk a little bit about scope.
And, again, in April we "2
.sent a letter to the Commission proposing to decouple the l
3 scope of 50.59 from -- as described in the Safety Analysis 4s -, Report.
Oddly'enough, outside of 50.59, you won't find 5,
!anything in the-regulations, statements or consideration, or Q
16.
~ otherwise, that says the scope of 50.59 is the updated final J7 Safety Analysis Report.
Okay.
j 8
,Again, way.back when, when these words were 9
. initially drafted, you know, that SAR was a very small --
410 well, initially it-was the Hazard Summary Report, i.e.,
the j
t
\\L'
!115
- Safety Analyse,s, and'it was a small set of information.
And 12 Jit'has grown.
Most. people -- SARs have grown substantially p
113-based on what era they were licensed in, primarily.
i c
14 Whereas, the number of issues addressed in the SARs are 115'-
. basically about the same.
What has really changed is the j;
16 level of detail and discussing and describing the facility.
'And, again,'those words in'50.59 and this is not -- I am not-l' 18
' blaming the NRC for this, this is how the industry, I think, L
19; has,gone on and implemented it, is to treat every word in k
' 2'0 ' ~
.the~SAR,.and screen'on that when they do 50.59s, as was the-21
' guidance'in NSAC-125, and go well beyond, in fact, just l
22-
'words in'NSAC-125.
L
.23=
We'still think you need to screen all the changes, 024:
but.are you screening against some description in.the SAR or i
25 is'itEmore appropriate -- again, and I don't think our p
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position is a new one, we really think we are going back to 2
the original incent in the. late '60s there, cf are you 3
changing an input assumption to the safety analyses that was 4
really the foundation for the operating license.
5 It would be a much improved 50.59 process if the 6
scope is defined directly in 50.59 versus deferring to 7
whatever the content'of the SAR is at your plant.
That 8
results in really uneven implementation across the industry D
to ucme extent.
10 CHAIRMAN BARTON:
When did you get it coupled to 11 the SAR?
I lost that if you said it.
12 MR. PIETRANGELO:
The words in 50.59 in (a) (1) say 13 change to the facility as described in the SAR.
14 CHAIRMAN BARTON:
And so it's always been there, 15 right?
16 MR. PIETRANGELO:
Since 1968.
17 CWtIRMAN BARTON:
Okay -- it's always been there.
18 MR. PIETRANGELO:
Yes, right.
Now for 12 years at 19 least there wasn't even an update rule to the SAR.
20 CHAIRMAN'BARTON:
Right.
21 MR. PIETRW3GELO:
And Russ spoke to this before, 22 and again when you go back to the previous diagram about are 23-you going to impact a limit, okay, that is equivalent to a 24 tech spec, well those come from the safety analyses, and 25-really we are talking again about the acceptance limits O
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124 l
1 established in the safety evaluation reports.
(
)
2 Now what would be the benefits of doing that?
.,.y 3-Well, we think there's too many right now, full 50.59 l
4 evaluations that are done that really are trivial.
5 You know, you used the 27 hour3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> number before for 6
what'an average safety evaluation takes.
That is just the 7
guy preparing it.
That does not include all the review l'
8 times and the oversight committees and all that.
9 I tell you, I was at the ANS meeting and I know l
10 Dr. Miller was in the audience there, and we had a. guy who I
talked -- from Commonwealth Edison -- who talked about how i
11 i
12 many they do.
On average, this is not a Comm Ed value, it's i
13.
an average value -- most licensees do between two and three 14 hundred' full safety evaluations a year, but they do l'h
(,,/
'15 thousands of. screening evaluations a year.
15 DR. MILLER:
You said 3000 a plant?
1 17 l
MR. PIETRANGELO:
Yes.
18 CHAIRMAN BARTON: 'That's the answer to four 19 questions only.
That's a preliminary evaluation.
m 20 MR. PIETRLC7LO:
Well, you have got to document 21' it, okay --
22 CHAIRMAN BARTON:
Yes.
It's the four questions.
23
.You file a form, a check-sheet.
24 MR. PIETRANGELO:
Yes, but when you are doing 25 thousands of them, and the reason I make this point is that l:
n
!i ;
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y 125
-p,
- D the total. hours it takes to do the full Lafety evaluations
'r s
.2 -
was dwarfed by the total hours to perform all the (s-)
3 screenings, so from.a. resource standpoint for a licencee the 4L screening takes.about 10' times more resources than doing the l
"S.
full safety evaluation.
6 Dk. APOSTOLAKIS:
Let me understand this -- you 7
sayithere are two or three thousand: screenings.
What do you 8'
mean by that?
9 CHAIRMAN.BARTON:
The preliminary evaluation -- it 10-answers four questions.
11 MR. PIETRANGELO:
And you say is the proposed JL2 change --
13 DR. APOSTOLAKIS:
I understand that, so in these
-14' cases they~ conclude it does not do anything.
15' MR. PIETRANGELO:
Right.
1 <6 DR. APOSTOLAKIS:
So they go ahead and do it.
17 MR. PIETRANGELO:
But they document it.
18 DR. APOSTOLAKIS:
They document it and that will 19 be affected --
.20 MR. PIETRANGELO:
Right now, no.
l 21' DR. APOSTOLAKIS:
Right now, okay, so'there are
'I
~22L two'or.three hundred cases where they have to do a safety I
L L23 evaluation --
l
.24.
MR. PIETRANGELO:
A safety evaluation.
)
l l
25' DR.-APOSTOLAKIS:
What does full safety L p)
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.2' MR. PIETRANGELO:
That means you have got to ash
' \\.g -
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- 3 :
yourself the questions on increases of probability and 4
consequences and malfunctions of a different' type and --
- f 5
DR. APOSTOLAKIS:
But you have already asked them
.)
6-in the screening --
{
17 CHAIRMAN.BARTON:
No,. no, no, no, no.
I 8
DR. APOSTOLAKIS:
No?. So you didn't pass the.
L
'9 screening?
Is that what you mean?
y
-10 MR. PIETRANGELO:
The screening.is different.
I
-11. -
That-.is the scope question, George, and right now it is --
L J
=
12'
- DR..APOSTOLAKIS:
Oh, you mean it is outside -- it 13 is outside the scope.
Okay, okay.
So then for the 200 14
' cases, you'ask these four questions -- three questions.
15.
CHAIRMAN BARTON:
- Four, t
16.
DR. APOSTOLAKIS:
No, the 3000 17-MR.-PIETRANGELO:
He knows the 3000..Now you are 18 talking about,the full safety --
19-DR. APOSTOLAKIS:
The 3000 outside the 50.59, is 20 that what you are saying?
I'
-21 MR. PIETRANGELO:
Yes.
You don't have to go i
22; through --
23-
'DR.'APOSTOLAKIS:
You don't have to go through the
~24.
questions..
Now you-have 200-or-300 of them.
You have to go 25 through the questions.
( ' [\\./;:[
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s f
-127 ro 1
'!!R. PIETRANGELO:
Right.
I 2'
DR. APOSTOLAKIS:
And for these, when you say a 3
full safetyLevaluation report, what do you mean, that-the 4
- answer is no'again?-
5 MR. PIETRANGELO:
It may be --
6 CHAIRMAN BARTON:
But you'have to really -- to
'l
'7 write'a full description, deterministic engineering l
2 I
8
. judgement'and all that, into an answer.
You can't just i
9
-answer'the'se yes or In3.
These are paragraphs.or pages --
10 MR..PIETRANGELO:.These are. pretty lengthy.
of verbinge answering.
- 11 CHAIRMAN BARTON:
.12 DR. APOSTOLAKIS:
27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br />.
13-CHAIRMAN'BARTON:
That's the 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> and then.you 14 have got to review it and then you have at least two-three t
15 l levels.of~ review.
16' MR. PIETRANGELO:
Right..That is plant' review, 17
'and then some of those, if one of the answers is yes, and it 18 is a USQ, then you have got to prepare an amendment for i
19 prior review and approval by the Staff.
20 DR. SEALE:
And it has to go to your legal i
12 1' department, almost certainly.
22 MR. -PIETRANGELO:
Yes --
12 3 DR. MILLER:
-- and about 10 percent of the 200-go j:
24 to -- no, less than.10 percent.
Less'than 10 percent.
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128 1
DR. MILLER:
Less than 10 percent.
2 MR. PIETRANGELO:
It 's a handful.
3-DR. MILLER:
Five percent at the most --
l 4
MR. PIETRANGELO:
Become our USQs that go for an I
5 amendment.
Most licensee if they get a yes answer go back 6
and look to modify the change so that they don't have to do 7
that.
8 DR. APOSTOLAKIS:
So if I wanted to use the IPEs 9
or IPEEEs, then I would do that and maybe in 5-10 percent of 10 the 200?
That is where they might help me?
11 k
OR. MILLER:
Maybe.
They might help you on the 12 200 some places.
13-DR. APOSTOLAKIS:
All 200 of them?
14 MR. PIETRANGELO:
I forgot -- let me go back to
()
15
.this other chart.
16 MS. McKENNA:
I think that the 200 have to be 17 evaluated.
Now whether the IPE would help you evaluate them 18 would really depend on what they were, I think.
19 DR. APOSTOLAKIS:
Yes, but in some of these cases 20-probably the answer is no and it's kind of obvious and you 21 don't have to worry about it.
I don't have to involve IPE 22 results so --
23 DR. SEALE:
The ones that are on the fence you 24 probably --
25 DR. APOSTOLAKIS:
Yes, but how many of those are O
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1 129
-1 there?. That is what I am trying to understand.
,.y 2,
DR. SEALE:
That is the 200.
HU]
3 DR. APOSTOLAKIS:
No, the 200 are not on the l
4 fence.
1 5
MR. BELL:
As I understood it, you would do the 6
full safety evaluation on the 200 --
i 7
MS. McKENNA:
Right.
8 MR. BELL:
Okay, now the five of those might 9;
five of those might trip one of your criteria --
10 DR. APOSTCLAKIS:
Right.
-- and seemingly require prior NRC 12 approval.
13 DR. APOSTOLAKIS:
Right.
14 MR. BELL:
I thought I understood it was those I
J 15 that -- well, why don't we look at it from risk-informed s.J 16 perspective and see if that can tell us what we need to know 17 about this change before cycling my licensing people, my 18 lawyerc and the NRC through an amendment process.
19 DR. APOSTOLAKIS:
Right.
That was my 20 understanding too, but these five or 10, whatever they are, 21 but less than 10, would take more than 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br />?
22 MR. BELL:
Oh, yes.
23 DR. APOSTOLAKIS:
So even if you didn't involve 24 IPE results.
f 25 MR. BELL:
Oh, yes, they take a lot of time, i.
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)
1
[,
.1 DR. APOSTOLAKIS:
Okay, so then it is worthwhile l
t
[.
2 to try to' expedite that process --
L 3
MR. BELL:
Yes.
1 4
MR. PIETRANGELO:
Well, we can do that today.
We 5
don't even have to change a rule to do this, and this goes 6
back to the EPRI PSA applications guide we had a 50.59 j7 7'
example in there.
l 8
You can't use PRA to answer the question, the
'9 criteria question, but if it is a USQ what we recommended in 10 our guide was if it is amenable to review under the PRA, you 11 should provide that'information to the Staff and to give 12 them the risk-informed perspective kind of grease the skids i.
13 to approve the change.
]
14 If they know it is'not very risk-significant, it
'()
~15_
would make the review process faster, j
16 I'think that is what they are recommending now.
I 17 DR. APOSTOLAKIS:
But at that time, you didn't 18
-have this business of minimal, minimal changes?
19 MR. PIETRANGELO:
That's right.
J l
l l
20 DR. APOSTOLAKIS:
So now the PRA may even help you i
21 there.
J 22 MR. PIETRANGELO:
It might.
j l
l 123 DR. APOSTOLAKIS:
That's my point.
-24 MR. PIETRANGELO:
We are very consistent on that
)
i l,
25 point.
You can't use PRA to answer these questions today.
i
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j 131 1
DR. APOSTOLAKIS:
I think you can.
" p/>
(
2 MR. PIETRANGELO:.Well, you can use it l
3-CHAIRMAN BARTON:
You are not allowed to use it.
l 4
.MR..
PIETRANGELO:
No, you are not allowed --
5.
DR. SEALE:
You are talking apples and oranges, l
6'
. George.
]
- l 7
DR. APOSTOLAKIS:
So "can" refers to the rule.
I i
'8=
'am. referring to the. state of the art.
-9 MR. BELL:
You can, but you may'not.
10 DR. APOSTOLAKIS:
Okay.
That is the correct 11 statement.
I L
12 MR. PIETRANGELO:
We. encourage the licensee to do 13' that.
.14-DR. APOSTOLAKIS:
This was very useful though,
/%.
\\ms/
15 because that --
i l
16 DR. SEALE:
-- clarifies it.
17 DR. APOSTOLAKIS:
Clarifies it in how many cases 18 something like this.would be useful and also.it sets a stage l
19 because, you know, I don't want to propose something that-i 20 will take 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> effort and make it 300 hour0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> effort but if I
l
-21
.it'is already there and you have problems arguing, then it l..
22
'is. worthwhile bringing in some additional information that 23 may. resolve th'e issue.
24 MR. PIETRANGELO:.The reason I put this chart l.
25 backup is to talk about risk-informed. perspective because I l'
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.think:this will help you.
/- y 2-Besides una example we just went through now on i;'.
L3 how you could use PRA, the other way --
~
4 CHAIRMAN BARTON:
Well, I think you are going to 13 almost going to have to use PRA with the example you gave,
'6-because if you don't all the RAIs on that amendment are all e
7 going to!be. risk-informed RAIs.
[
8 See, you are smart to use that going in.
i 9' MR. PIETRANGELO:
Now the other way to use this, 10 okay, we think, is.you can start using a risk-informed
~
.11 '
perspective.to help better define what this limiting line l'
12' is.
I 13' DR. APOSTOLAKIS:
That is not 50.59.
'14 MR. PIETRANGELO:
No, but it's really the
?15 reference for 50.59.
That~is where you are trying to redraw
~
- 16 where the line is why we developed 1.174?-
L 17, No,.no.
L
'18 DR. APOSTOLAKIS:
l'.174 helps you change that --
19 MR. PIETRANGELO:
'No, it'doesn't. DR. APOSTOLAK1S:
-- second line.
- 21 MR. PIETRANGELO:
No, it doesn't.
j22-DR. APOSTOLAKIS:
Tell us why.
'2 3 -
MR.:PIETRANGELO:
Okay.
Well, for permanent E
24-
- changes to the licensing basis'-
I agree.
2 5..
'DR. APOSTOLAKIS:c'Yes.
That's.what I meant.
l i
~%
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133 L
1 MR. PIETRANGELO:
I am?saying though when let's 2
~
say-you take risk-informed tech specs.
Somebody wants to 3.
change their allowed outage time and hopefully this in an 4
evolutionary way is going to happen over time, you start redefining what that box is and then it comes into play in 5
6.
50.59, l
7 DR. APOSTOLAKIS:
Right.
l.
8-MR. PIETRANGELO:
We are not at this point'yet 9
where you take a PRA' perspective and put.it on top of these 10-postulated design basis accidents and see whether th'ey are 11 really credible or not.
12 DR. APOSTOLAKIS:
Yes.
That is the new NEI 13 effort.
14 MR. PIETRANGELO:
Well, there is an effort ongoing l
15 with that',.but that would also help redefine where that line 16
'is.
17 DR. APOSTOLAKIS:.Yes, yes.
18 MR. PIETRANGELO:
So over time this box will 19 become risk-informed.
20 DR. APOSTOLAKIS:
-Yes.
21 MR. PIETRANGELO:
Now today it is to a certain 22 Ldegree but not as much as everyone would like, but over time
.23 that box should become more risk-informed.
This box won't.
24 The little one won't.
j i
'25 IMt. MILLER:
So if we define 50.59 somewhat based' I
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134 s
1
.on your diagram up there, then it would be kind of a living
(
2
-document in a sense that you redefine margin of safety and
[-
3
- edefine tech specs and 50.59 -- just follow it.
Is that 4
- what I am hearing'you say?
'5' MR.'PIETRANGELO:
I'm sorry, if we --
r 6-
'.DR. MILLER:
Using risk-informed methods, we would l'
7-redefine margin of safety and redefine tech specs in an T _8 '
evolutionary way and in 50.59 you just follow it.
P 9-MR. PIETRANGELO:
You don't have to change the l'
~ 10 rule for that.
di-DR. MILLER:.Right.
12 DR. APOSTOLAKIS:
Assuming that you still have the l13 ?
lsame regulatory philosophy.
l' L14 DR. MILLER:
Right.
1 15 sMR; BELL:
That is another: benefit of the
-16:
acceptance limits.
l DR. APOSTOLAKIS:
You only address the issue of
'18 risk-information here.
If you also become
[-
19
. performance-based, then things will change even_more l.
-20'
. drastically _because it's not just aLmatter of -- well, then L
21~
you will ask yourself_whether you should be spending all L-
.22
~this effort for things that are'inside the. envelope defined r
0 237 Lby the performance criteria.
24~
MR. PIETRANGELO:
Yes.
The other point I 25L in'eglected to make on this' chart, we were talking about 1
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135 1-cumulative, effects before.
p
,f-2 DR. APOSTOLAKIS:
- Yes, y
3 MR.:PIETRANGELO:
Well, what better way to control 4
cumulative effects than having a hard line that you cannot l
5 go past.
6 This addresses cumulative effects by using this
- 7~
kind of approach, and for probability we are not there yet,.
l 8
but even -- you know,.we'are keeping.our PRAs up to date, 1
.9' This is not beyond the stretch of the. imagination to say in l
10 subsequent years we.will be - 'when we update the PRA report 11-
~back what the baseline CDF and LERFs are, to show how the-12 changes are:affecting CDF and LERF.
13 I mean that is the other way to address it.
14 Let me go.back to scope again, and I apologize for
.15 jumping around here.
16-Potential benefits of improving the scope or i17 improving the focus of the scope, you would have fewer of these trivial evaluations that don't have any safety or 19'
' regulatory significance.
We think it would really help to 20 improve the consistency between the rule and implementation 21 and when you think about the -- and what we mean by this is 22'
.when you think about these questions in 50.59 on increasing
.23 ;
probability and consequences and that, the context, and I am 24.
glad you mentioned that this morning, George, the context 25:
you.are-talking about there is the safety analyses.
-f' Aj :
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Those questions don't make any sense once you I
-[
2 leave safety analysis space so a lot of the proposed changes 3
screen out, would screen out because they wouldn't affect an 4-input assumption into the safety analyses.
5-DR. FONTANA:
Are these all design basis safety 6-analyses?
7 MR. PIETRANGELO:
Yes, yes.
Then again you would
{
8 level the playing field, and part of our preliminary 9
contractor work has shown that even for a early vintage and 10 later vintage SAR, the information regarding the safety 11.
analyses is roughly equivalent -- in one plant, the older l
12 vintage one, had a six-volume SAR.
The later vintage one 13 had a 19-volume SAR, but the information on the safety 14 analyses was almost equivalent.
One had 200 pages, the i
15 later one had 300 pages, so there is a core of information l
16 in these volumes that is consistent across.
17 DR. APOSTOLAKIS:
That was after PCs were 18 invented, I guess.
19 MR. PIETRANGELO:
Finally, just a few conclusions.
l 20 I think we explained this before.
We think there j
l 21 is a need to expedite the rulemaking on this USQ criteria.
-22 If there is a lesson learned from the last couple 23 years, it is that unless you are going to eliminate the l
-24 legal community, you have got to have the words match the j
1 25-practice and cannot rely on finessing the words in the rule
/
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137 1
'shrough guidance.
That will not stand the test of time and
("i
'2
'is 'the subject 19" too many perturbations, depending on the
.3 number of things that could happen, so the practice has to i
4 meet'the rule and we can't use interpretations and guidance i5 to'get'around that.
6 That is why you have got to go to rulemaking on 7
this,'so we have got to~ expedite that to get long-term 8
stability-in this process and with that we think using 4
9
. acceptance limits for both consequences and margin of safety 10 would also serve to establish longer term stability in this 11 rule.
12 We do'think there is going to be a subsequent 131 rulemaking needed.to change the scope of 50.59 but we are 14 prepared to work with the Staff and the Commission early
[~
15 next year on that, consistent with the Commission's S,RM.
. V) 16.
That's it.
Again, that's a subset of basically 17 what we told the Commission.
~
18 CHAIRMAN BARTON:
Your use of acceptance limits 19 with the Commission was a hard sell, too, though, right?
20 MR. PIETRANGELO:
I don't know.
l 21:
CHAIRMAN BARTON:
You don't know?
l L
22
.DR. APOSTOLAKIS:
You didn't get any feedback how l
23 they thought?
24 MR. PIETRANGELO:
No.
I'll be honest with you.
I 25' think'--
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138 1
CHAIRMAN BARTON:
How about the body language if gr~}
2 you didn't get any words?
j
(/
i 3
[ Laughter.]
4 MR. PIETRANGELO:
Let me just say this.
We are 5
going to follow up the June 4th briefing with another letter 6
to the Commission to clarify certain points that were made.
7 CHAIRMAN BARTON:
Okay.
8 MR. PIETRANGELO:
And part of it has to do with 9
the acceptance limit and margin of safety issues.
We may 10 have not been as clear as we should have been at the --
11 CHAIRMAN BARTON:
I sensed some nervousness on the 12 Commissioners' -- on some Commissioners' parts when you were 13 into that dialogue on the acceptance limits.
14 DR. APOSTOLAKIS:
Could you elaborate a little
[)\\
15 bit?
\\_
16 MR. PIETRANGELO:
This is the how close you get to 17 the line.
18 CHAIRMAN BARTON:
Yes, that's it.
19 MR. PIETRANGELO:
And again that is why I added --
20 CHAIRMAN BARTON:
How close are you to his 21 acceptance limits line, and I sensed some nervousness there.
22 MR. PIETRANGELO:
And it's not that what the staff 23 is suggesting is not ridiculous, okay?
It has 24 plausibility -- I lost the chart.
25-It goes back to what you were approving in that
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l' 139 if there is an SER out there that says this line 1
SER.
- Now, rN 2
is okay because you have so much margin to this line that I i (
3 approve this line.
All right.
That is plausible, but we 4
doubt that that was the case, all right, at least with the 5
codes,.of which most -- how most of these limits were
'6 established.
The codes look at it from where you are going i
7 to fail and then provide margin back.
V
\\
8 CHAIRMAN BARTON:
But isn't part of the argument 1
9 here that the numbers that the Commission has come up with, 10 the staff has come up with have been more conservative than 11-L the industry's numbers and, therefore, there is some l
12 reluctance -- I hear that argument.
I read that in --
13-MR. PIETRANGELO:
We are going to address that in 14 the letter.
1
/~N 15 CHAIRMAN BARTON:
Okay.
i
> NY 16 MR. PIETRANGELO:
But, quite frankly, the staff 17 (a) wasn't required to that independent evaluation, but they 18 did it.
But the reason they did it was to establish 19-confidence in the' licensee's analysis, which is the analysis 20 of record, not the staff's analysis, which has not been 21 subjected to any review by anybody, besides internally.
So 22-the analysis of record is the licensee's analysis.
They did 23 their own independent verification to give them confidence 24 that the licensee's analysis was okay.
So that is the one 25 we are going by.
That is the licensing basis, not the
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l 140 i
1 independent one they did when you submitteo your l
"~
2 application.
I
' '~^
3 And, again, we think still that what we are
- 4
'failing to see in this discussion is how much margin there
'5' Lis than what we would call the real margin of safety out to 6
here. 1And, again, trying to use that tighter box is not 7
. consistent with historically how this was set up.
It l
8-doesn't afford enough flexibility and really is a poor use 9:
of resources on both the licensee and the agrncy's part.
Is 10
'it better than a zero standard interpretation?
Yeah.
11
' CHAIRMAN BARTON:
Yeah.
Sure.
12 MR. PIETRANGELO:
Yeah.
But it is still,'we 13
. think, consistent with what the original intent was, and you L14 are still really treating these as' tech spec values.
1 151.
DR. APOSTOLAKIS:
And all this, of course, would 16 go away if you worked with CDF and LERF.
.17 '
'(Laughter.]
18 DR. APOSTOLAKIS:
Think about it.
In-the 119 L containment analysis, all this stuff is there I
20 probabilistically.
There isn't a magic line that tells you 21-this is okay and this is not.
They say_the failure pressure 22_
' of the containment is the calculated probabilities of the-
'23
- loads and then it comes out.
This is the rational way of 24_
. doing it.
We need a new Voltaire.
'23 CHAIRMAN BARTON:
Any other questions for --
p -:
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141 l'
DR.' POWERS:
Voltaire was complaining about that 2.
point'of view, 'That was Dr.'Panglos' view.
l-3.
CHAIRMAN BARTON:
Anybody else have any comments?
4
.No,-there is nobody in the audience.
l 5
DR. APOSTOLAKIS:
Our' letter will not comment on 6
the scope, is that correct?
Will comment only on the
>7.
acceptance?.
I mean Tony mentioned two rulemakings.
One was 8
on the acceptance-criteria and the other was on the scope of 9
50.59, t'wo separate things.
Yeah.
And consistent with 11 Eileen said in her last slide, they owe the Commission 12 probably another paper next February on the scope.
l
[
13 DR. APOSTOLAKIS:
On the scope.
[
- 14 MR~ PIETRANGELO:
Yeah.
15 DR. APOSTOLAKIS:
So our letter is only on the J
l 16 acceptance criteria.
The ones that are in 50.59 --
l 17-CHAIRMAN.BARTON:
It's on the rulcmaking package.
18
-The~SRM and the staff's work developing this rulemaking l
[
19-package.
And that's -- that's what our. letter will address.
1
[
20 DR. APOSTOLAKIS:
Our letter will address the two 21 22' CHAIRMAN BARTON:
Yeah.
You are not gcing to talk 23 aboutiFSAR, any of that stuff.
That's a generic letter, 24 that's another issue.
.25 DR. APOSTOLAKIS:
Okay.
Another issue.
t t
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142 1-CHAIRMAN BARTON:
That is going down another path.
fg 2
We will get to see that one after public comment.
3 DR. APOSTOLAKIS:
Wonderful.
1 4
CHAIRMAN BARTON:
Because we already sent a 5
Larkins-gram up, I think, that said that.
So we won't talk 6
about that in this letter.
7 DR. APOSTOLAKIS:
Okay.
8 MR. PIETRANGELO:
Part of our follow-up to the 9
letter to the briefing is also going to inc.lude some revised 10 proposed language on the changes to the criteria, and that 11 uill probably go in late next week.
We will make sure you 1
12 al' get a copy of that, too.
I would encourage you to weigh 13 in on this.
I mean, basically, the Commission I think is 14 going to take all the information they get by July 10 and 1
(~T 15 then make a decision in terms of what goes out for public I
%-)
16 comment.
There's a chance --
l 17 DR. APOSTOLAKIS:
Our letter will be a couple of 18 days later.
19 MR. PIETRANG_ELO:
Well, yeah, they will be in the 20 mulling stage, I guess at that point.
But I would encourage 21 you to weigh in on this one.
It's very important.
22 DR. SEALE:
Your presentation has been very 23 helpful.
We appreciate getting your perspective on that.
24 CHAIRMAN BARTON:
Thank you.
25 MR. PIETRANGELO:
Thank you, gs ANN RILEY & ASSOCIATES, LTD.
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143 1-MR. BELL:
Thanks very much.
2 DR. APOSTOLAKIS:
So, Mr. Chairman,
- -)
(
\\>
3 CHAIRMAN BARTON:
We welcome any views or words of 4.
. wisdom you have got.
5 DR. APOSTOLAKIS:
We have expressed our views.
We 6
have no words on wisdom -- of wisdom.
7 CHAIRMAN BARTON:
No words of wisdom, just views.
8 All right.
If you have got something that you think is 9
important enough to go in the letter, give me a paragraph.
10 DR. APOSTOLAKIS:
I am going to send something to 11 Mike sometime.
12-CHAIRMAN BARTON:
Good.
Send it to Mike.
13 MR. MARKLEY:
Monday, right?
14 DR. APOSTOLAKIS:
Yeah, right.
/".
' Q].
15 CHAIRMAN BARTON:
Well, the meeting is -- oh, wait J
16
'a minute.
We have got --
17 DR. APOSTOLAKIS:
The meeting is on the 8th.
k
-18 CHAIRMAN BARTON:
-- two weeks.
Yeah, we have got 19 two weeks.
,20 DR. APOSTOLAKIS:
We have to write something for 21 22 CHAIRMAN BARTON:
Try and put together some kind l
23 of straw man so that we have got something to work off of 24 July 8th.
We are done.
25 DR. APOSTOLAKIS:
We are done.
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144 1
CHAIRMAN BARTON:
The meeting is over, adjourned, 2
whatever.
.y 3
[Whereupon, at 12:07 p.m.,
the meeting was 4
concluded.]
5 6
7 8
9' 10 11 12 13
-14
.O 15 U.
16
.17
'18
,19 20 21 22-
'23-l l
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before the United States Nuclear Regulatory Commission in l
the matter of:
NAME OF PROCEEDING:
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PLACE OF PROCEEDING:
Rockville, MD were neld as herein appears, and that this is the orig 1nal transcript thereof for the file of the United States Nuclear j
- (O Regulatory Commission taken by me and thereafter reduced.to y
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reporting company, and.that the transcript is a true and accurate record of the foregoing proceedings.
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1960 Vallecitos License Condition (all hazards summary was in TS) 1968 50.59 rule change (present USQ criteria) 1968 Rules on FSAR content, TS (design bases, margins, safety analyses of design basis events) 1974 Rule change to delete " authorization letters"-issue license amendments 1983 Rule change on no significant hazards Consideration of beyond design basis consideration noticing accidents and risk for licensing (ATWS rule 1984) 1986+ Tech Spec improvement Project (relocation of some TS to FSAR) 1988 Station blackout rule 1989 NSAC-125 Guidance for 50.59 evaluations
[ Note that severe accident considered in other contexts,such as IPE and IPEEE severe accident mitigation, etc., that did not modify the licensing basis]
1997 RG/SRP guidance for evaluation of licensee-requested changes to licensing basis that need NRC approval, using risk informed considerations 1998 Proposed rule changes to 50.59 (changes that licensee can make without NRC approval)
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