ML22230A083
| ML22230A083 | |
| Person / Time | |
|---|---|
| Issue date: | 02/10/1978 |
| From: | NRC/OCM |
| To: | |
| References | |
| Tran-M780210 | |
| Download: ML22230A083 (69) | |
Text
REJURN TO SECRETARIAT RECORD J
NU CI.EAR REGULA ro RY COMMISSION BEFORE THE COMMISSION IN THE MATTER OF:
PRESENTATION BY BECHTEL REPRESENTATIVES ON NUCLEAR POWER PLANT STANDARDIZATION Place -
Washington, D. C.
Date -
Friday, 10 February 1978 ACE - FEDERAL REPORTERS, 11'-l'C.
Official Reporten 4..4.4 North Capitol Street Washington, D.C. 20001 NATlONWICE COVERAGE* DAILY Pages 1 -
66 Telephone:
(202 ) 3A7-3700
(
DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on February 10, 1978 in the Commission's offices at 1717 H Street, N. W., Washington, D. C.
The meeting \\'Jas open to public a,ttendance and observation. This transcript has not been reviev,ed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or infommal record of decision of the matters discussed.
Expressions of opini-on in this transcript do not necessarily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or argument contained herein, except as the Commission may authorize.
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9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION PRESENTATION BY BECHTEL REPRESENTATIVES ON NUCLEAR POWER PLANT STANDARDIZATION Room 1130 1717 H Street, N. W.
Washington, D. C.
Friday, 10 February 1978 10 11 12 13 The presentation was conve~ed, pursuant to notice, at 14 9:45 a.m.
before the Commission.
15 BEFORE:
16 DR. JOSEPH M. HENDRIE, Chairman 17 RICHARDT. KENNEDY, Commissioner 18 VICTOR GILINSKY, Commissioner.
19 PRESENT:
1 20 On behalf of Bechtel:
Messrs. C. D. Statton, D. W. Hallig B. L. Lex, S. A. Bernsen, and R.H. Stone.
21 On behalf of NRR:
Messrs. E. Case, R. DeYoung and 22 R. Mattson.
23 24 Ace-Federal Reporters, Inc.
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P R O C E E D I N G S CHAIRMAN HENDRIE:
We.11; we 're glad to see you.
2 I wasn't sure whether we would turn out a quorum today, but 3
we have, so it's a Commission meeting and we scheduled it 4
in case we could gather a quorum~
5 I guess you want to tell us where you are going 6
on standardizationl, Bechtel style.
Please do~
Okay.
we~re prepared to proceed.
8 I'll kick it off for Bechtel.
9 We represent Be ch tel Power Corporation, _and my JO name is Charles Statton, and my associates,are Mr. Halligan, 11 Mr. Lex; Mr. Bernsen, and Mr~ Stone*~
12 The Bechtel Power Corporation's strategic plan 13 provides for a periodic reappraisal or reassessment of ~he
- J 4 di re ct ion we've elected to take in serving the e le ctri c 15 utility industry.
- J6 Now*, we also attempt to assess the directions that
- J7 the industry is taking; the impact of.the agencies that look 18 after those ma.tters; as we 11.as those things that occur from 19 the manufacturers.
20 We attempt to assess those from the standpoint of 21 how they might change our long-or short-term plan 1*
22 Based upon those appraisals and assessments', we 23 24 25 then pre pa re a de.f ini ti ve plan.
i~e present that to our chairman and the board of directors.
We have!, on two occasions -- and as you will hear
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further today -
discussed the Bechtel Power Corpo.ration"s position respecting standardization of nuclear generating facilities.
The first occasion was in 1973.
We have looked objectively at those conclusions that we have made, and what we have done with that conclusion over these past five years*, and we'd like to share some of those.re.sults with you today.
We would like to.solicit as many of your comments, as we proceed, as we believe that your comments are pertinent in d.eveloping any modification that might cccur to our plan Within Bechtel Power.
So, for that purp.ose, we would like to keep this as generally informal a.s possible 1, so feel free to interrupt.
-Our presentor is Mr. Lex.
Bert;~
MR. LEX:
ovr RUrpo.se.today\\ gentlemen, is to discuss the NRC Nuclear Power Plant Standardization Program, and exchange views on the nature of a Reference-Design Application which the Bechtel Power Corporation might sutmit.
As you may know~ we have long been a strong supporter of efforts to promote standardization in the nuclear power plant industry, and have carried on.an extensive standardization program on our own part, but we have notk elected to submit a Standard Reference Design Application.
It appears to us that your recent efforts to expand and strengthen the standardization program may now
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offer new opportunities for our particip,ation*, and it is that possibility which we wish to discuss.
First, however, bec.ause some of you may be unawar.e of the structure and range of operation of the Bechtel Group of Companiesr, we thought it we 11 to spend
.a few minutes giving a brief thumbnail sketch of our organizational structure~ as we 11 as of our intern.al Bechtel standardization program.
When we have accomplished that, we wi 11 then present our views on standardization and examine how they might mat ch your requirements.
Please feel free to Jnterrupt my presentation at any time that you have questions which,you would like clarified: Could we have Slide 1; please?
C S1 ide ~ )
The Bechtel Group of Companies is canposed of three prin cipa.l operating entities -
the Bechtel Power Corporation; the Bechtel Corpora ti on; and Be ch tel, Incorporated-- all reporting to the chairman and senior executive management under the di rec ti en of Mr. Stephen D. Bechtel*, Jr:
We undertake engineering, construction~ and construction management projects, both domestically and internationally, through eight operating divisions which report to different operating companies and which serve specific industrial areas of activity' ---- such as thermal
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5 power~ refining and chemical, and mining and metals areas.
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Our general corporate services -- such as legal, finance and accounting, personnel and procurement are 4
carried out by Bechtel Corporation for a 11 three operating 5
companies~
6 (Slide. )
7 The Bec.htel Power Corporation serves the electric 8
utility industry thr_ough three operatirg di-visions -- Los 9
Angeles~ San Francisco, and Gaithersburg --- reporting to JO President Harry o., Reinsch and a senior management staff.
J 1 The Los Angeles Di-vision sponsors an Area Office i-n Houston*,
12 and the San Francisco Division1sponsor..s an Area 0-ffice in 13 Ann Arbor~
14 CSl id e. )
15 Each of our divisions employs the same basic 16 organizationa*1 structure composed of departments for business, 17 de Velopmen t~ construction, engineering', project operations',
18 quality assurance, and services -
all reporting to a.
19 division manager, although obviously with minor variations 20 to suit local needs.
21 C Slide.)
22 The work undertaken on individual contracts is 23 24 performed through a project team organization where all personnel necessary to the direct execution of that project 25 are assembled in one physical loca.tion organized under the
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6 direction of a project manager, and work only on that project.
3 The typical team structure provides for 4
engineering, construction, quality assurance', and cost and 5
schedule services.
The engineering portion of the team is 6
broken down -into the. classic engineering discipline groups 7
of civil, mechanical, electrical, control systems~ nuclear-,
8 and architectural.
9 (Slide.)
10 This slide is intended to displey for you the 111 responsibility and reporting relationships between corporate 12 13 14 management~ division management, and project management.
Corporate management is composed of Mr. Reinsch, Mr. Statton~ and four functional managers -- mysel.f, in il5 Engineering; and managers of Construction, Operations and 16 Services, and Quality Assurance~
.I have.reporting to me
- 17 four chief engineers who coordinate the technical,activites 18 in the principal engineering discipline areas.
19 The division division managers rep::>rt directly 20 to Mr. Reinsch and Mr. Statton~
The basic departments of 21 22 23 their organizational structure receive line direction from their division manager, and functional guidance from the functional managers at the corporate level~
24 The engineering department has chief engineers 25 in the disciplines to oversee the technical work of the
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7 technical work of the engineering department.
These chief engineers receive functional guidance from the corporate 3
chief engineers~
4 At the project level, the project manager and key 5
team members recei~e line direction-from their respective 6
department management~
The project manager provides 7
project direction to the key team members, and the divisional 8
ch.ief engineers provide functional guidance to the discipline 9
engineering groups*.
JO (Slide;)
11 Bechtel's nuclear power experience startec:f as early 12 13 114 15 as the construction of the Experimental Breeder 'Reactor at Arco, Idaho; and participation in the Nuclear Power Study Group in Chicago.
This slide tabulates the 1i ght-wa ter reactor nuclear power stations in the U.S. and abroad for 16 which Bechtel has performed eng1neering and/or construction 17 services since 1959.
The 24 BWR units total 20~112 megawatts, 118 and the 50 PWR units total 48,236 megawatts.
Neither 19 sodium-cooled nor helium-cooled units are included in these 20 totals~
21 (Slide.1) 22 This slide shows the locations cf our current 23 major domestic nuclear projects, consisting of 36 units at 24 20 plant locations around the U.S.
The overlay adds the 25 locations of 26 units previously completed and in operation.
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8 The addition to 12 overseas units at -7 plant locations brings you to the tota-1 of 74 nu.clear units in which 3
Bechtel has been involved in engineering and c01struction.
4 This wide geographic location of site locations 5
have required that our designers respond to virtually every 6
level and combination of seismic criteria, environmental 7
and climatic conditions -
such as tornado design, wind 8
and temperature extremes, tsunami, et cetera -- and soils 9
conditions which it is possible to encounter.
JO
( SI id e. )
l I Our activity is the performance of engineering 12 and construction services tailored to the ne~ds of our 113 client.
The scope of services we contract to undertake 14 therefore covers virtua_l1y every variation or combination 15 of direct execution or management of engineering, procurement, 16 and construction activities, as summarized on this slide.
117 Typical projects illustrating some of these 18 examples are:
engineering, procurement, and construction 19 job:
Arkansas I and 2 Units; the engineering, procurement',
20 construction, management variation: Trojan and Rancho Seco 21 were handled und.er those contracts; engineering only, a goOd 22 example of that is the Oconee Nuclear Island design; 23 construction only:
the Ginna Project; engineering and 24 procurement is bes..t illustrated by the SNUPPS Project, 25 which is a powerblock design and a major equipment
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9 procurement assignment; engineering management is the typical mode of operation of our overseas projects in 3
Spain and elsewhere; technical,,service agreements covers 4
areas of continuing operatin.g plant support such as 5
the Pilgrim I contract.
6 (Slide.a 7
Within the general categorization of scope of 8
services offered, we encounter many variations needed to 9
respond to the requirements of individual eLec.tr.ic utilities.
10 Some typical examples are summarized on this slide*.
11 On some occasions we wi 11 undertake engineering 12 13
- at the very earliest conceptual stages of a pr-oject where a Client involves us.in site selecti.on, NSSS specificatico 14 and bid evaluation 1, but quite frequently we wiJl encounter 15 clients who have already selected their site and perhaps
=16 awarded their NSSS and T-G\\ and we come in with certain 17 preestabli.shed ground rules to work to'.
-18 On the.licensing and PSAR side, we have been 19 called -upon to coo rd ina te the preparation and publishing 20 complete task on PSAR; we've been called upon to support 21 22 23 our client who was handling the coordinatiQ'l and publishing.
We have occasionally worked with use of outside clients in addition to the basic -- pardon me, outside 24 consultants, in addition to the basic trimverate of client',
25 NSSS supplier, and architect-engineer.
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,} 4 15 16 17 118 19 20 21 22 23 24 25 JO Procurement is handled in almost any fashion you can imagine~
Bechtel sometimes functions as a direct purchasing agent, sometimes as agent for the owner'~ sometimes as a supplier of specifications and bid analysis for owner procurement; and occasionally specifications.supplier tor contractor or subcontractor purchase.
Thank you for bearing with me for this thumbnail sketch of the organization and of the backlog of nuclear experience which is.represented in our group.
Now let me turn your attention to the Generic Nuclear Plant Standardization Program which Bechtel has been carrying out since the early 1970s.
In comm on with many other archi tect-eng in eers and NSSS suppliers, Bechtel had already taken some internal steps at standardization of designs when the AEC standardization policy was announced in 1972.
After careful cO'lsideration of the policy-~ we concluded that it was too,restrictive in application to meet the needs of the electric utility industry and the responsiveness to site-unique utility-unique requirements which our clients expected of us.
- We completed de ve lopmen t of the Generic Modular Power Plant concept upon which we were working at that time, and prepared a presentation on cur Generic Standardization Program.
This presentation', and our views
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10 il l 12 13 14 15 16 i17 18 19 20 21 22 23 24 25 I J on what was needed for a viable standardization.program r
were discussed with the AEC by Messrs. Allen', Collins, and Schmitz, on January 31st., 1973; and by Messrs. Reinsch, Collins~ and Schmitz, on February 1st, 1974~
'C Slide.*)
That program.is summarized en this slide.
It is composed of six key elements:
criteria. definitionf, criteria application, licensing, basic systems design 1, physical layout', and procurement*.
The element of "criteria definitionu is handled through two activities.
First is the participation in national codes and standards writing groups~
During 1977, some 162 Bechtel people have engaged in 3011 separate and distinct code-or standard-writing committee assignments under the.auspices of the prim~ry technical.societies who direct and.coordinate these activi ties 1*
The second aspect of 11cri teria de.fin! tion" is the embedment of established design criteria and reg.ulatory requirements in our engineering standards program, which encompasses preparation and dissemination of standard specifications; standard drawings for typical engineering details; design guides govering method.s of criteria specification, _selection; and application; preparation of instructions;.and the design control procedures.
The second key eleme~t of our standardization
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,12 13 14 15 116 17 18 19 20 21 22 23 24 25 12 program is criteria application, which is implemented through technical topical reports prepared to facilitate licensing.
These reports cover detailed design or analysis methods.for subjects such as post+tensioned containment design~ missile impact analysis~ and so on~
Bechtel has 13 current topical reports, 11 of which have been.approved by the Commission, and 2 of which are under review at present~
The third key element. is the Bechtel standard safety ana lysis report.
This is an internal "PSAR without number.s 11 which provides basic text for use by our engineer.s in preparing safety analysis reports in conformance with the NRC standard format.
The fourth key element is a set of key design documents which we have prepared ~o outline basic sysxems designs.
These are standard systems desc;ripticns, describing the design and functional performance criteria for nuclear safety related and auxiliary systems, systems flow diagrams, preliminary piping and instrument diagrams1, basic system control logic diagrams, and electrical single-line diagrams.
The fifth key.element of the standardization program is the generic modular plant arrangement.
There are some eight or nine basic building blocks of wh~ch a complete power plant is com,=osed.
Each of these blocks has a number
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,19 20 21 22 23 24 25 L3 of restrictions requiring internal consistency of design*,
but a relatively small number of interface requirements for association with other blocks*.
This permits standardization of the basic building blocks themselves, while retaining some flexibility in their arrangement en a par..ticlilar site~
The last key element of our standardization
. program is in the area of procurement', which.is addressed by the extensive s.tandard specification program described earlier, and by standardization of procedures for supplier qualification and surveillance inspection activities.
You might ask:
What have been the bene.fits of your program'.?
Or how many plants have used.this generic approach and generic modular arrangement at Bechtel?
(Slide~)
Of 8 BWR units undertaken since 19.72, 4 units have made partial use of the generic, and 2 units have followed it directly.
Of 23 PWR unitsl, 3 have made partial use of the generic;, and 12 have followed Lt direct.ly.
In power generation capability terms, some 25 1,000 out of 35,000 megawatts of capacity have _been based on partial or full application of the generLc designs since J972.
The Generic Design has. continued.to evolve during this time, as feedback was received from projects employing BESSAR to help prepare their license application, as experience has accumulated in the execution of detaiied plant
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,19 20 21 22 23 24 25 14 designs based on the Generic Modular Arrangement,' and as new regulatory guides have been issued and regulatory positions established.
This. feedback has been incorporated into BESSAR through periodic uj:dates~ and in our Generic Modular Nuclear Power Plant Manuals.for both the BWR and the PWR.
These manuals contain plant and equipment layout drawings,
- standard system de sign criteria and functi cnal des er ip tions, preliminary piping and instrument diagrams', and control log.i c diagrams.
In combination with our standard specifications'*
these documents have permitted an.extremely rapid start of design and licensing for several foreign.and domestic jobs, including the Florida Power and Light South Dade Nuclear Project, with a high level -
on our part -- of confidence of the technical adequacy and safety of the design~ It is indeed unfortunate that Florida Power and Light had to*defer South Dade.
Now, with that _background on the Bechtel internal effort at nuclear power pl ant standardization, let us finally turn our attention to the form in which we believe that a standard reference design application could be carried out.
C 51 id e. i)
We would prefer to see a st~ndard reference design-process which we would call 11 Generic Reference Design~"
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10 11 112 13 14 15 16 17 18 19 20 21 22 23 24 25 15 which provides for a modular plant layout coupled with standardized design criteria and standardized system design~ but with sufficient flexibility to accommodate i each. of the major* NSSS packages; each of the major turbine-generator set*s available; and a family of site specific design parameters -- inc1uding seismic design levels; tornado design levels; other safety related natural or man-made hazards phenomena; soi ls/foundation conditions; and topography!, cooling water source,.access requirements, and visual impact:
C Slide~;)
To be viable*, a Generic Reference Design approach requires:
an extensive data bas..e of experJence; top technical resources available and dedicated, acceptance by potential utility clients; and demonstraticn of its li censabil ity.
We believe that the firsx three points are adequately covered 1, and it is the fourth point which we are discussing with you today.
The several slides present the key characteristics of a Generic Reference Design which we believe can be defined or specified with.sufficient exactness to allow an independent examination and finding that a plant meeting them can be designed, constructed, an¢ operated safely.
They concentrate on the establishment of the safety design
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- 19 20 21 22 23 24 25 16 criteria, and the methods of design and analyses which will be employed. to mee.t these er i teria, as we 11 as on the acceptance limits or bounding conditions which must be met by the design.
They do not require completion of the final detailed design, but allow.suffi.cient *flexibility in detailed design to accommo:fate equipment from any qualLfied s*upplier,
.and to meet site-specific and utility-specific needs.
These key characteristics include:
(Slide.)
Firm* design,criteria for safety-related systems~
components*, and structures inc.luding i dent 1 ti cation of applicable codes and standards and conformance to NRC requirements and guidance.
Criteria would address those characteristics of the items that are important to safety to the same level of detail as a typical safety analysis report.
The various key design documents such as system descriptions, piping and instr.ument diagrams, electrical sing le-line drawings, and control logic diagrams which are currently required for SARs would be provided in preliminary form but with sufficient detai 1 to identify features of the systems to satisfy the design bases.
- The report would commit to specific analytical methods and associated acceptance criteria for analyzing
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Design and analysis methods would be described and appropriate acceptance. criteri.a provided for engineered safety features and other systems as currently required for SARs.
CSl ide. )
All material covered in Bechtel Topical Reports would be included or incorporated by reference. Criteria and design rules governing physica 1 separation',.. fire protection*, a.ccess controls, and radiation zoning would be provided consistent with current re.. gulatqry requirements.
Standardized-design details', such as.typical Penetrations, seismic supports, pipe whip restraints, and other installations would be included.
The report would contain the required general listings and description of safety--related components, however in most instances.specific numerical,data on size, ca pa city, horsepower~ and so on, wou.ld be replaced by de.finitive criteria f.or. setting these values.
Interface requirements for each NSSS turbine generator system w.ould be included.
<Slide.)
The report would contain sufficient layout information to define firm arrangement and relati v.e location
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JO 11 12 13 14 15 16 17 18 119 20 21 22 I 23 24 25 JS of safety-related.features~
To the extent possible, Specific dimensions would not be included, however, except in instances such as the turbine generator unit where its or.ientation and separation, from safety-related structures might. be defined by 1imi ting dimensions~
A family of site-related design bases-would be presented; and specific change in plant criteria and in features..to accommodate each, set of site parameters would_be defined.
The report would also contain sufficient utility interface criteria to show how si ta-dependent features, such as cooling water and ultimate heat sink and mu! ti-unit arrangements, would be accommodated*.
C Slide. 1)
Many of the key characteristics of a Generic Reference Design, as we h*ave just described them, are.clearly in conformance to the Standard Format for SARs and the Standard Review Plans.
Several may not bei, or we may be misinterpreting those requirements, based on our experience with custom SARs.
This slide compares our concept of a ttGRD, 11 or a Generic Reference Design, to our understanding of a PDA/SDA, and highlights the things we believe dif.fer.
To pi ck two examples:
Take the seismic bas is where the present PDA/SDA scheme requires a single seismic design envelope -
placing this in the position of having
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We would prefer to include~ in a Generic Re.ference Design App li ca ti on~ several discreet seismic intensity level bases to bracket a wider range of sites, without penalizing a low-intensity leY-el with a design for a high-intensity case.
Another example is the -~*containmenti,-11 where the present standard_ revie~ plans and format end up driving us into a fully dimensioned presentatioo on the containment.
We believe that our topica 1 report describing the.analysis and the design methods for the containment!, the handling o.f critical details, and* telling yo.u virtually everything about a post-tension containment except the diameter and the height of a particular containment*, provides an entirely adequate design base fo.r a safety finding on containment.
We believe the plant design can be licensed on a gen er ic-:reference bas is* without limiting the particular dimension that it must be speci.fied tor a given NSSS and utility site condition.
We find customers with various problems1, in terms of the physical limitations of the site*~ that may.lead to a minimum needed containment diameter vs. units like Calvert Cliffs and the. Pilgrim 2-Project up at Plymouth Rock, where local scenic conditions and historic interest leads to a
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JO l l 12 13 20 desire to have the lowest profile plant possible --- hence the maximum reasonable containment diameter.
We need room for that variation.
I don't intend to go through every one of those items on the slide.
We would ask if there are any questions or comments, or discussions you would like to have around it at this moment.
.C No response. )
MR. LEX:
Dr. Bernsen, is there anything you'd particularly care to single out on there?
DR. BERNSEN=
Well, for example there might be some concern in the looseness of defining 11containment,*1 if necessary, for ex.ample, some minimum containment volume 14 might be identified, and things of that sort.
But we"d like 15 the flexibility in diameter', and height, and things like that.
16 And again, in the case of arrangement, as we have 17 said.before, the relationship of components;, without 18 necessarily specific dimensions, or typical dimensions.
19 Because, particularly in preliminary cases*, it appears that 20 the important features are the criteria*, and not the 21 preliminary di mens ions.
22 Vie have comrnitments to satisfy a certain 23 safety objectives, and if the dimensions have to change to 24 meet those, we do that anyway, normally, in a given situation.
25 But I think we could get into that discussicn
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CHAIRMAN HENDRI Es I guess I~ll want to come -
back to this.
I don't know whether I'll want to comment now.
It would be appropriate; CHAIRMAN HENDRI Es Maybe I would do better to hear some more; and then -- okay?
MR. LEXs Well, it is.apparent fr,om this slide that the basic difference is in the lack of specific numerical data, rather than in criteria bases, design methods, features~ analytical approaches-, or acceptance limits.
The benefits of standardization have been described in many ways and from many perspectives.
Underlaying the perspectives of the regulator, the uti 11 ty owner, the equipment supplier~ and the archi tact/engineer~ however, are two fundamental objectives:
to expedite the licensing process, thereby shortening licensing sche,dules and improving the utilization of the NRC staff; and to stabilize designs and design and analysis __ methods, thereby allowing Projects to proceed in a more orderly. fashion with less exposure to late redesign~ and allowing the NRC staff to conduct more thorough reviews and develop greater confidence that important issues have been identified and resolved.
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,)9 20 21 22 23 24 25 22 (Slide.,)
We believe that a Generic R.eference Design has se*veral definite advantages in meetin9 the objectives of standardization~
A GRD would stabilize design features by es-.tablishing the design and performance criteria significant to safety, and the.acceptance criteria or limiting condi ti ens, which must be met by a safe design.
A GRD would a.llow flexibility, for response to site-unique and utility-unique design featureS-- without sacrLfice in underlying safety criteria.
A GRD wou.id minimize the potential cost penalty of unneeded overdesign forced.by 11 enveJoping 11 criteria.
A GRO-; by focusing on design and _safety criteria rather than on fin al detail, would permit more timely updating to meet changes in the state of.the art with minimum _impact on overa 11-design and project schedules.
A GRD will provide stabilization of the design process in a manner which will permit an optimum and competitive respcnse by the industry~
Finallyi, a GRD will have broader.acceptibility in the utility industry than a "single-case" reference design.
Gentlemen, that completes the formailly prepared presentation. _ We have copies of it for you', which copies
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CHAIRMAN HENDRIE:
Okay. and I hope there are a couple of copies so that the staff can have copies~
Well, let me te 11 you how it strikes me', and 1 11 ask other Commissioners to comment.
Perhaps we can hear from the staff.
I've recognized Bechtel-'s. reluctance to come down the path that others have come with this on standardization, going back a long time --- there were some meetings Jn '73 and
'7 4, s orne in Gaithersburg, and in our offices in which we covered many of these same subjects.
And the reasons that seemed to you, in the light of your experience and. the way you do your work, were good reasons not to come in and focus down on single designs, and this is certainly consistent with that thrust.
From my standpoint, I must say that as I look at standardization propositions -- do it this way; do it that way; try some variation here; the various options -
I keep looking at it from the standpoint:
If we accept a particular option or avenue, okay, and go down that line, after the staff has argued with you over whatever there is to argue in that option and that~s settled and agreed upon, and then
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24 we come to put a specific unit into the precess, I ask myself:
What does the staff have to do in order to go 3
forward and get a construction -- make a case to justify, 4
as appropriate in the particular case, the necessary 5
findings for the construction permit?
6 To the extent that that work that was done 7
previously on the so-called "Standardizaticn Module, 11 or 8
design, or whatever, is complete and speci fie enough so that 9
this work that staff has to do for a specific unit~ for a
- 10 specific CP is either zero -
which is an unrealizable 11 ideal -
but at leas-t minimum, then I have a higher regard 12 for the standardization option.
13 Conversely, to the extent that the option has --
14 that that particular standardizaticn approach has, as yours
- 15 does,..a considerable variability into it -- so that when I 16 come and have the specific app.lication for the specific unit--
17 then I think there(s still a substantial amount of staff 18 work to be done.
19 And that, it seems to me fr om my standpoint, makes 20 it a less desirable option from our standpcint.
21 Now\\ I"m willing and I recognize that I have to 22 23 24 temper this view, also, and take into account what is practicable from the standpoint of the people who have to prepare these designs in advance of specific orders, or 25
-Jtmodules,n or whatever, and carry the burden forward of
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normally engineering firms aren't like heavy capital intensive firms; their stock and trade is in their heads and in their design notebooks*, and you *typically don't put it to work until you've got an order; you don't have a lot of expensive machinery that you have to buy be fore you can be *1n the business.
And in a way, the standardization things are going in that direction~
It's your form of buying a lot cf heavy machinery, which doesn"t pay off for you unti 1 you get an order for a product.
So, there are some practicality limits there, in terms of what you can stand to do~
And those limits :vary
..from firm to firm.
They're different between the vendors the NSSS vendors and architect/engineer firms, clearly.
There are also the anti trus.t considerations, which mean that we cannot be in a position of locking into specific suppliers on components that may reascnably be supplied by a number of people in the field.
We can't lock in on one and, you know, get him.a preferred position because he happened to be the guy whose design got used by an engineer in presenting the thing.
That clearly is a place we have to go back to performance specs and so on and work fairly closely with the antitrust people to make sure that
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,12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 itJs-- But in spite of those elements of practicality and the antitrust considerations, I must say my own *view about the possible ways to standardize is that=
The closer we can get to the place where the thing that we.talk about in the beginning -- apart from any specific application just comes and is as speci fie as it ca,n possibly be, and allows us to settle the differences of opinion that there may be, and get agreed on what's going to be acceptable bet.ore we get to the specific application, that's where I think the p.3yoff in the desirable pa th is, from our side.
Now, as I look at your generic modular approach, it does ap,Pear to me to lack that degree of specificity which would allow us to go into the construction permit._review on a specific item using it, with really a great deal of the safety review already in hand, and written down in the generic st a.ff safety e valuation re port that goes~ with the design.
It seems to me that what you have here in the direction you go is one in which we can get a piece of that done ahead.
Your generic standardization -
the module scheme -- amounts; in effect, to a series cf presumably coherent and internally consistent topical reports, to the same extent that other topical reportsi, dealing with how you do a certain piece of analysis, or what your approach is on some design -
safety related design prcblem~
To the extent that these can be thrashed out
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- 15 16 17 18 1)9 20 21 22 23 24 25 27 ahead of time with the staff~ then when they arise in a particular case*~ why we already know what your point Of
--view is*~ we already know what the* staff's point of view is', and that's a help in getting on forward with it~
But it does seem..to me that your approach would
.leave tor a specific CP application for a specific unit*--
would still leave the staff with a review effort which, while perhaps somewhat less than that that might be involved with a complete custom-design,* sti 11 is pre tty extensive.
And I wouldn't be surprised to see that the di fference.s in the manpower investment and the time investment on the staff's side, between that and sort cf a run-of-the-mill custom design, is not a:11 that great.
After a 11 ;* not only would the staff have to look at the way in which you have linked the modules and to go
. over the interfaces, but considerably beyond that, in numbers of areas, instead of presenting specific dssigns~ specific analyses, you say:
Here's how we're *goi~ to do the analysis.
Or, here are the rules we are gcing to follow to do the design.
Now',* we may have agreed back yonder that those were reasonable ways to do the analysis, reasonable rules for the design.
Now you've got a specific design.
We're going to have to look at it.
The staff has to come forward in that CP review and say "we know what the specific design
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They'r.e going to have to look at that specific design you present, now, and decide whether in fact they agree that you've *applied the criteria rules in a way that they agree with.
And by the time they get through doing that, I"ve got a notion there may not be a great deal of manpower di f.ference on the staff's part between doing that and having taken a specific custan design presented and just said
good. 11 start at day one, and we' 11 work through it and see whether we agree with it or not.
Now, obviously there would be some areas where that's not so and where there is considerable advantage, but I"m afraid there'd be a number of other areas where it wouldn"t.
COMMISSIONER GILINSKY=
Could I ask something be.fore --
CHAIRMAN HENDRIE:
Yes.
That s crt of runs me down.
COMMISSIONER GILINSKY:
Yes:, I'm anxious to hear your response on this.
But to what extent is your thinking tied to coping with the licensing process?
And to what extent is it really driven by other considerations.
You could mention
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CHAIRMAN HENDRIE:
Yes; it's a useful point.
Be cause, from my standpoint~ you know, if pretty well driven by the licensing process, and thatJ,s sort of the end Of it.
COMMISSIONER GI LINSKY=
We 11*, be cause one of the things that impressed me ------ go'ing up an::f looking at the SNUPPS Project*, was that the.re are just a lot of other important aspects about standardization*, having to do with the way you built the plant", and so on:, which.are quite apart from the licensing project~
MR~ 'STATIC)N:
Yes, much more than we can deliver in a written-document to you.
Well; generally~ of course we wanted to address the two objectives that we outlined there -- that we wanted to ease the licensing time~ if we could; and 1 think you've become*, of course, a little bit attached tc whether or noti, does a number make the license process easier for your staff or doesn't it? Does the height and the containment, or the diameter~ does it. make it easier?
I don't know.
We have suggested that perhaps it really doesn't make it that much easier --
now-*-
COMMISSIONER KENNEDY=
Could we ---
MR~- STATION:
I don't want to interrupt now --
COMMI SSlONER KENNEDY:
'I don't want to interrupt
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Go right ahead.
/
COMMISSIONER KENNEDY:
I want t c come back to that, because that relates to some assumptions, I think, from your side as to how this process does or ought to work.
MR. STATION:
Yes~ and I think this is the sort of exchange we really want from you~
Because we're not here to try and "convince" you, or turn you around, or anything.
I think we are really trying to get your rebound from the presentation we have made.
So that that issue shou.ld be addressed.
Does the number, does the height, does the diameter conveniently provide you with more reason to give that a -CP or not?
I don't know.
C01.fM1 SSIONER KENNEDY:
Will you', later -- not now, because I don't want to interrupt what you're trying to get at in response to Mr. Gilinsky's point explain later why you think it need not?
but will you MR. STATION:
Yes.
If I may call on some of my partners here to help do that?
COMM! SSIONER KENNEDY:
Sure.
COMMISSIONER STATTON:
The other point is, looking at all the experience that Bechtel has had --- and particularly the experience we had in getting the SNUPPS Group. together.
There was originally some 26 utilities invclved that we
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,}6 17 18 19 20 21 22 23 24 25 31 suggested ban together to do what 5 of them ended up doing.
The reasons we lost the other 21 were varied.
Some of the very same reasons we're talking about generic designs.
One happened to be right in this area.
His reasons were z Look, he didn't fee 1 that he wanted to be penalized for the site envelope conditionsr, if we felt we had to.envelope. so we could cover at least the 4 sites that we had~
So, you 1 ose some one on the basis of economics of a design.
In looking at.the broad experience that we've had as Bechtel*, from seismic character from the Wes~Coast to the Easi Coast, to the South, we have made quite an analysis of the changes that really need tc be re.spected from any one design to another, insofar as seismic is concerned.
And we have a pretty good idea of those things
- th at rea 11 y need to be addressed.
And in some cases, the seismic character of a plant can treated very ea.sily, going from cne location. to another, simply by addressing.the specific areas that we have a pretty good feel for where those characteristics need to be changed within the. desi9n.
So, from the point of view of having a specific design with di mens ions, our experience t e 1 J s us th at the market for that, or the useability of that with the utility industry, is going to be substantiaJly limited.
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- )9 20 21 22 23 24 25 32 Because the utilities have an economic thing that they must considers Is that the most ec-onomical design tor the plant that they have?
We have probably -
in the Gaithersburg office, alone no fewer than 5 or 6 audits a year by the Public Utilities Commissions, coming to take a look:
Are we in fact spending the utilities money as well we we should?
So you can't avoid certain of the economics.
And yet, on the other hand, we have to address the fact that we are trying to provide something that has a safety character well enough to get licensed.
So it is for those particular reasons that we have some hesitation of picking 11a 11 NSSS supplier, "a" unit
- size, 11a" containment dimension, and coming in and. getting that licensed, and expecting it to have the broad market value or util.i ty interest that we have seen we've been able to get under the generic approach.
COMM! SSIONER GI LINSKY:
Isn!t the penalty for snveloping a number of sites really pretty small?
In other words, from maximum to minimum?
MR. STATION:
I'm going to let.you address that one.
COMM! SSIONER GI LINSKY=
Because I remembered it was a very small percentage.
MR. STATTcJN:
Within the SNUPPS character, you are
34].~0I *~32 jwb 33
.absolutely right.
In-the locations of those plants, the 2 _ enveloping that we ended up with was of a very 1 it tl e
.3 impact, say from New York to Kansas.
So, it didn't have 4
that much.
5 6
MR~ LEX:
But what's the seismic --
COMMISSIONER KENNEDY:
You indLcated earlier that 7
it might have been quite different, as to an.umber of other 8
sites which are not ih that package~
9 IO
/
MR. STATION:
That's right; tha t"s right.
COMMISSIONER KENNEDY:
I guess that's the question l.I that Mr*. Gilinsky' s talking to.
12 13 MR. STATION:
Now the exact value of that, we didnJ't take time to look at.
I mean, we didnJ't go down and
,14 investigate the detail, because at the time there wasn't 15 that much detail to look at~
But it did bcther a number of 16 the utilities that the enveloping was going to be at some 17 particular penalty to their utility.
MR. LEX:
Well, our experience, in looking at the 19 cost differentials in particularly civil structural design 20 cons iderat ionsr, and secondarily to some extent the increased 21 quantities of piping, and electrical, and heating* and 22 ventilating, and aJl these other good things that come along 23 24 as -your plant grows larger*, in trans la ting from some low seismic intensity $ites to examining.35 and ~45 and.55 25 G-type things, we're looking at more than just a few percent.
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)9 20 21 22 23 24 25 34 We can get.up into ranges of 10 to 20 percent pretty rapidly. -- It's a very awkward thing to put a very specific number on*, because you're always looking at apples and oranges*- or else, a hypothetical treatment.
But our data do not all0w us to concur in the* l or 2 percent, or 5 percent range, whatsoever.
The cost of these on San Onofre showed significantly more money inv.olved.
We 11, but ---
CHAIRMAN HENDRIE:
Yes, but those are* almost pathological cases in the seismic sense.
I think, as you rai.se the seismic design bases, for_ instance, from a very nominal one dOwn around 10 percent of gravity at O period, it does seem to me that the enveloping penalties -- there is one, but it's-not a rapidly rising function.
And then somewhere around a *third_. the acceleration cf gravity, you begin-to get into a place ~here you're reaJly having to scratch hard on the design in order to meet the higher forces involved; and from there on out, why I doubt that it*'s really very practical to present envelope designs.
But1, let's see, Dick, what?
Somewhere around a quarter G, or.3,.33?
MR. DeYOUNG:
.3 is the normal type, tor standard plants.
CHAIRMAN HENDRIE=
The standard ones on which that
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MR. LEX:
1 would agree with that statement.
CHAIRMAN HENDRIE:
And furthermore, I think at that level, why you've covered a pretty fair chunk of the U.S., about 75 percent of the likely site locations.
Now there is a fraction.left that falls into the
.. higher seismic realms, and there -
there, I think maybe you ve got to go custom.
MR. LEX:
Dr. Bernsen, 1 think, had something.to add..
DR. BERNSEN:
Yes, I think there are a couple of things. First of all, one point didn't come out -- and I beiieve you may be thinking about it -- what you talked about three, four, five years ago.
1n this particular.case, we think we re talking ---
I shouldn't say we *"think" ---
we re talking about a committed layout of the module; a reiationship with the module.
It's not the building-block approach where you move things around, but a fixed relatic:nship of complements for an NSS.
SC?~- you firm up the relationship of the safety-related structures.
And it depends upon how far you carry the design to d.eterrnine how much the cost impact is.
At this stage, I think we-re saying that relative layout of each structure would not change from seismic level to seismic level, but if
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- 14 15 16 17 18 19 20 21 22 23 24 25 36 you get into things such as reinforcing details, and specific wall thicknesses, and additional flaws in diaphrams, then you get to add to the structural cost.
But, in a lower seismic level you-could take some of these out, if they're not there for shielding or other purposes.
Now, if you get into fi na 1 de sign and you want to*locate the piping _supports, and snubbers:, and if you want cable-tray supper.ts, and so on, now your costs are significantly different as you change the seismic level.
So i't depends upon how far you want to carry the design in licensing; I'd like to answer the other question you asked before~
Fro.rn my s.tandpoint, I think that What we're talking about would do more to expedite licensing than anything else, and it is really for that purpose.
Because it's hard to figure out why we need so many nurnber....s -
specific design numbers *- in the licensing process~
As I said before; the important thing to demonstrate in the final design is that you have met specific requirements and commitments and limits.
If we said we were going to use a 6-inch pipe for some auxiliary feedwa ter system, but we also say we have -
and that we supply a certain fl ow --- but we also say that we want a certain rate that will satisfy the requirements to take care of decay heat with so much spilling, the governing criteria is the
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,15 16 l7 18 19 20 21 22 23 24 25 37 one that says you take care of a certain heat release with a certain amount of spi_lling, and not how big the pipe was or what flow capacity you specified.
So we;ve kind of -
we've got _a belt and suspenders approach.
And the numbers -
the flow ra te:s, the capacities', the sizes -- don't govern; it's the criteria that govern.
And just as in the ccnstruction area where the I & E inspectors are verifying that the design is carried out in construction', why not have the staff verify that the final-design number5 implement the commitments and criteria and methods.
MR. LEX:
Along that same.line, I would like to CHAIRMAN HENDRIE:
Jt,'s possible,_ Well-, you had some other q.uestions?
COMMISSIONER GILINSKY:
No.
COMMISSIONER KENNEDY=
You were about to say?
MR. LEX:
I was about to come back to your earlier question, Commissioner Kennedyi, on the containment diameter and height question.
The basic characterization of the containment pipe, the basic purpose of the containment 1, after all, is to contain energy release from a ruptured system.
The,basic characterization of that is the energy quantity.
It begins to impact or relate to containment dimensions only when you start specifying a pressure and drive yourself into a volume
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We would have little difficulty in selecting, on a generic design basis, a pressure volume relationship necessary to suit a given NSSS and establishing the contai-nment pressure design level that we would attend to.
We".re simply trying to retain some level of flexibility in the dimensions to adjust the containment to suit the individual unique site requirements that we handle.
And having been personally involved in shoehorning plants --
CHAI'RMAN HENDRIE:
We 11, th ere are more NSSS-related o from that standpoint, sites MR. LEX:
The NSSS establishes the energy-release
-values', certainly.
And after that, it becanes a geometry question.
COMMISSIONER GILINSKY:
I wonder if you could comment en how long you see the process taking right now, from inception to operation of reactors., and what you think is.achievable by fully employing the plans you are laying out?
MR. STATION:
Chuck just completed a very extensive study on this.
To give the variations on it, you can pick it up from there.
MR. HALLI GAN:
But the more I worked on it, I think, the le.ss sure I became of what I thcught I knew.
C Laughter.)
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-20 21 22 23 24 25 39 CHAIRMAN HENDRIE=
Yes~' I've had the same experience.
There may be other fields;, but this one is notable, that ones confidence level and ones canprehension goes through an early maximum (Laughter.)
CHAIRMAN HENDRIEs and I haven't found that -
after you -
once you peak out, why I haven-'t found that it turns up again.
C La ughte:r.)
MR. HALLI GAN:
We 11, we can look at 1 t taking several approaches~
If you boil it down to the very simplest parts of the problem, we believe that if you would take a* look at from the time you award NSSS until it's delive,red at the s,ite -- which.is a good, key point to look for -- to.date, they're talking about 44 to 54 months.for that in today"s environment.
Although*, in talking to the people who make the NSSS systems and their reactor vessel su PP lier s, and ~s team-generator suppliers, they fee 1 that if there were a fairly high level of stability in the market and in,the requirements, to where they could make commitments and get the long-lead-time materials such as forging on stream, they could cut that down to something.on the order of 30 months, say.
So, you look at the -- and also you look at the other end of it:
1he time the reactor vessel goes in place
341.0J.39 jwb 2
40 at the site*, and then the bulk work to accompl.ish installing wire, and cable, and piping, and looking at 3
the et.feet ive utilization of manpower -
you start, say 4
taking the 44 months -
you end up with about 8 years, say 1, 5
from the time you sward the NSSS until you finish it up 6
as a commercial operation.
7 CHAIRMAN HENDRIE:
So there's a bout 4 years.
8 Once you get the vessel on the site, you'r~ about 4 years 9
oft completion.
10 MR. HALUGAN' That is a good ccntribut,ive time.
ill That looks very easily attaina.ble.
12 COMMISSIONER GI LINSKY:
Under present-day
- 13 conditions 2 14 MR. HALLIGAN=
Under present-day conditions.
15 COMMISSIONER GI LINSKY:
And how much time is 16 there before the award o.f the NSSS?
,17 MR. HALLIGAN=
In your site-licensing problems, 18 anywhere from 2-to 5 years, maybe.
Take 3 years as a good 19 20 21 22 23 24 25 average, maybe.
And that's a tremendous licensing window; a tremendous window for the stabilization of given criteria, fr om the beg inning to end.
From the awarding of NSSS, it seems practical as a goal to search for in the industry to match what they're doing overseas right now.
And that is*, about 6 years from award of NSSS to fuel loading.
And they de that by virtue
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- 15 16 17 118 19 20 21 22 23 24 25 41 of', say, decision making, ~nd not being hampered by the potential interferences, by licensing, everyth.ing moves ahead very boldly, with a sense of confidence that what they are planning today is actually going to occur.
COMM! SSIONER GI LINSKY:
When you say "overseas,"
is that pretty much the case everywhere?
Are you talking about Japan? Or Germany?
MR~ HALU GAN:
It-'s starting to flow down, over.seas, also.
Bechtel has not has as much experience overseas COMMISSIONER GILlNSKY=
Well', this is your own experience overseas that you-'re referring to?
MR. HALLI GAN:
Yes~-
COMMI SS I ONER GIL.INSKY:
And that would be where?
MR~ HALLIGAN=
France*~ Spain --
Taiwan.
MR. HALLIGAN=
Taiwan; So as far as doing the design, gathering the material together, getting it at the site and putting it together, 6 years is entirely possible. It's a very realistic time.
But in today'.s environment in the United States 1, we believe that about the 8 years is something we ought to be. seriously looking at, and not the 10 to 13, 10 or II.that we seemed to be seeing in the last few years.
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- 42.
COMMISSIONER GILINSKYz Oh, you're actually seeing something like 10, from the award of the NSSS?
MR. HALLI GAN:
Toa t 's correct.
COMM! SSI0NER GILINSKY=
I see.
MR. HALLIGAN:
And of course that's made up of a number of elements, some of it being the lack of stability in the needs by the utilities, their perturbations ***on their side, the financing problems, and also it's th* impact of the licensing process itself and the licensing requirements.
COMM! SSIONER GI LINSKYz And how do you see the licensing process impacting on thLs?
MR. HALLIGAN:
Probably, in the establishing of the confusion over the lack of confidence of what I plan today, and I can plan a total scheme, and then I put together a method of carrying it out and getting it done, there is enough perturbation a.ssociated both.. in the processes and the public hearings and the changing of the safety requirements, however large or small.they might be, it's just enough to keep the industry off its feet from an e.ffective and a very efficient standpoint.
COMMISSIONER GI LI NSKYz Now is this up to the CP?
Or do you see it also going on after the CP.
MR. HALLIGAN:
There has been considerably after the CP.
COMMISSIONER GILINSKY:
I mean, is that a
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- 43 significant part of this extra time that you're pointing to, The post-CP?
MR~ HALLIGAN: *In the efforts at looking at this recently -- and believe me; this is not intended as a negative comment towards the review staff in any sense; i t"s just the fact that we believe the impact of the total 11 cens ing acti vi tyi, if that could be reduced to zero so licensing were not-an impact on this whole process, that
.about 3 years could be reduced from it.
COMMISSIONER GILINSKY:
But this is MR. HALLIGAN' But part of that is en our own side, as far as responding to existing 11cens~ng criteria, in the for~s of adequate or understandable codes, and standards, et cetera.
including this --
COMMISSIONER GI LINSKY=
Let"s see.
Are you the CP review when you say 11,:: ye ar s " ?
MR. HALLIGAN=
Yes, I am.
MR~ STATION:
Oh, yes.
COMMISSIONER GILINSKY:
Well, I mean that --
MR. HALLIGAN:. And I would.like to go back, and COMMISSIONER KENNEDY:
Yes,, but how about separating that-- which was the question, earlier.
COMMISSIONER GI LINSKY=
- Yes I, in other words COMM! SSIONER KENNEDY:
Take the CP out of it, and
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- 25 44 then what?
After the CP has been issued.
COMMI*SSIONER GILINSKY:
To what_ extent are you faced with new requirements, and so on1, that one hears a great deal about, after the CP is granted?
Or~ can you pl an*, reas,onably ~ beyond that point?
MR. HALUGANi It-Js been the implementation of say the broad requirements~ and understanding of systems separat101*~ seismic support for cable tray and c*ondui t, the
., details of implementation which were not fully understood o:r: defined in everyones minds five years ago.
And so a great deal of --- and this gets back to --
.leads into something that we believe the approach that we're suggesting might help to solve~
One of the biggest problems that exists in the completing of plan ts, to date, are those -- the wire and cable,* the conduit 1, cabletray hangers, piping -
a 11 largely associated with the solution of.the pipe-break problem, separation, seismic design.
The method of design of a 11 these things depends on a lot of field-fit.
But yet we're taking the total system of duct supports, cable tray supports and designing a very carerul criteria and degree.
The hangers.
They have to be installed in sequence.
And as we got smarter and smarter~ and become more -- say the regulatory requirements became much, much tighter Q'\\ how we do thi*s -- the tremendous interferences in
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productivity installing all the bulk reduced significantly, because a great deal of backfit w_as required. -
to put all of this field-bulk material in place.
So, it/s *unlikely that you could ever complete a standard design of a plant -- a specific*, implemented, standard design to the degree that you could solve all of that. The physical problems of getting all of these little pieces associated -- and that's another reason why we can't r_ea 11 y honestly give you a good *answer as to what does it cost to go from ~2-G to ~ 33-~
Because the real cost is in trying to fit 17,000 pipe hangers-, along with 27',000 cabletray hangers~ in an area. that needs to be laid out in extreme detail to avoid the congestion, just to get them in; and still permit some field changes.
DR. BER8'1SEN:
I can't give you anything specific on the effect of schedules\\ but as a practical matter -
to give you sane example -- most of the projects we 're worrying about today have CPs~-
And yet the amount of time and effort spent by licensing-oriented people in supporting pr9jects~ trying to figure out how to solve new designs, meet new requirements~ how new requirements apply to plants With CPs and. not* OLs, is greater than ever before.
We have a larger number of people worrying more about these specific prob.lems -
COMMISSIONER GILINSKY:
What does this do?
Does
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or do you -.-
DR. BERENSON' It creates uncertainty, and backfi tting, ancL redoing~
COMM! SSIONEFI GI UNSKYz --- end up redoi rq things that you ve done already?
DR. BEFIENSONa Yes, all of these things --
depending upon how smart you are, and how far ahead you can anticipate what the requirement might be when you bring the final safety analysis report in, it could be anything from rubbing out a drawing, to ripping out an awful lot of concrete and steel.
COMMISSIONER GILINSKY:
Now*, doesn't this argue for having a final design, to the ex.:tent possible,.,before we ever get involved in this process?
I think maybe that's what Joe was saying _at the beginning.
MR. HALLIGAN:
Well, let me ask a question.
This is really what we're trying to sort out, exactly the same thing.
Will, in fact, a standard reference design which cannot specify all the major components*- like the exact manufacturer for the feedwater pump, an:i for the condensate pumps, and _the safety pumps, and all these things -- does ttre*-perturbation caused by finally acquiring the actual purnps,'S'nd systems, and components going in there, does the perturbation.:'t-o that, as far as the "look-see" or the
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47 re*view of the safety aspects "'O~.:the plant*~ are those greater than what we a re proposing in the -G~ff?
COMM! SSIONER KENNEDY:
What;'s -yrur answer?
MR~* HALLIGAN:
We don't think sc~ *-Be-cause it 5
seems to us the most imper tant thing is to make sure vt"e 6
all agre*e on what the criteria is tor that pump~*
So that 7
no matte.r whose pump we buy;, it wi 11 f.i t the safety-related 8
- er iter ia'; but yet permit the comnie rcial forces to come into 9
pl.ay to adjust..to different pipe sizes*~ different pipe 10 orienta-t.ions*~
- Because when you get to the seismic', again, tJ I the most important thing is to make sure tha*t piping system 12 113 14 il5 16 J7 18 19 20 21 22 23 24 25 wi 11 withstand the *-best.in a s*eismic environment*, not just meet the criteria:
so; we would 11 ke to see a design evolution come about where we would not. have to have all cf those very cumbersome"; awkward~* almos.t impossible pipe supports in there.
And today;* if we sit down to design a standard plant which would be* approved, it would in fact have to include some of those things*, to.really respond to what You are looking for, to avoid all this continu*ous re*view,
- specific review of some of the design, dimensicnal *details.
Because 11 dimensions, 11 that's on this whole -- I keep referring back to the seismic*, because I thJ.nk we all perhaps have discussed Lt enough; we have a pretty good feel for why it is such a pain in the neck.'
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10 11 12 13 14 15 16 17 18 119 20 21 22 23 24 25 48 So, wouJd. the review, under the standard plant design, reference design*., once you get a given feedwater pump, is that greater than what we are proposing----which is that you don't size* the line that comes out of that pump, but we could agree on what the criteria is for that pump -- for the pump, and also for sizing the line and supporting the line.
Because~ again, we would like the flexibility.
to.improve on that design, on incremental -- on a controlled basis, in bOxes that fit within a hole 1, rather than having to change the whole bit.
Another example:
On the philosophy as we 1 ook at it -- and *we're re.ally sure it differs a 11 that much from yours, either -
take the containment vessel again'. which is something physical we can all recognize.
There are several major suppliers of the tendon systems for pres.tressed post-tension systems.
There's been a great deal of thought and evolution that has gone into what is the appropriate length, and different manufacturers, for commercial reasons, have dif.ferent lengths', different sizes, different end connec*tions.
There is a tendency right now that if in fact --
and we have been somewhat of a party to it -- in order to become more standardized on this, and to avoid as much discussion and pro longed review with NRC,.. to narrow dOwn
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49 So, the criteria for the tendons, ~he m~thods for analysis, and the way in which the criteria for the end connections would -- if that could be established, then there are* several manufacturers that could come in and respond to tha t.
But there will be a tendency,.we believe, as we tend to -
if Bechtel were to draw a ccntainment s..tructure giving dimensions which would tend to fix the tendon length, which would tend to fix the tendon diameter and the number.s of it -- that all of a sudden we would.tend to push some of the potential suppliers out of the way.
Because it's too risky a business for that size a company to enter into it anyway.
So that's one of the things we;ore trying to get.
MR~ STONE:
I think it would be worthwhile if you would allow me', just for a few momentsi, to use I think the best example there is in the industry tOday--- the advantage of the generic application*-- and that's SNUPPS; that sprung from a generic design.
I. know two of the.Commissioners have been out to visit to see what the project is about~
That sprung from a generic design by Bechtel which was far less advanced at that stage than we are today in our generic designs.
It a,llowed the project to complete its filing,
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So that was 24 months.
Now*, there was some delay in the construction permit time, but-the advantage there was that~ springing from a generic design,' and bringing together the custom requirements of 5 utilities~ was able to bBnefit the filing of a Significant document and achieving the first consiruction permit~ in view of that task of bringing together the people, within 24 months.
Then, the completion of the fir..st unit," the first fuel load~ was supposed to be toward the end of '81 *.
We have seen the effects o.f economics*, of slowed growth*,- have stretched that out*~
But that *was looking at a period from the time the PSAR was docketed*~ which was June,74*, to the fuel loading of the first unit, was 7-1/2 years*.
Now, if all of those things had come off on time and had not been affected by +/-inancing, and low growth~ that would have been a significant improvement to the industry~
And I think the example of the utilities being able to work together in small groups such as that with a generic design', allows them the economic advantage that Mr. Statton has talked about as one of their needs~
CHAIRMAN HENDRIE:
Well, it's certainly a reasonable way to do business, and is O"le of the
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And from our standpoint, it is a
(
very satisfactory one; But the essence of it*;* I th ink from the sta ff--'s standpoint~ is.less that you are able to form the specific application for X units* from your generic base that you have in hand; that, you know*, is not*;.I think~ a notable point for the staff~*
What's of interest to the staff is:
By George, here's a specific application that says nhere's the design of the plant-~ and we're going to' build six of *these*; and there are going to b.e a few minor differences for
.site-related matters as 'noted in each of the site--specific a_pplications; but here"s the specific design in terms of the basic safety-related plant design~
- Ana here are the analyses that go with it: This applies to all these units. 11 And the staff looks at that and chews through thatl, and that then stands.for all the individual units~
And I hope we are doing the same thing in the OL stage~ to the maximum-possible degree.
Now~ it was an advantage to you to have the BESSAR backup in-house, in terms of your putting this application -
the joint application --- together.for your clients.
I guess there would be some incremental bene.fi t to you and to the staff if the staff had 1 wked. at BES SAR
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52 and there were sections of that on which the staff had said this is a reasonable approach, and so on.
But I really wonder if that wou]d have made ve~y substantial differences in the work the staff would have felt it had to do when the specific dssign came in.
And what I have a feeling is that, because of their need to be able to speak in some detail to things on the specific design, maybe not so muche Not nearly so much advantage, I think*~ as a case where there has been a reference design -- a standard design which is pretty specific -- which does settle down to the maximum possible degree on how big is this, you know, what have we~ got herei, the whole thing, has been worked over.
And that's, you know, that's sort of a fundamental comment I make to you about this concept.
DR. BERNSEN:
I'm curious.
How much specific numerical information does the staff need, and what do they do with it? What do they do with a 116-inch line size" or a penetration that's 2 inches*, which is 3 inches*, and things like this? What's governing in their review at the PSAR stage, first of all?
CHAIRMAN HENDRIE:
Well, I think we ought to -
I haven't given the sta_ff a chance to comment, and let me do that in a minute, and then they can.address this point, among others.
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JO ii 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 53 But I must say that what you propose, the sort of thrust that you take with this generic modular sort of approach, it may be that it's workable in part at the construction-permit stage, but I think the staff will still have to do more work on a specific application using it than they would if they had a more specific*, approved, standard design in hand; What bothers me more is I don "t see any reasonable way for your scheme to progress to the point we would like to get to, I think-~
And that is; not to have people coming in referencing preliminary design approval standard designs at construction permit time*,* but rather for us to get into a shape where we can do a single major safety re*view and let that stand~-
Wha.t th is re qui res is a design which is final, in a safety sense. It needn't be a final --- now we"re going to get all the ready proof for construction drawings and so on, but in the terms of final safety analysis; And, you know, we have a batch of preliminary design approvals out now*, and are working hard on/sort of the next phase of the standardization policy, to see where we go from here.
But the thrust; *very clearly, is to encourage those people sup porting those designs to go forward to final -
to a thing which we' 11 call a "final design
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What that leaves 1, then, the thing you brought up.
Now we have to confirm that what'.s actually built ind,eed conforms to that design.
1he staff wi 11 have to look at th~t.
It will be, in part, an inspection function, and in part a licensing review.function.
But I wculd see it as nowhere near approaching the present process, where there is a whole new presentation, you know, a refurbish.ing of everything.in the application., for the final safety analysis report, and the whole staff review of thati, and so on.
COMMISSIONER GIL1 NSKY:
What I understand the Bechtel people to be saying -
c.orrect me if I'm wrong ---
is that this kind of detailed final de sign somehow conflicts with industrial reality.
Is that in fact what your're saying?
MR. HALLI GAN=
We question that I, yes.
That you're going to get enough perturbation, through actual final equipment in there, that there is little or no difference
.in the amount of time of review required by the staff to confirm the fact that it does.fit the preapproved design, with the new specific equipment in it than cur approach where the criteria is preapproved, and we still buy the
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-12 13 14 115 16 jl7 18 19 20 21 22 23 24 25 55 specific equipment and put dimensions on it which requires a total staff review:
And the other -- I was thinking as you were talking about SNUPPS, Joe~ is there any difference~
really, in the approach-~ from the licensing standpoint',
considering the SNUPPS project*, to one of the generic family, and it becomes, then; the same reference submitted as a standard reference?
It is a standard licensed preapproved design~ and would enjoy~ or would require the same degree of changes to meet whatever license changes came along-, and commercial equipment chan;,es came along, as a standard reference plan submitted for a preapproved design.
The end product seems to me to be identical.
CHAIRMAN HENDRIE=
I think that/s righti, but I would want to cover the ground again to make sure I understood those things.
I have been threatening to give the staff a chance to comment, and why don't I -- Ed?
Roger?
Dick?
Please do.
MR. MATTSON:
From a broad perspective, as an engineering matter, what the people are proposing today makes good engineering sense~
That is\\ the approach to standardization which emphasizes performance objectives --
I didn't hear the words*, but I presume that underlying that is qualifications testing.
I did hear words about national standards.
That "s good, sol id eng inee ring sense, at least J
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The problem comes in trying to _implement that, alon9 the µ3th that Bechtel is proposing today.
One problem is a matter of trust -- trusting people to set performance objectives, not provide you any details about how they're going to meet them', and then expect them to come back* a few years later having met them.
I will give you two examples one having to do with the 1 ine sizes that these people have dis cussed; and the other having to do with something near and dear to your he arts.
One could look at the question of environmental qualification of electrical connection 11s 11 as a graphic example of setting performance objectives namely, "thou shalt provide electrical equipment capable of performing in the accident environment -
as a good example of setting a performance criteria, and then going about procuring equipment without a Lot of detailed analysis by the regulatory staff, maybe even none; and then finding out that you had a number of operating plants, ostensibly constructed to have environmentally qualified electrical connecticns that in fact it did not.
So there's a matter of trust in setting performance object.ives and. then understanding that they will be met, even when_ national standards exist'.
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Excuse me\\ Reger.
I--'m not sure how that situation obtains any differently in the proposal that they're making from any other, including a custom design.
As a matter of MR. MATTSON=
There's n01e, sir; I agree~
COMMISSIONER KENNEDYi It does not.
So that applies anywhere?
MR~ MAT1SON:
Yes, sir.
COMMISSIONER KENNEDY:
Okay*.
MR. MATTSON:
The question as tc how much detail is required in something like containment design, it is probably safe to say that the mass and energy capability of the containment to withstand a blowdown --- I don't need detailed dimensions of the containment:
The problem is that the requirement is to assure the safety of the containment, given a loss-of-coolant accident.
And that's more than just the mass and energy absorption capability.
It might be, for example*, asymetric loads on the vessel.
Does the breaking of a pipe blow the vessel open?
For that, one has to look at subcompartment loads*,
at a syme tr ic discharges.-, at their pipe size*, or even break opening time could have quite a lot cf difference on the engineering outcome of the technical outcome of the analysis-~
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10 11 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 58 It is possible, in principle~ to set performance objectives for all of those kinds of safety considerations 1, and to approve standard methods and procedures for coming at those pro bl ems.
It hasn't been done yet.
It's conceivable, and we're moving in that direction.
It*'s conceivable that we could achieve that.
This would certainly gi've us impetus in that direction.
One other comment that's probably a nit on this scale of things~
1he "topical reports:."
We have to be a little bit careful of how we use topical reports with standardized plans~
If we're talking about 15 topicals, that's a manageable number~
I* have a standard plan in my division right now under review that has 120 topical re ports re.ferenced.
So, 50 of them are unapproved.
Some of them are unsubmitted.
Now that's sort of counter tc standardization in the way that topical reports can get reviewed sometimes.,
They can get put aside for a number of years before the staff will reach a conclusion on this.
If that eventual review on a topical report leads to a design change 1, then I've circumvented standardization.
So a 11 I would say is "13" is a manageble number.
If you keep it manageable!, it's consistent with standardization.
CHAIRMAN HENDRIE:
Yes?
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In an effort to present sDmething in a general sense in a half-hour period, it is impossible to get into details.
I think we are fully aware of the kinds of things that have been mentioned, and recognize that the arrangement of the reactor vessel and the biological shield in the cavity*, and the treatment of this, and the methods as well as*, perhaps if necessary, limiting loads as some demonstration that you achieve these', and how, would have to be included in this design, as well, probably in the same degree of detail that you provide now.
I think the real question is:
What do they do with the specific numerics, at any point in time, when the real issue is the results:
Have you --- for example, are you qualifying the penetrations to the pressure, and how do you get the pressure?
What range of breaks do you consider?
And where?
And-how?
And so on~
What conditions are they qualified for, and what limiting conditions are they qualified tor?
Tnese are the things*~ it seems to me, that everybody is concerned with-, and not the *specific number.
CHAIRMAN HENDRIE:
Aren't there an awful lot of those things in a design where itJs easier for you -- God knows it"s probably easier for us -
to say", instead of trying to construct this enormous~ all-encompassing package of how we 're going to do it and gear the cri teriai, and so on, to
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Here's how we're going to do it; It's a piece of cold roll this big, and here's the dimensi 01 on it; and you want a stress analysis? there it is.
And we can look at that and say:
By God, that piece of ironwork is okay.
And it may be enormously simpler, from an engineering standpoint, to deal with a great number of the features of the plant design.
And-;* ye ah, maybe if you rea 11 y cu stem did every piece of every plant you ever did, that piece of ironwork would look different on this one over here!, and th.is one over here.
But, for God's sake~ it's sort of weighed down in the noise, and if you're going to be on a basis where you can deal efficiently with these designs~ we could be on a basis where we can review efficiently~ it would make a lot more sense to say "that's the gubber we"re going to use there,".an.d never mind a lot of fancy descriptionso MR. HALLIGAN=
I would -like to meet our desires',
our intent.
We would want to answer that problem in our generic design. That's the kind of thing that we want to put to bed in::--house.
So that we don't have a flock of structural engineers sitting around dreaming up new analytical methods to find more reasons for rebar *. But that is exactly the kind of thing that we want to put to bed in our generic, and you can do that for each NSSS supplier.
Because we would make the basic piping layouts so we would
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Those are the kinds of things that bog down the engineering design --- deci siOn-illaking :and design processes,- between us, the client, and you'.
MR~ MATTSON=
I wasn"t claiming it was impossible.
I say that it is difficult~
MR. HALLI GAN=
It "s difficult, but if it can'*t be done-, that would be a very fundamental cbjective of our design -- it would be to tie down that type of thing~
MR~ MAT1SON:
If I could *follow up with one more comment, Dr. Hedrie-, I think you mentioned!, the question of flexibility can,.become a very difficult question.
You can end up doing more review at the CP stage', perhaps, than you would w1 th a custom plan.
If the J:ermutations and combinations of different accident conditions, and different seismic conditions, and different torn ado conditions, and different flood conditions, can so complicate at that.the PDA review-, that you don't know how to sort through them all for a specific cycle.
If we're reasonable on that flexibility ----- that isl, we don't have seven different design le*vels for _earthquakes; we..,d.have a couple; and we dcn't have 18 different tornadoes 1
we have a couple ---- then i t"s manageable.
CHAIRMAN HENDRIE:
It at least gets closer to being manageable.
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I'm afraid we're catching up to time --- I was going to comment.
We all recognize that, even in a so-called "..final re.ference design" in which we're able to fee.l we have a final safety analysis to deal with and can make judgment on it and stand with it, we recognize that there are certain variabilities that end up there -
for the antitrust reasons, among others.
- Now, you recogn.:ize these things' 9 tooo It may be that the place that you end up and the place that the sort of thing I've been talking about ends up are not that far apart.
But I start from a place where I say:
Let's have a specific design in every possible nut-and-bolt detail that it can be managed; and then come down saying, all right, you've got meo I've got to allow flexibility to take any one of four pump vendors, so I have to come down off that absolutely fully detailed_ specific design, okay?
And here's another place where -- and that, in turn, maybe means that I can't fully define the piping hookup, so now there's another little flexibility, and so on.
And, right, here's a -
It-'s a balance of plant design, and I have to take a~count of the fact that just the primary inventories are substantially different between one SSS system and another, so I've got to do scmething about a swing in containment volume.
And we decided', I th.ink in one
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63 scheme', why*~ you know*;* the containment's either that high*,
or that high;* but it's the same diameter, *and the 3
arrangement is the same; it's a way o:f getting a volume 4
'Variable term in *to fit it*, and so on.
So* I've had to 5
come down some m*ore.*
i>
Your approach starts sort of down here*~ and says:
7 W&-'d like to; you* know~ be able to fit the customer, in 8
terms ot his specific seismic requirements', so we've got a 9
Whole :series*,of variations on that*, from a seismic standpoint,
- Jo plant layoutg *we've got the module units*, but*, you know, in 11 some plants we want the turbine. bu.ilding over herei, and some 112 over there*, and so on*~- and so *on:
13 And as you -- tor your own purposes*, and for 14 licensiQg µ..rrp6ses 1, fine; it's be*tter to *reduce the number 15 of these options~ and so on~
You sort of work up_ -toward
- 16
.. a specific design~
17 I'm coming sort of down, and yc;,u're coming up.
18 It may be that in fact we end_ VP not very far apart, but
!19 I sort of continue to feel that from the standpoint of 20 effective licensing and so on~ I ccntinue to.sort of want 21 to start up here, and then back off if I have to,. rather 22 than start out.with you and see how far we can encourage 23 24 25 you to c.lose down th.e number of options so tha*t it is manageable.
MR. STATION:
We certainly respect that 1, and we
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But we did an awful lot of work~ Joa; to ohi, we took bids tor any equipment components -- to make sure that the manufacturer could handle the load and also stay in business~
Be.cause it was obvious tha*t he couldn't dedicate his whole shop to do us for five or six year~:
And as a consequence, some of the procurements that we've made have been in trouble;* or we've found that our assessment of the guy's. ability to handle as much as, say, five units would put on him; has impaired his ability to deli'ver~
So~ I think you have to have the margin that wi Jl a 1low you to proceed 'under almost -- as many cfr;eum*stan ces that appear to be reasonable *tor the schedule we 're tr.yi*ng to achieve:*
So-we.. appreciate your comments:
I.think they are very per:tinent; they're the very thing we were looking for.
We didn't really come to seJl you this; we come to test the water*~ because our examination te.lls us that this has been a fairly successfuJ approach within Bechteli, we've bounced it off a ntnllber of our clients~-
They~ frankly~- are quite concerned about the standards program, as to the advantages that they can see for themselves.
We're not here to relate any concern of theirs
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I think we're trying to see how we can best serve the industry~ from the generic point of view.
So your comments, I think, were frankly very good for our purposes.
CHAIRMAN HENDRIE:
Well, that's very useful to us to hear your points of view.
You have a lot of experience with these plants, and it's very important that we try to understand the reasons that lead you to the sort of approach you'd like to take.
I would *--
CHAIRMAN HENDRIE=
I think it ould be useful, you know, as time goes on a little bit and you see more clearly where you want to go -- we would encourage you to be in contact with the staff officers who work on these standardization sorts of things, and to keep them informed; that a dialogue be maintained so that we could --
MR. STATION=
We are quite interested in knowing just what is the value of the licensing e+/-fort', depending on the kind of submittal we would propose;, and of course we don't have that depth of the detail but we could iron that out with the staff~
So I think we are going to try and pursue some evaluation in our terms, and perhaps yours;, where that is.
It may be that most of the review occurs after the CP, or maybe most of it would occur.before CP.
We're finding that,
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particularly on SNUPPS -
that we had predictable *licensing success on the thingi, and we really could have enjoyed more engineering time, to get more completed before we went in the field.
CHAIRMAN HENDRIE:
There*, you see, there are -
There are some CHAIRMAN HENDRIE:
There are disadvantages to speedy licensing~
(Laughter.* )
But in all good respect, we-'ve tried to point this out to Victor~ that for what we're attempting to do, if we're really going to get all the time, all the slack out of it-, we've got to work on not only licensing, we've got to work on constructicn time, the techniques CHAIRMAN HENDRIE=
That's exact Jy right*.
MR. STATION:
-- and the amount of commitment that we have to make in the field~
And that is being done, and it has been very helpful~
CHAIRMAN HENDRIE:
And you need to know what we're up to, too~*
If we a 11 of a sudden turned around and started doing 9-month reviews*, why ---
( Laughter~)
CHAIRMAN HENDRIE:
Thank you very much.
(Whereupon at 11:25 a.m.~ the hearing was adjourned.)