ML20216K070
| ML20216K070 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3092, NUDOCS 9910070233 | |
| Download: ML20216K070 (264) | |
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ORG\A_ AS N 7-3092 OFFICIAL TRANSCRII'T OF PROCEEDINGS NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
Title:
MEETING: 466TII ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
TRO4 (ACRS) .
RETURN ORIGINAL "
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....._.P 415-7130 THANKS! , ,. ,
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Docket No.:
Work Order No.: ASB-300-942 i em L OCATION: Rockville,MD DATE: Friday, October 1,1999 PAGES: 238 - 455 00 3 991001 T-3092 PDR ANN RILEY & ASSOCIATES, LTD.
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DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS OCTOBER 1, 1999 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory
. (,.n5) Committee on Reactor-Safeguar03 taken on October 1, 1999,
%j as reported herein, is a record of the discussions recorded at.the meeting. held on the above date.
This transcript had not been reviewed, corrected and' edited and it may contain inaccuracies.
l 10
238 1 UNITED STATES OF AMERICA )
2: NUCLEAR REGULATORY COMMISSION 3 ' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 ***
5 MEETING: 466TH ADVISORY COMMITTEE ON REACTOR 6 SAFEGUARDS (ACRS) 7 8- U.S. Nuclear Regulatory Commission 9 11545 Rockville Pike, Room T-2B3 10 White Flint Building 2 11 Rockville, Maryland 12 Friday, October 1, 1999 L13 The Committee met, pursuant to. notice, at
- 14 8
- 30 a.m. i 15 MEMBERS PRESENT:
16 DANA A. POWERS, Chairman, ACRS 17- GEORGE APOSTOLAKIS, Vice-Chairman, ACRS 18 THOMAS S. KRESS, ACRS Member 19 MARIO V. BONACA, ACRS Member 20 JOHN J. BARTON, ACRS Member 21 ROBERT E. UHRIG, ACRS Member 22- WILLIAM J. SHACK, ACRS Member
'23 JOHN D. SIEBER, ACRS Member 24 ROBERT L. SEALE, ACRS Member
.25' GRAHAM B. WALLIS, ACRS Member
[
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239 1 PROCEED-INGS
() 21 3 DR. POWERS:
[8:30 a.m.]
Let's come'into order j 4' '
Thd s is the second day of the 466th meeting of the 5 Advisory Committee on Reactor Safeguards.
6 .During today's meeting, the committee will 7 consider the following: proposed resolution of generic 8 safety issue 33, reactor coolant pump seal failures; status 9 of the proposed final amendment to 10 CFR 50.55(a), codes-10 and standards; reconciliation-of ACRS comments and 11 recommendations; strategy'for reviewing license renewal 12 applications; proposed regulatory guide on design basis 13 information; and proposed resolution of generic safety issue 14 B-55, improved reliability of target rock safety relief 15' . valves.
16- The meeting is being conducted in accordance with 17 the provisions of the Federal Advisory Committee Act.
18 'Dr. Richard P. Savio is the designated Federal 19 official for the initial portion of the meeting.
20' We have' received no written comments from members 21 of-the public regarding today's session.
22 We have received a request from the Nuclear Energy L
23' ' Institute for time to make oral statements regarding 24 prop,osed final amendment to-10 CFR 50.55(a). !
25 In addition, we have received a request from the l
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240 1 Westinghouse Owners Group for time to make oral statemencs s
(d 1
2 regarding the proposed resolution of generic safety issue 3 23.
4 A transcript of portions of the meeting is being 5 kept, and it is requested that the speakers use one of the 6 microphones, identify themselves, and speak with sufficient 7 clarity and volume so that it can be readily heard.
8 Before we launch into the session, I will ask if 9 any of the members have any opening comments they want to 10 make.
11 [No response.]
12 DR. POWERS: Seeing none, I guess we'll move to 13 the first topic on the agenda, which is the proposed 14 resolution of generic safety issue 23, reactor coolant pump
/~T ld' 15 seal failures.
16 Professor Wallis, can you lead us through this 17 issue?
18 DR. WALLIS: This issue is about 20 years old.
19 It started in 1980 because there was experience 20 with a large number of pump seal failures at nuclear power 21 plants during normal operation, and the leak rate for a 22 major seal failure can be several hundred gallons per 23 minute, and if this occurs at one or a number of pumps, this 24 constitutes a small break LOCA which has a potential to 25 uncover the core in a few hours unless appropriate actions ANN RILEY & ASSOCIATES, LTD.
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l l 241 1 are taken.
() 2 How, since then, there have been improvements in
.3 several things. One is in the materials of pumps seals, and 4 one is in the reliability of methods for cooling them. Very 5 often, the seals fail because they are not adequately l 6 cooled.
I 7 As a result, there have been very few experiences 8 with major pump seal failures. I think we need to get l 9 straight what that experience is, but I understand that, I
10 over the past 10 years, there have been no significant pump 11 seal failures, and the staff has essentially determined that 12 there have been so many improvements that this is no longer 13- a generic safety issue, although there may be some plants 14 that have perhaps not installed the materials or not made i( I 15 the improvements in their cooling system, so they might i
16 still require attention. I 17 So, probably on this basis, on the basis of 18 . determining -- also on the basis of risk analysis of this 19 issue, it is probably appropriate for this GSI to go away.
20 Now, there are still some technical questions we 21- may want to ask about, such as how many of these 22 improvements have really been made and how many plants L 23 remain that require attention. I 24 There seems to be some question about what is the J 25 real flow rate we're dealina with. You will see numbers of l
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r-242 ,
l 1 182 and 300 gpm, but if you go over the Westinghouse
- t. .
~'\ 2 analysis, you'll see something around 480 gpm and so on.
, [G i 3 So, we might want to ask a few technical questions.
1 4 But essentially the case is there haven't been 5 failures, there have been improvements, this is no longer a 6 generic issue, and risk analysis shows that only very few 7 plants require attention and, therefore, this chould no 8 longer be a GSI, and John Craig is going to get us started.
9 John, are you ready?
l 10 MR. CRAIG: Good morning. Yes.
11 While Jerry Jackson and Art Buslik come up to the 12 front of the room and get ready to make the bulk of the 13 presentation, I'd just like to add a couple of comments to 14 the.. remarks that you just made.
( 15 This was an issue that was identified, in fact, l 16 some 20 years ago, and as a result of some staff work, we 17 developed a model that was based on work that Westinghouse i
18 had done, a considerable amount of work in testing for their 19 reactor coolant pump seals.
20 We built on that and the model that resulted, is 21 referred to as the Rhodes model, which is conservative, and 22 you'll hear how we're going to use that in some 23 plant-specific analysis.
l 24 The staff proposed a rule that the Commission, for 25 reasons that Jerry and Art will go into, said that we should
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243 1 not move forward with because of plant-specific
-[q q) 4 2 :onsiderations, that it was not generic.
3 There were other generic issues that were tied 4 into this, this generic issue, one related to station 5 blackout, one related to loss of cooling water systems for 6 tha reactor coolant pump seals, and you'll see, I think, why 7 those issues -- or how we're addressing those largely as a 8 result of plant-specific analysis.
9 This is an activity that's been coordinated 10 closely with NRR, and as we get to the end of the 11 presentation, you'll hear about continuing reviews and some 12 plant-specific -- more in-depth plant-specific analysis that i
13 will be conducted for some number of plants that we expect 14 to be in the neighborhood of about 10.
15 Following the results of those analyses, NRR will 16 make determinations about plant-specific back-fits.
17 So, with that as an introduction to -- and I agree 18 with the characteri=ation that Dr. Wallis made -- that was 19 originally perceived as plant-specific, as we look at it 20 more and more closely -- or as generic -- more closely, 21 there are plant-specific questions and approaches, largely 22 form the basis for the resolution of the issue. ]
23 So, with that, I'll turn it over to Jerry Jackson.
24 MR. JACKSON: My name is Jerry Jackson. I'm with 25 Office of Research, and the other two presenters will be
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l 244 L 1 Mark'Cunningham and Art Buslik.
j
)- 2L I'd just like to quic'ily go through what our 3 agenda will be this morning, what we intend to cover.
l
.4 ~ We're going to have a short introduction and.
5L background. Then we need to go into some discussion about 6 how reactor coolant pump seals are cooled, and t:1en the bulk 7 of the presentation will be plant-specific analysis and risk
- 8. considerations that we will get to then, followed'by a 9 conclusion, j 10 As was already mentioned, as John had already 11 mentioned, the reactor coolant pump seal failures that we
,12 had a concern about were from the normal operation failures 13 early on, when the issue was first prioritized, and since l
14 that time, as has been spoken about, these have improved,
() f15 but even'early into the issue, concerns began to develop L 16 about. methods of loss of cooling that would affect the seal i
17 failure, and these were station blackout or component 18 cooling water or service water, all of which you will see 19 later support the cooling of the seals, and so, therefore, 20 the bulk of the concern that the staff had has shifted to a l
21 loss.of all seal cooling and how that can affect or cause 22; seal failures.
23 This led the staff'into a number of research areas 24 to determine how the seal would behave under a loss of-25 cooling event', because the seal is designed to be cooled at i
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p-245 1- all times,
() 2-3 Our'first -- the first concern that was had were
'for the soft materials, things like 0-rings and so forth, 4 that-.could fail under high temperature. If the seal cooling
.5: were not available, then they would be subjected to the l-l- 6 reactor coolant temperature, and they could fail.
7- .Further -- and in this test, we identified -- at l:
t 8 least.in the Westinghouse seal -- that some of the earl L 9 O-rings'that they used would, indeed, most probably fail.
10 Since then, they have developed new materials, improved 11- materials, and tested them for those conditions.
l 12- Also,-this led us to concerns about the hydraulics l 13 stability of the seals, what will be referred to later on as 1
~ 14 a popping open, the seal instability -- on loss of seal
( fl '( 15 ; cooling, if you have flashing to occur between the seal 16 faces that can cause the mechanical seal faces to actually 17- open wide and' allow'a large leak rate, and after doing this 18 research, we developed a. seal model that will be referred to 19 later as the Rhodes seal model, and it was based on --
l 20 .primarily on the Westinghouse seal model, with modifications
- 21. that the staff thought were necessary to the model to make
- 22. it what we believe would be more realistic.
23 DR. WALLIS: I think the Rhodes seal model is
'24 essentially a risk model, not a' hydraulic model. It draws
. 25 on some other estimates of thermal hydraulics.
t-i l
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246 L
I 1 MR .' JACKSON: Right.
I l
() 2 3
DR. WALLIS: The Rhodes model that plays such an important role in your work essentially is a risk model.
l 4 MR. JACKSON: That's correct.
5 DR. APOSTOLAKIS: What does that mean?
I 6 MR. BUSLIK: That means basically that it's a set 7 of events with their probabilities -- events, timing, and 8 probabilities.
9 DR, APOSTOLAKIS: You will talk about it today?
10 MR. BUSLIK: Yes, i 11 MR. JACKSON: We'll talk about that in a quite a i i 12 bit of detail. ,
i 13 'This led us to propose a generic rule that would l 14 be applied to all the PWRs in 1994, and this rule was sent
() 15 to the Commission, and it basically said that the licensee 16 should take action to reduce the dependencies to ensure core 1 17 cooling given a seal failure or demonstrate that the risk 18 from seal failures were sufficiently low that no further 19 reduction would be justified, and in 1995, the Commission 20 took up this rule, and in their SRM of March 31, '95, they 21 disapproved putting this rule out for -- to the public, and 22 they gave as reasons, there was insufficient basis for gains 23 in safety, and they also believed this was not a generic 24 problem, that it was very plant-specific, and they had 25 concerns about the model that the staff used in coming up
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1 247
..j 1 -. with their risk numbers, and then they also pointed out that
( ) '2 the industry was addressing many of these concerns through 3 their IPE program.
4 I'd like to put up this morning just one diagram 5 to illustrate a little bit of what we consider the important A aspects of this, not only that the seal -- the seal, as I 7 mentioned oefore, needs to be cooled at all times, and the 8 seal is cooled by two different methods.
9 You have seal injection flow that comes in that's 10 provided by'the charging pumps, which are also cooled by 11 component cooling water or service water, and this comes in 12 in the orange here.
13 It's higher pressure that the reactor coolant.
14 This is the pump shaft in this area, and reactor coolant in n
15 the schematic is'here.
(s.)
16 So, injection flow comes in at a higher pressure 17 flowing down along the shaft and blocking the flow of hot 18 reactor coolant. ;
1 l'9 DR. WALLIS: What is that big pipe at the bottom?
I 20 MR. JACKSON: This is the schematic that
, 21 - represents the second method of cooling, which is component i
22 cooling water, to a heat exchanger that surrounds the shaft.
23 This is -- in the Westinghouse model is referred to as the l
24 thermal barrier..
25 So, you have two methods of cooling the seals --
']
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248 1 the injection flow which actually cools the seals.and blocks 2 the flow of hot reactor coolant from coming up the shaft,
.(
3 and in the event that you lose seal injection, then you 4 still have component cooling water through this thermal 5 barrier, and when you lose seal injection, then you have hot 6 reactor coolant flowing past the thermal barrier heat 7 exchanger and cooled by the thermal barrier heat exchanger.
8 The flow then passes through the first-stage seal.
9- In the Westinghouse design, this seal takes up almost all of 10 the pressure drop. It goes from about 2,250 pounds per 11 square inch of cooled water, charging flow, and drops down 12 to about 50 pounds pressure on the back side of the seal.
13 So, the number two seal is just designed as a 14 backup. In the Westinghouse seal, the number one seal
-A (s; 15 provides the primary sealing flow. ,
16 If you lose all cooling in the hot reactor, 17 coolant flows up through the seal. There's a couple of ways 18 that failure can occur.
19 There are O-rings that are critical, like this one
'20 that's shown here, that can blow out due to the high 21 temperature, and the seal balance -- it's balanced depending !
22 on the pressure above this floating stationary ring, a 23 downward force there.
24 Opening force is ba'anced, a comes from the flow and
'25 the pressure drop through the seal.
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l 249
~
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, 1 If flashing occurs when the hot reactor coolant
()
L i 12 comes.up through the seal, when you've lost cooling, then 3' there's a possibility that the pressure distribution will
~4 cause this floating seal ring to move up and open this face 5 very wide, and that's what leads to the large leak rates.
6 And the point we want to make primarily here, 7 though, is that you have two methods of cooling, and even i 8 .the injection flow is dependent on-the component cooling
! 9 water and the service water, as well as, I think, 11 0 t high-pressure safety injection system, too.
'11 With that, I think we'll go into the risk 12 ' considerations, and I will turn it over to Mark Cunningham.
13- MR. CUNNINGHAM: As John Craig alluded to earlier, 14 the original basis for the GI-23 was kind of the spontaneous 1 ) 15 failure of reactor coolant pump seals. ,
16 Over time, it's evolved, and we recognize now that 17 there's actually a couple of other issues that are more 18 critical, at least from a risk context, about seal
.19 performance.
. :2 0 ' In particular, they deal with the issues of i ,
l 21 station black-out-induced seal failures or losses of l 22. component cooling water or emergency service water failures.
.23 DR. . WALLIS: Mark, could you clarify the matter of 24 the last 10 years?
l
'25 My. notes.of our subcommittee meetings said there
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250 1 had been no seal failures in the past 10 years, but I 2 ' understand it's not really no seal failures, there have been
(
3 some, but they haven't been of any significance or i
4 something? What sort of failures have occurred? I 5 MR. JACKSON: We looked back through -- we looked 6 back at the data, and we can find no seal' failure since 1980 7 that would come anywhere near challenging the norma 2 8 charging system.
9 There have been no seal failures whose leak rate 10- has been above 100 gallons per minute. So the normal makeup 11 would be able to take care of that.
12 DR. WALLIS: There have been failures of some 13 sort.
14 ,
MR. JACKSON: There have been failures, j ) 15 DR. WALLIS: Which involve what, the O-rings or 16 what?
17 MR. JACKSON: Not necessarily, because our concern 18- now is primarily with seal cooling. Most of the failures 19 are failures that occurred just during the normal operation 20 of the seal.
21 DR. WALLIS: Not loss of cooling water in some 22 way?
23 MR. JACKSON: Not necessarily. They're not l I
24 necessarily cooling water events, loss of cooling water l 25 events.
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i 251 ;
i 1 .DR. UHRIG: If you have that type of leak, do you I I~'Y 2 consider operation, 100 gallons per minute?
V 3 Mk. JACKSON: No. The recommendations, of course, l
4 would be to close down.
5 .DR. UHRIG: As soon as practical?
6 MR. JACKSON: They have procedures for shutting 7 down'in an orderly fashion.
l 8 MR. CUNNINGHAM: Jerry made the point earlier, 9 these seals are designed to be cooled. If you've lost the 10 cooling to them, you don't want to operate the pumps, 11 basically. i 12 From a risk standpoint, the spontaneous failure of 13 reactor coolant pump seals, in effect, is a small LOCA, and 14 the original concern was does this dramatically change our A
() 15 perceptions on the frequency of small LOCA from spontaneous 16 failures?
17 DR. UHRIG: Remember we had a lot of problema with l 18 seals during startup'back 20 years ago. l l
19 MR. CUNNINGHAM: Yes. That's related to the i
20 genesis of this. issue, if you will.
-21 DR. UHRIG: Yeah.
22 MR. CUNNINGHAM: Again, over time, we've looked at 23 it a little more differently and come up to the point now 24 that the interest from a risk standpoint is a little 25 different.
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y 252 1 The interest is do you have-initiating events that 2- .can lead'to seal' failure and~ compromise the ECCS system 3 that's used to copeJwith the small LOCA, and that's where 4 the station blackout and the loss of CCW and ESW comes into 5 play.
6 In the station blackout rule and things like that,
'7 it is recognized that you lion' t have ECCS. The difference 8 .. here is, if you have seal failures, the rate by which you
-9 . lose. coolant from the system can go up much more than you 10 expected.
11 So, the. issue then is,'has the basis for the
-station blackout rule somehow been compromised by our
~
12 13 -understanding of seal performance, and this was recognized
- 14. in the station blackout rule that said that we'd come back
'15
( at some point once 23 started to be -- had a better 16 understanding on 23 and say do we.have a reason to question
- 17. 'the station blackout analysis?
18 So, the first thing that Art will talk about is 19 the' evaluation of the implications of closure of this issue 20 on the station blackout rule.
21 The second part, then, is related to loss of CCW 22 and ESW. Again you have a situation here that these losses 23' of these systems can'cause -- compromise the reactor coolant 24 pump seals by the mechanisms that Jerry was talking about 25 earlier, where you've lost the capability to cool the seals.
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b,
-s 253
()
2 .also used to cool the charging pump bearings or a variety of
.3 . things like that so that you can -- a loss of CCW can, 4 again, also cause failure of ECCS.
5 So, it's, in a sense, a common-cause failure i 6 that's much more significant than the spontaneous losses of 7~ seal. cooling.
8 So, the second part of Art's presentation is going
- 9. to be discussion of the loss of CCW and ESW systems. He's 10- gone through some review of different plant designs to see 11 'what the implications of this might be, and what you'll see 12 'is there's a-fairly broad --'the issue becomes very 13 plant-specific on the issue, based on the design of the pump 14; seals, on the design of the CCW systems and that sort of
() 15 thing, and Art will go through'that now.
16 MR. SIEBER: I have a question. I have heard 17 folks talk about disaster bushings. Is there such a thing, 18 and what is it and.where is it? {
19 MR. CUNNINGHAM: I'm sorry?
20' MR. SIEBER: Disaster bushings, which is intended 21 to close the clearance in the seal package. Have you heard 22' 'about that?
23 MR. JACKSON: There's flow limitations that are 1
24' ' built?into the seal. They're called -- maybe the 25' Westinghouse person in the audience might address those.
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i 254 1' The name escapes'me now, but yes, I've heard of those.
l
[)
%)
2L IMt. KRESS: Are you talking about the labyrinth 31 -- seals ?
4' MR. JACKSON: Labyrinth seals. Yes, the labyrinth 5'- seals limit the flow somewhat through the seals.
6- MR. SIEBER: But not all plants have that,, right?
7 MR. JACKSON: All plants, I think, have a j 8 _ labyrinth seal.
9- MR. TIMMONS: My name is Tom Timmons from 10 Westinghouse.
11 -The concept of a disaster bushing is something 12 that has been looked at-but has not been installed on any I i
13 Westinghouse plants.
14 What Jerry was referring to is a labyrinth seal,
() 15 which is tortuous path between the shaft and a clearance on
)
16 the casing, which limits the flow up through the thermal j 1
17 barrier heat exchanger into the seals in normal operation or l 18 on loss of all. seal cooling. ,
I
'19- MR. SIEBER: Thank you. l 20 DR. WALLIS: I have a question I'll raise at this 21 time.
22 Mark, you mentioned common-cause failures, and you i
23 spoke about component cooling water loss.
24 Now, I read all the stuff that came to me, and ,
j 25" .nowhere could I find how many of these seals -- you talk
)
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e 1 255 1- about the-seals or seal are mentioned, but there's never
/\ 2 .anything in the literature.aboutLhow many pumps are h./
-3. affected, and you've got -- this flow rate is quoted, but E4 presumably it's a. flow rate per pump.
-5' Is there some common-cause failure where you lose 6 Lcooling water, you lose it-to all the pumps?
7 MR. CUNNINGHAM: That's correct, and that's built-P into the Rliodes model.
9 DR. WALLIS: Then you have to multiply the 500 gpm 10 bylfour.
11 .MR. CUNNINGHAM: That's correct.
- 12. EDR~.'WALLIS: You will address that?
i
-1 31 MR. CUNNINGHAMi We will talk about that.
14 DR WALLIS: I didn't find that in any of the
() 15' 16 literature.
MR. CUNNINGHAM: But you're absolutely right, most 17 .of"the design that Jerry was' showing -- there's an t- 18 . individual pump, i.
19 DR. WALLIS: So you lose all the seals.
20 MR. CUNNINGHAM: You have the potential for losing i 21- all of the seals and having, instead of the leak rates we're 22- _ talking-about,-three or four times that, depending on the 23- number of pumps, that's correct.
i.
l- 24 I guess Art is going to start out talking a little 251 . bit about the Rhodes model that we foresee.
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F 256 1 MR. BUSLIK: The Rhodes model is common. You need
(}
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2 to understand thrt to understand how the seal behaves with'a 3 lack of seal cooling, and so, before discussing two 4 particular ways of losing seal cooling and the ability to 5 mitigate it, namely station blackout and loss of component 6 cooling water or ESW, I'll define what the Rhodes model 7 m e a.' s .
8 Now, the Rhodes model came from Appendix A to 9 NUREG/CR-5167, which was a cost-benefit analysis for this 10 issue, and basically, the only paths which have any 11 cignificant probabilities are, one, the reactor coolant pump 12 seals half open, and this, as Jerry said, refers to 13 hydraulic instability of the seals, when two-phase flow goes 14 between the seal faces, and the seal faces that pop open --
15 there are three stages in a Westinghouse pump.
[v) 16 The first stage has a relatively low probability 17 of popping open and is actually neglected in what I'm doing.
- 18 The second stage has a -- is assigned a probability of 20 19 percent by Dave Rhodes of popping open, and given that the l
20 second stage pops open, the probability that the third stage 21 will pop open is one.
22 Now, the pop-up that occurs when the hot fluid 23 reaches the seal faces, the inlet to the seal face, seal 24 stage, once -- when there's sufficiently low sub-cooling of 25 the fluid at the inlet to the seal faces, then flashing will )
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g 257 l 1 occur during the seal phase.
2 DR. APOSTOLAKIS: Can you explain these three l ~3 stages using the diagram that Jerry showed earlier?
4 MR. BUSLIK: He would probably be able to do it 5 better.
6 DR. APOSTOLAKIS: Just to help me follow you.
7 MR. BUSLIK: Basically the fluid seems to go 8 through it in series.
9 DR. APOSTOLAKIS: So, explain, please, the three 10 stages?
11 MR. JACKSON: There are three stages in the 12 Westinghouse seal.
13 You see where seal runner number one is, is 14 attached to the shaft. ]
() 15 16 DR. POWERS:
MR. JACKSON:
Okay. Yeah.
And there is -- the first seal stage l l
17 is the mating part between -- this is the floating seal 18 ring, and the first stage seal is the mating part between 19 this floating seal ring and the runner which is attached to 20 the shaft.
21 So, that limits the flow, and in the Westinghouse
- 22. seal, this takes the primary pressure drop, it's the primary 23 limiting mechanism for flow there.
24 Then, it's further reduced through the second 25 stage seal, which is this runner attached to the shaft, and I l
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258 1 the mating part is to a floating seal part.here.
('~} . '2 So, the mechanical face is.here. That's the Na' _ -
3 second stage seal.
4 And then the third stage seal is just -- it's 5 similar with a third stage runner and a part here. That's 6 simply a' low-pressure atmospheric-type seal.
7 So, in the Westinghouse seal, the primary method 8 of sealing is all in'the first stage, and in the event that 9 it. fails, then it shifts to the second stage, but the third 10 stage is not really designed for the high pressure. That's 11 why it has a probably -- a given of one of failure if you 12 have the other failure.
13 DR. WALLIS: Your analysis of loss of cooling l 14 water is occurring somewhere else. Typically, if you broke O) g 15 something like the first number one seal bypass, then the 16 flow would go squirting out there, would never go to the 17 seal at all.
18 MR. BUSLIK: If you broke this, for example -- if 19 something happens and the flow here is stopped, your ueal 20 injection is stopped. If both of those happen, you would 21 lose cooling.
22 DR. WALLIS: If the mechanism for that had been l l
23 the breaking of, say, the number one seal bypass, your water l q
24 would not have to go through all these paths. l 25 MR. BUSLIK: The concern is that can lead to a l
)
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p 259 1- 'small LOCA. What it doesn't do is -- because it doesn't 22- lead to chis-situation where'you've, lost the coolant and 3' lost the ECCS.
~4 If you have a small break LOCA and you're able to
- 5. mitigate it, then it's not as serious, and if it happened at
- 6. a sufficiently large frequency that it would increase the 7- frequency of smallt break LOCAs -- but that was back to what 8- we were considering originally.
9 DR. WALLIS: On that' slide, you have the t- 10 probability of pop-open mode-is 20 percent epistemic 11 uncertainty as a statement?
L1'2 MR. BUSLIK: Yeah.
- 13. DR. WALLIS: Is that an assumption, or is there 14' some evidence forfthat? Where does that- come f rom?
(A.j -
15 MR. BUSLIK: That's basically expert judgement.
l 16 IfLyou look at;the'NUREG-1150 expert judgement studies that 17 were done, Lone expert from Westinghouse gave a relatively l 18 low ~ probability of it. Dave Rhodes was another of the 19 experts. He gave, I think, 20 percent, and later, we 4 l
2 CL attained that. And then there was a third expert who gave j 2 11 it 25 percent probability. I l
L 22- It's state-of-knowledge uncertainty. Westinghouse j l 23 has a calculation which indicates that actually you don't H24 Eworry about two-phase-flow going through the seal, but the L
25 seal, because of thermal ~ heating'up, will pinch closed, and
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260 1 you won't get any flow through it, or very little flow, but
[)
mj 2 there are large uncertainties in that calculation, according
.3' to various experts.
4 Jerry may be able to answer that one better.
5 MR. JACKSON: As Art said, the second stage -- on 6 failure at the first stage, the Westinghouse analysis and 7 other analyses show that, if everything goes as planned, the 8 second stage rotates in a manner that closes off or pinches 9 off the flow, and it's held together thermally and doesn't 10 allow a flow to go through there, it becomes a limiter, but 11 there are things that could happen that would cause that to 12- not occur, and that would be too much -- it requires a small 13 amount of leakage through this second-stage seal, but that's 14 pinched closed but just enough to supply a boundary -- a f%} 15 boiling water boundary condition on the back side.
16- So, this is -- we feel is open to some question if 17 it will really occur, and that's really the basis for the 18 probability of 20 percent.
19 DR. APOSTOLAKIS: So, this is acting as an 20 initiator? This is the first failure, or this is in the 21 context of something else that this happens?
22 MR. JACKSON: This is given losses of seal 23 injection and component cooling water.
24 DR. POWERS: Okay.
25 MR. JACKSON: There's a 20-percent probability --
i
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u 261
-1 -this conditional probability of 20 percent of having this
. failure mode'of the seals.
'2_
3 DR. APOSTOLAKIS: Now, why did you choose to go I
4 with:epistemic here? I mean if you have 1,000 of those 5 ' initiators, you would~ expect exactly 20 percent?
6 MR. BUSLIK: No.
L .7 DR. APOSTOLAKIS: That's what this means.
8 MR. BUSLIK: If you 1,000 -- if it were epistemic, 9 my understanding would be it would be like a coin which is
- 10 two-headed or tail tails and you don't know which.
11' DR. APOSTOLAKISi .Right.
12' .MR. BUSLIK: So, here, if you had.1,000, then 13 nearly all of them would pop open or nearly none of them.
- 14 ' DR. APOSTOLAKIS: That's what I'm saying.
I\ 15 ~- .MR. BUSLIK: That's.the approximation.
V 16- DR. APOSTOLAKIS: Now, is that a reasonable 117 approximation?. -I mean why don't you have aleatory 18- uncertainty?
19 .MR. BUSLIK: There is some.
2'O DR. APOSTOLAKIS: Some of them will fail, some may
'21 .not. I mean that's too drastic, is it not?
l- 22 MR '. BUSLIK: There may.be some. For example, one 231 of the mechanisms which may make it pop open is there may be
- 1. .24 scratches or wear on the seal faces, but I'm not sure how
- 25. much of that is really required there, and if there were l
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262 x 1 wear, practically,-as far as a point estimate is concerned,
. 2- it's a question of whether they all fail or only one of the L/)T '-
'3 .four fail, and'if there.were wear, you-would expect that the
- 4. pump seal faces would be worn pretty much the same, I 5 believe, for all of the pumps. '
6 DR. WAI.LIS ': What did ths' experts say about this.
7 -probability?. If'you have four pumps, they said that, if one I 8 ' fails, _they all fail?
9 MR '. BUSLIK: Dave Rhodes did.
- 10. Now, I believe there was a -- and I think probably 11 Jerry Jackson. thought so. .I believe that the Westinghouse
-12 expert did not believe that was.the case. It really 13 depends,.to a certain extent, on whether -- on how important 14 you think that -- how bad you think the wear has to be, and
() 15 161 they-also gave a lower probabi2ity.
it.
I think that's part of 17 MR. SIEBER: But the wear reveals itself as a 18 t change in seal leak-off,.right?
-19 MR. BUSLIK: No, I don't think you have to have
]
1 20 that much. wear for it to occur. '
21~ DR.-APOSTOLAKIS: So, you had three experts, you 22 say, and they gave 20 percent, 25 percent?
23' MR. BUSLIK: You always have to worry whether l
124 ' experts are independent. One expert gave 20, one gave 25 25z percent, and the other gave a low probability. I don't ANN RILEY & ASSOCIATES, LTD.
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263 1 remember n what it was,[but it was perhaps 1 percent, 2 2 percent.
3 'MR; CUNNINGHAM:~ Just to be clear, the three 4 experts were assembled. That was in work being done for 5 'NUREG-1150'. So; that's been a number of years ago.
6: DR. APOSTOLAKIS: They went through the training 7 and.everything.
8 MR. 'TNNINGHAM : Yes, that's right, all the expert
.5L elicitation process that was used.
10 One of tha issues in 1150 was reactor coolant pump 11 seal performance.
12 DR. APOSTOLAKIS: This was one of the few level 13- -ene issues.
14 MR. CUNNINGHAM: Yes, that's exactly right.
([ 15- DR. APOSTOLAKIS: Probably the only one. I don't 16 remember another one. Was there another one?
17 MR. CUNNINGHAM: I think there were a couple of 18' others, but you're right, the vast majority of them were
- 19. level two.
' 20- DR. BONACA: Do all pump designs use the same 21 materials for the seals, and what are these materials, and 22 'what:are the failure modes?
~
.0 3 ' MR. JACKSON: No , they're different. Our early
- 24. concern.was primarily just with the Westinghouse seal, and
'25 'most'of the work was done with that seal, and that's what
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-:e1 i -i.... .
264 l' the model has been developed for. We had to use this tool j f .2 as a -- what.we feel is a bounding case to apply to the 3: other seals.
!. 4 Now,. Westinghouse accounts for like 54 of the 5, plants when the other two seals involved are, I think, 10 6 Byron Jackson and nine Bingham that are involved.
7 DR. WALLIS: We can read this slide. I'm puzzled 8 by what I see. I see this 182 gpm, and then your upper 9 bound is'300. I read a Westinghouse report where they 10 . predict 490 and an E-Tech report where they say 440, and 11 there's an H.B. Robinson experience where it was 500, 12 MR. BUSLIK: Let me explain.
13 When I say 182 gallons per million, that's a given 14 for a certain set of failures, that the second stage and
'{ 15' third stage fail, so to speak, pop open, so that basically 16 they don't limit flow. Whatever flow resistances there are
'17- are from the number one seal and the labyrinth seal.
18 The 480 gallons per minute corresponds to 19' . essentially removing the whole seal package and having left 20 .only that_ tortuous path, basically, to limit things, the 21 labyrinth seal, and then you would get estimates on 480
-22 gallons per minute.
23 That has a low probability of occurring. Compared 24- to this 20 percent, le has, I think, according to Dave 25 . Rhodes, something like five times 10 to tne minus three ANN RILEY & ASSOCIATES, LTD.
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l I-
p 265 l~ probability, and it turns out~it won't contribute.
I Q) l
['I. 2 DR. WALLIS: Well, I guess it depends on the 3 consequences. If you have a leak of 2,000 gpm, four pumps, 4 ratner.than a leak of, say,,1,000, that makes quite a l 5 difference.
6 MR. BUSLIK: Well, it depends.upon when you're l 7- trying to recover.
8 DR, WALLIS.: It makes a difference to your LOCA, 9 that's right, and you're talking about four hours, but you 10' -don't get four: hours with the 2,000.
11- MR. BUSLIK: Don't get four hours, that's true.
-12' If 480 gallons per minute had an appreciable probability and 13 if there were -- if the curve for recovery of off-site 14 power, let's say, of station blackout went down very
() 15 16 rapidly,-conceivably it might make a difference, but it doesn't.
17 DR. WALLIS: It seems to me you have to still 18 a'ssess it. You can't just dismiss it. You have to look at 19L 'the probability and the consequences.
20 MR. BUSLIK: It was assessed, I believe, by Dave 21 Rhodes.
22' DR. WALLIS: _ And your final evaluation of 23 probability appears, then?-
24 MR. BUSLIK: I didn't actually-include it. I
- 25. -neglected it=in what I did, but I could make a bounding i
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.1
1 l
266 1
l 1 estimate, t
' [ )
Q ,i 2 DR. WALLIS: The H.B. Robinson was an expirience I 3 where they started up a pump after -- they did get like 500 4 gpm.
5 MR. BUSLIK: That's correct, but what happened 6 there, my understanding, is that -- well, actually, Jerry 7 can explain it.
8 MR. JACKSON: I thir,k they had a problem with the 9 pump that failed, where the .tirst-stage seal -- there was a 10 sale failure, and they shut down in the normal manner, and 11 while they were shut down, there was an occurrence that 12 somehow blocked -- they got crud into the other seal on the 13 other pumps, into the seals, and they couldn't start up the 14 pumps because they couldn't get the minimum flow through the
/x 15 first-stage seal, and they tried to restart the failed seal, (s _-)
16 and when they did that they had a mechanical failure.
17 The parts of the first-stage seal were thrown into j 18 the parts of the second-stage seal and into the parts of the 19 third-stage seal.
20 So, mechanically -- they mechanically failed the ,
1 21 seal by trying to restart it when it already had a failure 22 that resulted in a high leak rate. It was a procedural 23 error.
24 DR. WALLIS: They got 500 gpm. The only evidence 25 we have -- these are estimates, these numbers here, is that
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r-267
.1 ~500 gpm'is possible,' and"these. numbers here are-based on 2- theory.
Jr.
': 3 . MR. BUSLIK: These numbers are based on theory,
-4 that's correct.
5 Now,-you-may also --
=6 ^DR.'WALLIS: Who calculated -- excuse me -- the 7 .182 gpm?
8 MR. BUSLIK: Okay. This was initially calculated, u 9' 'I believe, by Westinghouse.
l 10- DR. WALLIS: What you_get from Westinghouse is l 11' this 490. .That's what bothered me.
l 12 MR. BUSLIK:- Westinghouse considered various paths l
'13 on anfevent tree, which unfortunately I don't have with me.
14 If all three seal faces popped open, you would have 480 15 gallons per minute. If the first stage does not pop open i 16 but the second and third stages pop open, their best 17 estimate is 182 gallons'per minute. ld1d there are various 18_ ~other things that werefconsidered.
19 DR~..WALLIS: So, you're dismissing the worst case, 20; .saying it's improbable.
- 21 MR. BUSLIK: I'm dismissing it based on the 22 'probabilityfof_ occurrence:for a loss-of-coolant event.
23- Now,- it could occur from a mechanical failure -- )
i 24 indeed,-it has_ occurred, but under those circumstances, 25 you're able to mitigate the LOCA. ,
l G
-( ,f' .
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+-
U;/
268 t<
L 1. li-a more -- the problems we are concerned about t
() 2 3
is it; occurring on a station blackout. With the pump stopped or on a loss of component coolant water, ESW, i
- j. 4 'there's a loss of seal cooling. It's conceivable that the 5 operator would not stop the pump, but it's against all his l 6 proceduresp and with a high probability, he's going to trip i
l 7 'the pumps.
I 8 ItRis considered in PRAs.
- 9. If you had a different model where these 10 probabilities weren' t as high,
- you might have to consider 11 the operator error of failing to trip a running pump.
12 Now, the.other kind of failure has to do with the 13 0-rings in Westinghouse pumps, and there the model assumes 14 that they. fail at two hours after a loss of seal cooling.
(). 15 ,
? Essentially, the temperature makes them softer and they 16 extrude out through a gap.
17- How fast they'll extrude out depends on the 18 temperature, .it depends on the size )f the gap, it depends 19 on the pressure, and Dave Rhodes did not give any credit --
20' the' operator, in an accident such.as this, will 21 de-pressurize the reactor coolant system. i 22- He'didn't'give any credit for a delay in 0-ring 23- failure or for that, and I mean he explicitly mentions that, 1
~
24 it'sfnot an oversight, and he must have a reason for it, but !
25 I don't-know what that reason is. It isn't documented. It
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e 1 269 J L- .. 1 has to-do with what experimental evidence he had. There was (s.) 2 experimental evidence'for 0-ring failure. They did do tests 3 on.the O-rings.
4 ' MR - SIEBER:
. I presume there's only 0-ring of I
~
5 importance on.that drawing that you had?
6 MR. JACKSON: There's one in each stage, at least certainly in the first and second stage, of primary 8' importance, the.one-that seals the noveable -- the ring that 9 moves up:and down, in the up-and-down direction.
- 10. MR. BUSLIK: He explicitly mentions that he's 11- -talking about failure of 0-rings in the first and second 12 stages.
13 Now, what's the time to core uncovery? By the 14 way, the uncertainty -- I did do a sensitivity study where I l) 15 assumed that you got a 95-percent upward bound flow rate of 16 -300 gallons'per minute for this.
l 17 E-Tech said that there was a 50-percent 18- funcertainty from two-phase flow correlation, which was 19 higher than what other people had said in the literature, 20 but it was from their experience. They expanded the 21- uncertainty.
i 22- DR. WALLIS: So,'this was come up with by your j 23' consultants, then.
sL MR. BUSLIK: Yes, that's correct.
25- DR. WALLIS: Did you multiply by two? I i
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270
~1 MR .- BUSLIK: No. Fifty percent, I interpreted,
'[~ 2, 'from 180 would be 270, but there are other factors, friction
%)).
3 . factors and things, so I just.took a number of 300.
4 DR. APOSTOLAKIS: Do you have anything against 5- diagrams? It would have been much easier to follow this is' 6 you showed.an event tree to begin with, and second, the time 7- axis _and put all these things there'. It's really hard to-8 follow.
9- MR. BUSLIK: That may be true. There may be 10- something against diagrams, because I find them hard'to 11 draw.
12- [ Laughter.]
'13 'DR. WALLIS: You run 300 gpm per pump. So, you
- 14. have,a four-pump plant, or what do you have?
() 15 16 MR. BUSLIK:
in1 Westinghouse plants.
There are three- and four-loop plants 17 DR. WALLIS: These are plant-specific, these 18 scenarios, now.
19- MR. BUSLIK: Yes, but it' turns out that the 1
~
1 20 ' inventory in the'four-loop plant is bigger than the i i
21 inventory in:the three-loop plant so that the times to core 22 uncovery are about the same for a given leak per pump.
1 23 DR._WALLIS: You're talking about a loss of )
24 coolant accident now with four pumps all leaking 300 gpm, 1
25 MR. BUSLIK: Yes, for one of the failure modes, l ANN,RILEY & ASSOCIATES, LTD.
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l 271 1 that's right, and actually, Westinghouse verified that I~T 2 they're basically the same.
Q 3 I basically took -- it's a small conservatism tLat 4 you'll get core uncovery in four hours whether you have the 5 seals pop cpen and then the O-ring failure or the seals 6 don't pop open and the 0-ring failure, things like that.
7 DR. WALLIS: Did you run a LOCA scenario or 8 something to figure this out?
9 MR. BUSLIK: They were run for me beforehand. The 10 results are given in one place in a Westinghouse document.
11 Now, for non-Westinghouse pumps, I basically --
12 and this was in agreement here -- I basically used the same !
13 model as for a -- as far as pop-open and the same 14 probability of pop-open as for a Westinghouse pump, but we rN
() 15 assumed that the -- basically, the elastomers are better, 16 and we assume they will not fail.
17 They're, I think, of a different material. They 18 tend to harden instead of soften with temperature. Indeed, ,
19 the new Westinghouse 0-rings, which we assume don't fail, 20 also have that property.
i 21 DR. WALLIS: Now, this is another question we had. ;
22 You've got Westinghouse pumps with models. You've got these 23 other pumps where you're making an estimate that they're 24 probably better than Westinghouse, so we'll use the 25 Westinghouse number, but we haven't made an analysis of O ANN RILEY & ASSOCIATES, LTD.
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272 1 them.
- ( ) 2 MR. BUSLIK
- There was some analysis for a 3 particular big -- it's difficult to really do a good 5 4 analysis, because I don't think we have, for example, the
.5 dimensions and the design information for those pumps.
6 DR. WALLIS: If it'e necessary to do it, then it 7 has to be done.
8 MR. CUNNINGHAM: .Maybe we can come back to that in 9 a little bit, but there's - key point here that you're 10 hitting on, which is the Rhodes model was developed based on 11 a lot of analysis by Westinghouse and by the staff. There 12 is no equivalent model for the Bingham pumps or the Byrcn l
13 Jackson pumps. l 14 So we've had to apply it, as Art has said, to
(~h
() 15 these other plants, and it's to be, in one sense, sote sort i'
16 of bound on it, and that drives us in a particular direction 17 in terms of what we need to do as followup.
18 DR. WALLIS: What did the plants submit.> I mean 19 this must have been an issue. Did they just say we don't 20 have a model and you're going to get your own or make your 21 own assumptions?
22 MR. CUNNINGHAM: In the IPEs, they had their 23 model, which was -- they have a model which is, in effect, 24 very little leakage under these conditions.
25 MR. BUSLIK: I don't think that the -- for I
i
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r 273 1 example, Combuetion Engineering using a multiple Greek l
2- letter model where they. essentially assume that the various
?. [JD
.- 3 ; , stages in this pump lare like.having, say, three different
- 4 ~ diesel generators,.and you may have some common-mode failure
~5 .between them. .To me,'it's not~very sound, and --
( -
6 .DR..APOSTOLAKIS: I have another question.
7 MR. BUSLIK: Yeah.
L ^8 DR. APOSTOLAKIS: To what-extent-did you rely-on l 9 .other people's work when you did this?
10 MR. BUSLIK: As far as --
11 MR. CUNNINGHAM: I'm sorry, George. In what 12 specific context?
13 DR. APOSTOLAKIS: Well, it seems that all these 14 rates, gpm's, came from Westinghouse.
15 MR. BUSLIK: Oh. Yes, except that they were 16- verified for certain cases. It.happens that the 182 gallons
.17 per: minute wasn't verified, but E-Tech, in a document that 18l -- I think it's NUREG/CR-4294 -- did do -- go through the
-19 calculations, and basically, the model -- it's included in 20 the uncertainties.
21, 'It used a steady-state two-phase flow model where 22 you.had equilibrium between the phases and there was no 23 slip, and it was all mixed up, homogeneous.
24 DR. APOSTOLAKIS: Now,.you also relied on some 25 probabilities that were derived by Rhodes?
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l 274 1 MR. BUSLIK: That's right.
I
(%,') '
2 MR. CUNNINGHAM: David Rhodes is an employee of I l
3 AECL who was under contract to NRC to do this work, in i 4 effect.
i 5 RMR. BUSLIK: Right. And it's not very different l 6 from the central estimate or the mean estimate from the 7 three experts. Of course, there's dependence the're, because j i
8 David Rhodes was an expert. ;
9 DR. WALLIS: The E-Tech model gave the 400 gpm. l 10 MR. BUSLIK: Yes.
11 DR. WALLIS: So, what did that confirm?
12 MR. BUSLIK: Well, that did confirm -- actually, 13 it -- one of the primary limiting factors there ia the 14 labyrinth friction factor, I guess. I'm not sure what else j r~N '
i 15 is in the model.
16 DR. WALLIS: I guess, with all these different 17 gpm's, though, I'd be sort of reassured if you could let us l 18 know that it doesn't matter if the flow rate is up to 500, 19 because the risk analysis shows that it's okay anyway. Then 1
20 we would. forget about all these uncertainties in the flow '
21 rate.
.22 MR. BUSLIK: For the loss of component cooling 23 water in ESW, it won't much matter, because even with the 24 other flow rates, you don't have much time for recovery, 25 okay? So, you won't be able to recover.
I Os ANN RILEY & ASSOCIATES, LTD.
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7 275 i '
'1' t I'think that's true. I think, with 480 gallons
- (~)
V 2 per minute - I don't remember how long it will take for 3 core uncovery, but --
4t DR.' WALLIS: But if you get into some different
~
5, ' mode of failure which is more disastrous when you have these
'6 ~ higher numbers,.then I think it behooves you to show that 7 there's not a problem.
8 MR. CUNNINGHAM: The basic situation, as Art has
.9 kind of suggested before, is yes, there were other failure 10 mechanisms of.the pump seals that could have much greater 11 leak rates.
'12 They have a higher leak rate, but they have a 13 'substantially lower probability, in our estimate, by our 14 estimates, of occurrence, and it's the trade-off between the
,-~
( 15- . reduction in time to core uncovery versus probability that's 16- . built.into Art's arguments, and he's basically saying the 17 ones that are the most important are the two, the pop-open 18 mode and the 0-ring failure.
19 The other mechanisms, from a probability of leak 20' ' rate, if you will, or probability of time to core uncovery, 21 are not very important.
1 22: DR...WALLIS: So, if we get, then, to your bottom '
23 line, which.I guess we have to get to before too long, it 24 wouldn't chrnge the CBF significantly, ;
25 MR. BUSLIK: No, it wouldn't. It couldn't, l'
(
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276 1 because it changes the time you have for recovery, and it's
,m
( ) 2 not going to make --
V 3 DR. SHACK: Now, is that true for the 182 as well 4 as the -- the 300 is sort of bounded by the 500. At least I 5 have a bound there. The 182 seems to me the number that 6 kind of hangs out there.
7 So, if that was 300 instead of 182, would it make 8 a big difference?
9 MR. BUSLIK: No. These start at -- let me think.
10 If you had 300 gallons per minute, it will start in about 10 11 or 15 minutes into the accident, and it will take -- I 12 assume that core uncovery will occur in two-and-a-half 13 hours. That's conservative.
14 If you just had 300 gallons per minute constant, r'%
15 it would take about three hours to core uncovery from the
((_-) j 16 start of the accident, and I've done a calculation like 17 '
that, which you'll see.
18 Okay?
19 You see the result from station blackout.
20 Does that answer your question? I'm not sure. !
i 21 DR. SHACK: I'm not sure. I'm having a hard time, 22 as George said, associating initiating events with each of 23 these leak rates, you know.
24 MR. BUSLIK: It's because I started with what 25 happens if you lose seal cooling to a pump, and I didn't I
['1
(, /
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i 277 l j start.with the accident sequences.
19 Q
'2 MR.'CUNNINGHAM: In all of these cases that we've L3 talked'about,-the1 initiating events are loss of cooling to I
4- the seals.
5- DR. Sh JK: Yeah, but there's the seal injection 6 ' flow and then the' component coolant flow.
7 MR. CUNNINGHAM: It's the loss of both of those.
8- DR. SHACK: I need both of those for all of these 9' scenarios.
- 10. .MR. CUNNINGHAM: Yes, that's right. And then the 11 different11eak rates are associated-with differenc 12_ -combinations, if.you will, of the three stages of seal 13- failure.
14- DR. SHACK: 'Okay. But I do need those two things
() 15' .for all of the scenarios.
.16 MR. CUNNINGHAM: Yes. j 17 DR. APOSTOLAKIS: What kind of sequence are we 18 talking about, to have an idea of what space we're in?
.19 ' MR. CUNNINGHAM: We'll come back to that.
L20- DR. APOSTOLAKIS: In the imaginary time axis, what 21 'are the events.lthat are competing here? I'm losing coolant, 2 21 ~ and'what,are you trying to do to prevent --
, .23. MR. BUSLIK: You've lost cooling and possibly the 24- abilitycto mitigate it,;say, from a station blackout.
b 25 DR.-APOSTOLAKIS: Okay.
f"Y ANN RILEY & ASSOCIATES, LTD. !
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l' n 278 l
'l MR. BUSLIK: 'The competing-event would be the --
I .
- 2. inithe case ofLa' station blackout'-- would be to recover V[' ) ..
3~ electric power.
~4 IN1. APOSTOLAKIS: So, the key element here is we 5 have a competition in. time, like we do in fires, where the 6' bad. thing-is the loss of coolant --
7' MR. BUSLIK: ~ Right.
8 DR. APOSTOLAKISi -- and something terrible will
~
9- happen after a certain time, and the good thing is that you 10 Jare trying to recover power, and we have those curves that 11' have'been used in all the PRAs --
12 MR. CUNNINGHAM: Yes.
13 DR.'APOSTOLAKIS: -- the probability of recovery.
14 MR. CUNNINGHAM: Yes.
(3 g 15 .DR. APOSTOLAKIS: ,Right?
16 'MR. CUNNINGHAM: Right.
17 DR. APOSTOLAKIS: So, the question is now who wins 18 the' competition.
I
- 19. MR. BUSLIK: That's exactly right.
20 DR. APOSTOLAKIS: And what is the equation you use 21 'for that? What is;the probability that-I will recover power 22 .before I will:--
-23 MR. CUNNINGHAM: 'You're getting into the station 24 blackout analysis.
- 25. DR. APOSTOLAKIS: I don't see'any equations
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279 l
1 anywhere for it. lDo you have difficulty with software t
2 .there,.as well?
(} ,
'3 MR. BUSLIK: No, I can write equations.
i 4 DR. APOSTOLAKIS: Okay. Those diagrams, though, 1
5 really would'have helped a lot.
6 DR. WALLIS: At least if there was some sort of 7' summary that says, if you assume 182, this is the uncovery 8 time:and'here's the probability.
9 lMR . CUNNINGHAM: What we've done is basically 10 translated it to those conclusions in the context of the ,
t 11 frequency of core damage.
12 DR. WALLIS: I think we have to move on.
13 MR. CUNNINGHAM: Yes.
14 DR. WALLIS: I think these are important points
( 15 we've.been raising, but I think, from now on, we should be 16 able to get to the bottom line.
17 IMt. APOSTOLAKIS : There is a report, Art, that has 18; -all~these things?
11 9. MR. BUSLIK: There is something. It's in draft 20 form, and it will be out shortly.
21 DR. APOSTOLAKIS: But it will have diagrams and ;
i I
12 2 equations.
23 MR. BUSLIK: I will put' diagrams and equations in
~
24 it.
25 MR. CUNNINGHAM: What we'd like to do is go now to l
l I
l l
["')
\s./
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r:
280 1 -- as I said earlier, we've got -- all of this issue of pump
(~') 2 seal performance under these conditions has implications in
~ \._J 3 station blackout accidents and loss of component cooling 4 service water accidents.
5 In the interest of time, we're going to jump 6 through some of the slides.
7 DR. APOSTOLAKIS: In terms of presentation, I 8 would have started that way, from the end and worked 9 backwards.
10 MR. CUNNINGHAM: Okay.
11 DR. APOSTOLAKIS: Because it's really confusing, I 12 think, for someone who sees it for the first time and you l 13 get into the details of the 182 gpm versus the other, and 14 we're losing the big picture here.
() 15 16 MR ., CUNNINGHAM: Yes. We're back to the big picture here, or one of the big pictures, if you will, which 17 is the' implications to the implementation of the station 18 blackout rule.
1 19 DR. APOSTOLAKIS: Okay. !
l 20 MR. BUSLIK: So, the station blackout rule l 21 required that certain -- that each plant must be able to 22 cope for a specified time with a station blackout.
l 23 The time for each plant depended on, essentially, i 24 characteristics of the plant, which determined an estimate 25 of how likely it would be for a station blackout to occur, ANN RILEY & ASSOCIATES, LTD.
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c 281 1 and the intent of the station blackout rule was an industry
() 2' 3
average core danage frequency from station blackout of about le minus'S per year, on an industry average basis.
l l
4 Plants were either four-hour or.eight-hour plants.
5 That means that plants were required to cope with a station
-6 black out of four hours, some plants, and others, eight 7 hours.
8 DR. APOSTOLAKIS: So, you have to recover power, 9 in other words, within four hours.
10 MR. BUSLIK: They have to show, under certain 11 assumptions, that they're able to cope, some plants for four 12 hours, other plants for eight hours.
13 DR. APOSTOLAKIS: What I'm saying is that is 14 equivalent to say that you better recover power within four 15 hours, because beyond that, you can't cope.
l()
16 ~ -MR. BUSLIK: That's right. There's a residual 17 risk if they don't for a four-hour plant, and that's l
l 18 considered acceptable.
19 DR. WALLIS: So, if the core uncovers in
!- 20- two-and-a-half hours, you've lost these plants. You haven't 21- been able to do anything to mitigate this loss of coolant in 22- that time? Or have you?
23- MR. BUSLIK: There's a certain probability that 24 the -- first of all, the two-and-a-half hours corresponds to 25 a sensitivity study. The analyses for coping were supposed ANN RILEY_& ASSOCIATES, LTD.
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g- q ]
l j .:- ,
282 i-
'1 to be best estimate analyses. .This is actually --
2 DR. APOSTOLAKIS: Why was that, Art? I mean you i 3. are not the kind.of guy who would say something like that.
l~
4~ Were you asked.to do this best estimate?
?
5 MR.-BUSLIK: This has'to.do'with the rule.
- [6 - MR. CUNNINGHAM
- Coping using best estimate not 1.
l -7 traditional conservative regulatory analysis.
'8 -DR. WALLIS: I'm sort.of confused, because we get
- 9- this four-hour coping.and then we're told the core uncovers 10' in, you know, two-and-a-half, four, six hours, depending on
[ 11 . which flow rates you assume, and I'm sort of saying does l 12 this matter.
- 13 If it uncovers in two hours, does this mean this l-14 is a real loss of something, because you can't cope with I- 15 things in that perico of time?
.16. MR~ CUNNINGHAM:
. First it comes back to what's the
-17 probability of it occurring in two hours.
- 18 DR. WALLIS: If the flow rate is over something, 19 then you're in real trouble when you weren't before.
-20 MR. BUSLIK: No, because if-electric power is not 21 recovered for a four-hour' plant, it's not a question that, 22 .if you lose off-site power, it's never rer. overed within four 23 hours and it's always-recovered after four hours.
24'- DR. WALLIS: Ifsyou've lost the core before you
'25 ~ get the power back,.then you're in real trouble.
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p 283 1 MR. BUSLIK: That's considered the frequency.
2 'DR.-WALLIS: You may not have time to do it.
3: MR. CUNNINGHAM: That's where you come into the 4 probability arguments in the station blackout rule.
l 52 DR. WALLIS: If your flow rate can be big enough 15 to'get you in real trouble, then I think you worry about 7- -that,.'whatever you've done for probability, but if you can i
8 assure us that the. flow rate is low enough that you'll never 9 really get in trouble --
10 MR. CUNNINGHAM: That's one.way to cope with the 11 --
12 DR. WALLIS: -- then we'd be very reassured. But 13 these assessments are all very dependent on how much the 14 ' flow rate is.
() 15 DR. APOSTOLAKIS: But they also have, Graham, 16- curves -- and I guess the epistemic uncertainties there are 17 not large, because there is a large database -- that give us 18 the probability-of recovering power,.off-site power, as a 11 9 function of time.
20 MR. CUNNINGHAM: That's correct.
21 DR. APOSTOLAKISi So, it's not that for four hours
)
22' the probability of loss of power is one.
I ;
i 23. MR. CUNNINGHAM: Correct.
24' DR. APOSTOLAKIS: In fact, the mean value is 25 Lfairly low, as I remember -- :
i 1
l O ,
j j
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Y[
284 i
1 MR. CUNNINGHAM: Yes, e
2: DR..APOSTOLAKIS: -- on a nationwide average. A
'3 couple of hours?
4' MR.'CUNNINGHAM: ~I think that's right. There's a
- 5. 'long tail due toicertain types.of weather condicions and 6- ~ things.
- .7 .' DR . APOSTOLAKIS- But it is an essential part of 8 -the argument.
- 9. MR2 CUNNINGHAM: But another way to think about.it 10 .is:that you want.to maintain the probability of having core 11- uncovery in two hours at a sufficiently low level that it's 12; judged to be. acceptable. So, it's a probability of that 13 ' core uncovery time.
- 14. .MR. BUSLIK: Frequency.
15 MR. CUNNINGHAM: Frequency. I'm sorry.
16 DR. WALLIS: -We keep asking questions. We have to
- 17. iget on. I notice you've got a lot of detail on these 18 slides, and if someone can somehow distill from this what we 1 19 really have to worry about, then we'll finish on time.
l 20 MR. BUSLIK: On 14, you will see a table which 21- indicates how.the. core damage frequency varied for the
' 2 2- eight-hour plants,-the plants which were required to cope l 23 for eight hours,~and you.see basically what their core 24? damage frequencies were, and for the best estimate case or
!. 25.. slightly conservative best-estimate case of four hours for
-7 ANN RILEY & ASSOCIATES, LTD. 1 Court Reporters 1025. Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
.L.-.
g 285 1 core uncovery and for two-and-a-half' hours.
1 2' MR. SIEBER: 'Before you leave that, that's just 3 for station blackout, but there's other initiators besides 4 station blackout?
15- ,
MR..BUSLIK: That's.right. That was the second a 6 part.
n7 MR. SIEBER: So, you could almost say that this is 8 like two orders of magnitude.higherLconsidering all 9 initiating events, which would make it a dominant
'lio contributor tot the' total. risk for the plant?
11 1 MR.'BUSLIK: I don't understand the point.
12 MR. SIEBER: Well, you know, for example, three
.13' weeks ago, there was a loss of an emergency bus to the plant )
14 -that lost safety injection flow and component cooling water
~
- 15 . flow to two pump seals, which did not fail.
-16 MR. BUSLIK: This was Beaver Valley?
17' MR. JACKSON: Beaver Valley, yes.
18 MR. SIEBER: The probability of that happening is
-19 much greater.than the station. blackout, and so, the number 20 you have as~FSWLSP, which is your frequency of severe I
-21! - weather,'which is a factor of probability in this whole
- 22; thing,.is twoLorders of magnitude.
23 MR. BUSLIK: But the point is, in the other cases,
[ 24 you may have had degraded ESSC, but you did have ESSC. Even 25 if.you had a LOCA, you would have been able to mitigate it,
'f/~'\'
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o l.
L.
i 286 1- 'and.also,1there's a question of recovery of those incidents.
.2' .It was recovered'within'three minutes.
3 MR; SIEBER: . Yeah. Two' minutes and 45. But if
'4o you look at the.IPE for that plant,uit is a high contributor 15 to CDF.
6~ MR. BUSLIK: Yes 7 MR' SIEBER:
. Okay, 8 MR.LBUSLIK: .That I treated, as a matter of fact,
!F for that' plant, a'lthough I'm not going to give those 11 0-. specific results, but I did look~at that for Beaver Valley 11 unitLone. This event occurred at unit two, but I think the 11 2 -bus configuration.is pretty similar. But I treated that as 13 -. ~a loss of component cooling water, ESW. It's not station 14 blackout, at any rate.
() 15 So, plants which are required to cope with a 11 6- 'four-hour station blackout can'still cope with a four-hour
'17 l station blackout, because core uncovery times are longer, 18 .using best' estimate values.
19' DR. WALLIS: -But if you use the 500 gpm, what does 20 that do.to you?
2l1 MR. BUSLIK: It's not a best estimate value. You n22 .would uncover in less than four hours.
123 DR. APOSTOLAKIS: Why not-do an uncertainty l l
24 calculation? The~ rule doesn't say that, right? The rule is i
I L 125 from' conservative to best estimate. I i
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y 287 l 1 MR. BUSLIK: I~did a sensitivity calculation, and
[ .
j }
2'
~
.y ou'll see that it doesn't matter that much, if you look at l .3 .the-table for the eight-hour plant.
4 MR.-CUNNINGHAM: The question that we had put
. .Sc before us, that we had to answer in a fairly short amount of
'6 . time, was have we compromised the ground rules, if you will, 7 the station blackout rule, by this set of assumptions, and 8 .we didn't try to go back.and, if you will, do something more i 9 elaborate.
10 We - said have' we . done it, and I think the answer is 11 this does not compromise our situation on the blackout rule.
12- :That's'the kind of bottom line.
i 13 MR. BUSLIK: .That's the basic argument, and the l
14 risk is -- yeah, that's right. You still have an industry C\
( j 15 average.one times 10 to the minus five per year.
16 The os . ~ kinds of ways of losing seal coo)d.ng is
- 17. loss of' component cooling water and essential service water, l
18' and' seal cooling is supplied, as-you've seen, by seal l 19- injection'and component cooling water to a thermal barrier 20- 'in many plants,. basically the B&W plants and the 21 Westinghouse plants and Palo Verde.
! 22 The other Combustion Engineering plants don't have 23 seal injection.
24 The classic sequence :'u n one in which, say, l
25
~
. component cooling water is lost, and'therefore, then, you
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- i l
288 j 1
1 may have. seal injection, but the HPI and charging pumps are l i
'2 dependent on component cooling water for seal and pump motor I
[}
3 cooling.
4- You lost the charging pumps and you lose the --
5 and.you've lost the component cooling water, so you get a i
6 seal LOCA with some probability, and also, you can't 7 mitigate'it, because the HPI pumps are failed.
8 DR. WALLIS: So, this is a bad story but it's very
- 9. unlikely?-
10 MR. BUSLIK: You have to figure out'how unlikely
'11 it'is.
12 DR. WALLIS: Okay.
13 MR. BUSLIK: And then there are pumps without 14 reactor coolant pump seal injection, and here.you lose
'[
~
'15 component cooling water and you'get a seal LOCA, and if the 16 'HPI' depends on component cooling water, you can't mitigate 17 -it.
18' But there are lots and lots of different variants 191 between plants. ;
)
20 DR. WALLIS: Component cooling water -- is this
< 2 11 one of those safety significant systems?
22 MR. BUSLIK: Yes. It's safety-related. Don't ask
-23' me.what safety-related and important to safety mean, because i 24 I don't remember.
'25, MR. CUNNINGHAM: Yes, it's important.
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h b
E 289 MR.-BUSLIK: .So,. the charging pumps may not
~
1 l E2 require' cooling. They can.be air-cooled, or they could'be l [G~'Y
\
13~ . cooled-.by ESW instead of component cooling water. Then loss
- 4. of component cooling water isn't of concern, but ESW, which 5 is the heat-sink for component cooling water -- if you lose i-D 6 that, you may have a. problem.
7 [You may have'a back-up-cooling system for the
~
- 8. charging pumps. Some plants have installed that -- Turkey 9 Point, units three and four, H.B. Robinson, Three Mile 10 Island unit one.
.11 You can mitigate a small break'LOCA without HPI by
.12 cooling down and de-pressurizing'using the steam generators 13 .and using the low-pressure' injection systems.
14 Now, it turns out the low-pressure injection j 15
) system -- I believe the bearings there don't require 16 . cooling, it's only the seals, but if you're. pumping cold 17 water, you don't need to.have cooling to the seals. So, 18 .what they do-is have a way of refilling the refueling water
- 19 ' storage tank and continuing to pump cool water.
20- There are other types of designs. The i
21 Westinghouse reactor coolant ~ pumps, if they use the new )
22 0-rings instead of-the'old, you' decrease the probability. !
2' 3 ' It depends,-- the importance will' depend on the frequency i l
24 for losses of component cooling water, losses of ESW, which )
. depend.on the design of those systems.
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'1L We looked quanti.atively at 14 units, and nine of p
(~)
%)
12- these. units, the core. damage frequency.was.below le minus 4.
3 'The highest one wasfl.4e minus 3 per year. This is a
'4 preliminary screening' estimate. We have to look at it l '5-. -further.
6- - It wasn't a random' sample of units. I'had a'IPE l 7- databaseEwhich gives me frequencies of losses of component 8 ' cooling water,~and'I tried to pick ones which were high.
'9- DR. APOSTOLAKIS: This is what confuses me, Art.
.10 'MR. BUSLIK: Yes.
11 DR. APOSTOLAKIS: The-rule, as you said earlier, 12- speaks in terms of averages.
'13 MR. BUSLIK: The intent of-it. That was for 14: station 4 blackout.
[15 MR. CUNNINGHAM: Station blackout.
16 DR. APOSTOLAKIS: Oh,-this rule'is different?
17- MR. BUSLIK: This is a generic issue.
18l DR. APOSTOLAKIS: So, we're not going by the 19 ~ average here?
20 MR. CUNNINGHAM: No, we're not. Here the issue is 21 we have a generic issue 23 on reactor coolant pump seals. !
22: Is'it generic? Is there a' generic solution to this problem?
23! And theLanswer --'what Art-has been doing is'saying is there 24 ;anything: generic about this, and we come back to it and we
--25L see J great dependencies.on plant-specific features.
i l
I
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291 1 1 So, you can have a very low core damage frequency
/ 2 coming from these, you can have a higher core damage
~ N))
3 frequency coming on, depending on a series of plant-specific 4 . issues, and the bottom line, to get to it, is we need to 5 follow:up on them plant-specifically, not generically.
- 6. MR. BUSLIK: Obviously, you could have a generic 7 'fix, but-it wouldn't satisfy the cost-benefit criteria.
8 MR. CUNNINGHAM: That was in our proposed rule.
9 DR. WALLIS: You're not saying it's not a safety 10 ' issue. It still seems to remain a safety issue. You're
~11 really concentrating on the word " generic."
12 MR. CUNNINGHAM: Yes.
13 MR. BUSLIK: That's exactly right. For some 14 plants, it may matter; we have to look more closely.
() 15- DR. APOSTOLAKIS: This 1.4 (10) to the minus 3, 16 even if you sharpen your pencil, how low can it go?
2L7 ' MR. BUSLIK: Oh, it can go low.
18 DR..APOSTOLAKIS: Lower than 10 to the minus 5?
19- MR. BUSLIK: I had a 20-percent probability of 20 . pop-open' . If that probability of pop-open became 1 times 10 21 .to the minus 3, it could go lower.
22 MR. CUNNINGHAM: The key piece here is that you're 23- applying the Westinghouse model to non-Westinghouse pumps.
24 That's a key piece, ar.d that's why there's a big range in 25 -these. things, and.that's why we're not willing to say that
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l 292 1 that's a real number, if you will.
2 2 DR.~APOSTOLAKIS: I'm a little bit confused how
- 3 the calculation was done.. The 20' percent was epistemic.
4 The 10 to the minus 3 is aleatory. So, how would that 5 .changeLchiange that?
6 MR. BUSLIK: I mean if I try to take in the 7 uncertainty range, it becomes a big number. The upper range 8 becomes big.
9 DR. APOSTOLAKIS: But in terms of point estimates 10 that you are doing'now, I:do not see how the .2 enters into 11' the calculation.
12 MR. BUSLIK: Because I use mean values when I do 13 --
I average over the epistemic uncertainty. The 20 percent is the mean value of a distribution.
~
14
() 15- DR. APOSTOLAKIS: Of an epistemic distribution.
16 -That issue arose many, many years ago, and the NRC had a 27 workshop.
18 'How do you combine the epistemic uncertainties in 19 level two with the aleatory uncertainties in level one, 20 because in level two, the event trees go yes, no, yes, no, 21 ~ yes, no. In level one, there is a fraction of time you go 22- this way, a fraction you go that way. We have the same 23 problem here.
24 Those things will be in the report you are about 25 to publish?
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.1 MR. BUSLIK: No. If I did something like that, I I/~) 2l may come'up with essentially!a number for the 1.4 times 10 b -3 to the'minus-3 plant --'first of all, it has to be looked 4 .at. Maybe there are' problems with the way the initiating 5 event was treated.
~
6 'But.if I did nothing but do'an epistemic.
7 -uncertainty and I said it's aither zero or one, or 8 essentially that, it could go up to 70 minus -- I'd have two 9 estimates, 70 minus 3 per year and zero, essentially, not 10 zero but.a small number, and what that would'say is that you Ell have to reduce the uncertainties, which we know already i 12 actually, before we could~go ahead, i
13: MR. CUNNINGHAM: A key piece of this is we're 14 making'the assumption.-- to get to the 1.4e minus 3 -- that
() '15~ 'a-Westinghouse seal.model or a variation on the Westinghouse 16 seal model, a Rhodes seal model, applies to a 17 non-Westinghouse design pump.
- 18. One of the things we're trying to do is get better 19 information on whether -- what is an appropriate model for a 20 non-Westinghouse pump.
21 We've had some conversations with EPRI and with 22 .some others to try and see if we.can come up with a better 23 model for-those pumps to reduce that uncertainty, if you 24' wil!L.
'25 DR. SHACK: 'But you have the same problem with the
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7 294 1 Weisringheuse plants, where if-you really did it as a zero, '
l
{
t2
~ one, rather thanftaking.;the mean of .2, you would end up s
3' -throwing everybody,.I would assume,.at the one.
4 !;MR. BUSLIK: 'Yes, that's true. It turns out that
- 5. Westinghouse pumps, because they use a model -- many IPEs 6 use the model more.similar to our model'. If they came up 7 with a high value, they did something about it.
8 DR. SHACK: But'they came up with.that'value by 9' plugging in
.2.
10 MR. BUSLIK:' That's right.
11 . DR. SHACK: And the question is whether that's a
~
12 legitimate procedure.
'13- DR. WALLIS: Maybe the number-you plug in is-14 itself aleatoric.
l r
( 15' Can we sum'up here? I'think the key thing is 16 whether you really know enough to close this issue, whether p 1 71- 'your. strategy is something the committee is going to 18 ' support.
19- MR. CUNNINGHAM: Maybe.we can go to 22. In the
'20_ context'of th'e emergency service. water and CCW issues, we've 21 got a. couple of pieces of future work, which are basically y 22 we want to.go back and look at these in more detail to try 1
23 and come'up with something better than what we think is 24 'somewhat of a bounding estimate on core damage frequency 25- associated with these,'and they are very plant-specific Tj '
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- 1. issues. That's what our concern is. So, we're going to do
'2 the' future work.
3 'I guess, Jerry, there's one more slide, the
-4 summary slide, the conc]usion slide, related to 23 itself.
5 MR. JACKSON: I guess our conclusion, then, that 6 we're trying to make -- I'll give you the basis for our i
7 ' conclusion, was'we'll think back to the Commission's SRM.
8 We proponed a generic solution to the probleu, and the j
'9 Commission ruled against that generic resolution, and they 10 pointed out that they believed there was insufficient basis 11 for gains in safety and that it wasn't a generic problem, 12 and I think if you 1cok through this analysis by Art, 13 etcetera, it points out that it is truly a plant-specific issue, and the Commission also had concerns with our seal L( ) 15 . evaluation model, and they pointed out, as well, that the 16 industry was addressing many-of our concerns by changes in ,
L 17 the IPE program, and if we look at changes that have !
i 18 actually.been made in the plants, the station blackout rule j 19 has reduced the likelihood of seal LOCAs by the addition of 20 alternate power sources, for one thing, and the IPEs have l
l 21- resulted in specific changes to this particular problem in ;
i 22 'the, plants, like reducing the dependencies on cooling in l
23 .certain instances.
24- The. maintenance rule itself has reduced the 25 likelihood of a component cooling water, service water ANN RILEY & ASSOCIATES, LTD.
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296 I j
l' system failure,. which affects this seal failure probability, 2 and then, as we talked about earlier, the normal operation V[~'\ .
3 . failures have improved.
4 .There have been none of the large leak rates, 5 since even'1980 was the last time we had one that'anywhere 6 'near_ approached the makeup capability, and to sum up our
- 7. plant-specific analysis that Art has done, I think we've 8' shown>that the station blackout -- when you look at the 9 station blackout plants' applying our conservative model, 10- that we sti13 meet --
the intent of the station blackout 11 rule is still met, and for.the loss of component cooling 12 water and service water, when you apply this model to the 13 plants that we've looked at -- and Art looked at 39 of the 14 74 and only found five. plants that were screened out with 15- the higher values.
16 So, we believe that that shows that the majority 17 of the plants have a low risk associated with this seal 18 failure.
19 So, to summarize, the staff concludes that closure 20 of generic issue 23 is appropriate and would like to request 21- your agreement'on closing this issue, i
22 DR. WALLIS: Do we'have anymore questions from the 23 Lcommittee?
24' [No response.]
]
.25- DR. WALLIS: We have a presentation from industry?
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297 )
1 Thank you very much. j
/~'\ 12 MR. LOUNSBURY: Good morning.
,b 3 :My name is Dave'Lounsbury. I work for PSE&G 4 Nuclear, Salem Station, and I'm here to discuss the WOG 5 position.
i 6 What I'd like to do in this package that we sent 7 _out, slide' number two, three, and four is just there just to 1
8 give you some sort of indication what the WOG involvement 9 has been.
10 I'm not intending to discuss each one of these 11 items'. It's just there for a visual, so you can understand 12 how much work has'.gone on.
i<
13 .Here again this just all the work that we've done 14 within the Westinghouse Owners Group and Westinghouse to
() 15 resolve this.
16 Part of our conclusions is the WOG supports the 17 closure of GSI-23. .There's conservative analysis that has 18 . determined approximately 21 gpm per pump, RCP leak rates at 119 fullipressure and temperature.
- 20. DR. WALLIS: So, you're saying 21 gpm, and you l
21 heard numbers of several hundred earlier on.
{
! 22 MR. LOUNSBURY: We'll get to that. l l
23 DR. WALLIS: Okay. !
24 MR '. LOUNSBURi; Emergency procedures are in place j 25~ 'to' cool _down and de-preopre.q s the.RCS, further reducing the l 1
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298 1 expected leak rate. I'd like to stop.right here and discuss 2 'that.
3' Part of the discussion that I heard was the 2.5 4' ' hours for uncovery of the core and the 300 gpm.
5 Westinghouse emergency operating procedures -- that's ECA-00
~
6' -- for station blackout events -- I'm only telling you this 7 so you'll have an understanding of what the operators are 8 actually going to do in these events -- they have directions 9- to cool down and de-pressurize the plant using the steam
- 10. . generators, and that de-pressurization occurs at maximum 11 rate.
c2 1 MR. BARTON: And that depends on whether they 13 recognize the alarm and' respond in a timely manner, which 14 they didn't do at Beaver Valley. Luckily they got flow back
() 15 16 in two minutes'and 45 seconds, but they didn't do what they are supposed to do, which was shut down.
17 MR. LOUNSBURY: I agree, but for the station 18 blackout, I think the operators would be pretty much aware 19' they.didn't have any AC available. It's a different 20 scenario. But the point being is that the RCS would be
- 21. de-pressurized in some amount of time, would cool down in 22 some amount of time, and would significantly reduce the 300 23_ gpm.
24 Additionally, the loss of seal cooling is a safety 25 concern only when no RCS makeup capability exists for an "N ANN RILEY & ASSOCIATES, LTD.
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- 1 -- extended time -- i.e.,-coping times, i :
<[
< d' L2! Testing and actual' experience support the above
'3 statements.
'4 DR.LWALLIS: Could you say something about that?
F Your testing supports this 21-gpm number?
., 6 MR. TIMMONS: My name is Tom'Timmons from 7 Westinghouse.
8 Westinghouse, in conjunction with Electricity de 9 France _and-Framitome, performed.a test in France in 1985 on 111 a full-scale, seven-inch reactor coolant pump seal.
11 The steady-state leakage in that test was -
12 approximately 14 gallons per minute, so_that we.believe, 13' based on that. test, which confirmed the best estimate 14 : leakage estimate of 21 gpm --
( 15. DR. WALLIS: This'is one' test. Did you fail-the 16 seals in the way that.was presented to us by the staff?
- 17. MR. TIMMONS: No, we did not.
18' DR. WALLIS: So, you were looking at a particular 19 scenario where there's a small leak.
20 MR. TIMMONS: We were looking at loss of all seal
- 21. cooling and see'how the entire seal package behaved during 22_ that test.-
L 23 DR. WALLIS: You had one' data point?
24 MR. TIMMONS: That's correct.
25- MR. BARTON: Has there been any actual similar i
1 Q 'E h/
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' events at operating reactors;in this country, where you've 1
2 : lost cooling and you had seal failure?- What was the i_ '3' leak-off rate? Because there have been seal failures, 4 right, due to loss ~of cooling?
5'
- MR . TIMMONS: There have'been seal failures due to 6 loss of cooling but'not seal failures due to complete loss 7' 'of cooling for an-extended period of time.
8 The only other data point was during a production 9 test of at full-scale _ reactor' coolant pump in which they were 10 running a test of loss of seal injection and they lost power 11 at the facility, resulting in a loss of component cooling
~
12- w a t e r..
13 So,.there was a loss of all seal cooling to a 14' full-scale _ pump in a test loop, and the maximum leakage in
( 15 that case was about113 1/2 gallons per minute. However, at 16 .about the time that the maximum leakage was occurring, 17 component cooling water was restored when they restored 18 electrical power, and so, that tended to turn the transient 19 around.
20' DR. WALLIS: This-182 gallon per minute, whatever 21' it is, came from Westinghouse.
22 MR. TIMMONS: That's correct.
23 DR'. WALLIS: Hypothesizing some other scenario.
2 '4 - MR. TIMMONS: Yes. !
25 DR. WALLIS: So, why is this conservative?
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'l MR. TIMMONS: The 182 gallons per minute is a
/~'\ 2 thermal hydraulic calculation based on a model of how the V
3 seal parts react and a model of the seal parts and the seal 4 leak-off systems, and it assumes that the number one seal 5 operates as designed and that the number two and number 6 three seals don't.
7 DR. WALLIS: You say conservative is 21, yet you 8 have a model which predicts 182. So, for some reason you've 9 discounted the 182 if you say this is conservative.
10 I don't quite understand. And the staff uses a 11 conservative of 300. I don't understand what is meant by 12 conservative in this context.
13 MR. TIMMONS: Twenty-one gpm was, again, from the 14 WCAP-10541, assuming that you didn't have a number two seal rN i
b) 15 failure or a number three seal failure. The test data that 16 we -- that was done by EDF showed it was 16 gpm. So, it's 17 less than the 21 that was predicted in the model.
18 DR. WALLIS: You did one test, and you didn't get 19 the failure which would have led to 182.
j 20 MR. TIMMONS: Correct.
21 DR. WALLIS: It doesn't mean to say 182 will never l 22 happen.
23 MR. TIMMONS: It's a probability.
I I 24 DR. WALLIS: So, what do you mean by conservative?
)
25 Maybe we should move on.
1
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~X~ ; 302 ;
l I E 1- MR. TIMMONS: Yes.
l..
2: 'MR. LOUNSBURY: The risk associated with the RCP 3 l seal failures is not significant'from the CDF. Installation of high-temperature 0-rings would provide a-long-term.
-l4 -
5 passive solution.
~
6 MR. BOEHNERT: Have all'the. pumps -- all the 7 plants put in those high-temperature O-ring seals?
8 MR. LOUNSBURY: -No.
9 MR..BOEHNERT: Are they going.to?
10- MR.-LOUNSBURY: I don't know.
11 DR. WALLIS: .This is something.that came up in the i
12- subcommittee meeting. There seemed to be this uncertainty- f 13 of this wonderful material which works so well but it hasn't 14 been put in.
() 15 DR. SEALE: We don't know.
- L16 .DR. WALLIS
- We don't know if it's.being put in.
17 That seems strange that you don't know.
18 DR. SHACK: Is this a case that the seals continue 19 to operate-and they just haven't been replaced or is it a 20/ . case they've been replaced with the old material?
L 21 MR. LOUNSBURY: My understanding -- and I can't
.'22 speak-for all the utilities, but there has been some '
23 position by utilities that they choose not to incur the
- 24' additional' costs'of putting high-temperature O-rings until o . . i l
L 25 GSI-'23 is closed. I L i l
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i-303 l' MR. BARTON: -What's the logic behind that?
s N '2 MR. LOUNSBURY: Like I.said, some utilities have
,Q .
3 taken that position. I. don't know:what their justification l
g 4 'is.
=5: DR. SEALE': Gh, boy.
6 DR.:WALLIS: If we close this issue, does it mean 7 .that they will or'will not put these materials in?
8 MR. LOUNSBURY: .I can't speak far each utility.
9 MR. BARTON: For safety's sake, we better hurry up 10 and close it.
11' [ Laughter.']
L12 MR. BOEHNERT: Do you know how many plants have 13 .put in the new material?
14 MR. LOUNSBURY: Yes. Seventy-five percent of the Westinghouse fleet of pumps have installed high-temperature 16 0-rings.
17 However,.th'e WOG believes the NRC model 18 assumptions.are overly conservative, specifically the 19 L20-percent probability of the seal popping open, which leads 20 to your 182 gpm, and the.50-percent probability.of the l 21 number one seal'O-ring failure if the number two seal pops 22l :open. The WCAP-11550 predicts a lower probability.
23 ' DR. WALLIS: The staff '.ndicated it-was 1 or 2
- i. 24 percent o'r something like-that
-25. MR. LOUNSBURY: .It's a single-digit. number.
l, t-p, ,
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304
! 1- .. Int. WALLIS: Does it predict or guess?
E t-g- ]) 2 MR. LOUNSBURY: 'IsLit' a prediction or a guess? I
-3' don't know.
T'4 MR.'TIMMONS: It's an assumption.
L 5 '- DR. WALLIS: That-doesn't give ma warm feeling.
6 'MR.1TIMMONS: That particular behavior-has been 7J postulatedLby the -- a c'onsultant to the NRC based on his 8 professional opinion. It has never been observed in a l
9 . plant','never been observed in a test.
i 10 'MR. LOUNSBURY: To. continue on, the operating L .11 experience and test data do not show a high probability of l 12 .. excessive leak rates for loss of seal cooling events.
! The.NRC assumptions are based on non-prototypical 14 ; testing, and use.of these' assumptions may lead to
! p-l ( ,/ 15 'unnecessant expenditures for plant modifications and 116 analysis.
L 17 DR. WALLIS: What testing are you referring to?
18 MR..TIMMONS: It's our understanding that the NRC 19L consultant postulated that the seals would pop open based on 20 some tests:that he did using non-prototypical-size parts and 21 using hydrauliciactuators to move the seal parts to the 22 point where they would fail.
23 DR. WALLIS: You'rt. referring to E-Tech?
s 1 24 MR.-TIMMONS: .I'm referring to AECL.
25 , DR. WALLIS: Oh, Rhodes?
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o 3 305 ,
H .1 MR. TIMMONS: Rhodes?
2 DR. WALLIS: But~he didn't do any testing. He 3 just did. guess probabilities.
4 MR. TIMMONS: Well, the AECL laboratories were i
- 5- involved in testing.
6 'MR. JACKSON: We had a test program at AECL. It 17 .was a scale-model-type test to demonstrate whether there was B feasibility of hydraulic instability. I think that's what i- 1 9 he's referring to.
L-
'10 DR. WALLIS: And it did show it?
i 11 MR., JACKSON: That's right, it did. It showed l
l - 12 what conditions it would occur under. It doesn't occur 13 under all conditions, but that was the purpose of the tests, l l !
i
- 14 were to map'the conditions under which it would occur, and l 'O t
-Q 15 they also did analysis of this phenomenon.
l 16 MR. LOUNSBURY: The WOG position is contained in 17 WCAP-11550, which presents the Westinghouse RCP seal LOCA 18 model, and in the correspondence with the NRC on proposed
[ 19 closure of GSI-23.
20 Fundamentally, our biggest argument or concern --
21 and this has been going on -- is the 20-percent probability 22' of the seal popping open. The WOG disagrees with that
'23 ' number and with the 50-percent probability of the number one D 24 seal failing if number two.ceal pops open.
25 .DR. WALLIS: How will we decide? I mean the staff
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r; ,
306 1- seems to have a 20-percent, which doesn't have all that much
( (2' 'of.a basis, and you have some other number which is much
'Ns 3/ lower which doesn't.have much of a basis. What should be 4 the basis of our judgement on this?
5 DR. SHACK: You'said you mapped out the conditions 6 .under which this'could occur.
7 r ', what exactly does that mean?
8 MR. JACKSON: That means the approach angle that 9 the seal must have. It means that -- the degree of 10 :sub-cooling in the conditions, of the approach to this seal.
11 It'shows at what.back pressure this would occur, behind this l'2 seal.
13 So, if you take.-- these are all conditions that 14 wouldiaffect the seal in actual operation, and so, you look i
() 515 'at the-conditions that would be expected in a real seal.
'16 'For instance, if the back pressure behind number I 17 one seal were to be very low, failure of the second stage 18 seal,.for instance, then you could have popping open 19' . occurring.
'20 . .DR. SHACK: Okay. So, under these conditions, the 21- probability is one.
22< So, the real question, then, is what is the 23 probability of these conditions occurring?
24 MR. JACKSON: That's correct..
.25' DR. SHACK: And the' face angles we're talking i l'
\
l
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l 1 1about are consistent with the design?
I 2 MR. JACKSON:
{ ) Right. We look at the face angles l E3 that occurred in the: Westinghouse seal, and the. conditions 4 -- these change with the thermal conditions, because i-j 5- normally the' seal is cool, so you're talking about what the 6 seal will -- what will happen to the seal under loss of I
l 7 cooling conditions.
8 MR. LOUNSBURY: In answer to your question, the 9 20-percent probability and the difference between what we
.10 say in the contextiof the Westingh'ouse model -- they're 11 using the results partially from our test data that we did 12 and the work that was done with Westinghouse vice the test l
13- data that was -- I don't even know if they actually had a l
14- ; full-scale model but that they did with the NRC.
() .15 DR. WALLIS: We didn't have the benefit of your 16 comments at the subcommittee meeting.. So, this is a?.1 new 17- to me.
I 18- Are there any other questions?
19 [No response ]
20~ DR. WALLIS: Thank you very much. i
)
21 I'll hand this back to you, Mr. Chairman.
22 DR. . POWERS: I will recess us, then, until 10:30.
23- [ Recess.)
24 DR. POWERS: Let's come back into session.
25 We're going to. progress now on to one of the O ANN RILEY & ASSOCIATES, LTD.
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- 1 topics lthat's becoming a perennial favorite, status of the L-J 2 proposed final amendment to 10 CFR 50.55(a), codes and
~3 standards 4 ;Dr. Shack, will you lead us through this effort? l
- _ 5' DR. SHACK
- . Okay. We're going to hear an update l-
- 6. ltoday~on the status of this. In particular, the part of the 7 amendment'related to the elimination of the requirement for 8 . licensees to update their in-service inspection and 9- in-service testing programs every 120 months and the 10 question of an. addition of a requirement to perform
-11 volumetric inspections of these small-bore high-pressure 12 safety injection lines. ;
13 We'll hear from the staff, and then I believe NEI 14 has requested an opportunity to comment on our letter
.() 15 related.to the elimination of the'120-month update I
16 requirement, and Mr. Scarborough, as usual, will be leading 17 us through the.show.
'18 MR. SCARBOROUGH: Thank you. Good morning.
19 My name is Tom Scarborough. I'm with the Division 20 of Engineering of NRR.
. 21 - With me is Matt Mitchell, also with the Division 22' of Engineering, and we'd like to go over briefly the status 23' of our two activities that we told you we would respond and 24 come back to you witn.
- 15 One is the 120-month update issue for in-service ANN RILEY & ASSOCIATES, LTD.
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L 14 inspection and in-serviceLtesting program, and the.other is 2 the-high-pressure' safety injection, class one piping weld
! /')b .
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3 examinations.
4 Just to give you a little background of where we 5 are since we last talked to you, in December, as you 6' remember, of '.97, we publ'ished a proposed rule to
~
' '7 incorporate by reference the '95 edition with the '96 8 addenda of the ASME boiler and pressure vessel code and'the i
9 ASME code for operation and maintenance of nuclear power 10 plants, with certain limitations and modifications.
11 Then, in April of this year, we issued a L
l 12 supplement.to that proposed rule where we indicated a 13 'possible replacement of the requirement for licensees to l
14- . update their ISI'and IST programs every 120 months with a I 15 voluntary updating provision, and in May of this year, we l
16 -had'a public workshop'where we had participants from the i
i 17 staff, the Nuclear Energy Institute, ASME, several nuclear I 18 utilities, and private citizens to talk about the update l
! 19 requirement and the need for it.
20' Then, in June of this year, we received further
, i L 21' direction from the Commission in terms of go ahead and
]
- 22 finish the incorporation by reference of the '95 edition of j 23 the ASME code into the regulations and to defer the l 24 120-month update issue until the next rule-making, and we 2$1 'followed 'that direction, on September 22nd, the final rule l
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310 1 was published in the. Federal Register, which incorporates by j '2, . reference the '95 edition of the code,'and in that rule,
[~"/
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3 that's where we brought up the point that we would defer the at issue on the HPSI-class one piping weld examination while we
- 5 evaluate.an industry initiative.
.6 MR. BARTON: What's the status of the 120-month 7 update'now?
8- MR. SCARBOROUGH: We deferred it from -- well, we
-9 separated it from the '95'--
10 MR. BARTON: --
'96 addenda.
11 MR. SCARBOROUGH: Okay? And now what we're doing 12 is what we're going to talk about right now, where we are 13 with that status.
14 MR. BARTON: Okay.
15 MR. SCARBOROUGH: Okay.
.(A) 16 So, we issued in April of this year a proposed 17 rule discussing the 120-month update. The public comment
' 18 - period ended on June 28th, and we received about 34 comment
- 19. letters.from members of the public, and we've been reviewing
_ j 20 Lthose comment letters and working up responses to them and
.21 categorizing them.
-221 As we began drafting a Commission paper to discuss 23 this issue before the Commission provided recommendations, !
l 24- we found.that there was widely varying views, both external 7 l 25 and internal, regarding the need for the mandatory updating l
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] ~2 So currently we're considering various options.
3 We've' currently worked our way up to four options, and we're
- 4 looking at those to see if there's any other options to try 5 to resolve this issue.
6 But we haven't reached _a decision yet as to which 7 .partic'ular option.and recommendation that we might put 8- . forward to the' Commission in'the Commission paper.
9 So, the next step of where we're going is we're 10 preparingthisCommissibnpaper,we'regettingcommentsback fil- from the internal stakeholders. We've pulled together the 12 comments, public comments.
13; Those_have been addressed and responded to in 14 terms of developing positions regarding.them, but now we're
() 15-
~
bringing in_all the internal stakeholders and their 16 '- positions and developing a -- working toward a consensus 17 document so that we can provide options and recommendations-
'18 to the Commission.
19_ We plan to come'back and brief you again in 20 December, at your December meeting, and we have a 21 subcommittee meeting that we're arranging, as_well, and we 22 intend to have a draft Commission paper for you at that 2 3'. time.
24 Currently, ourischedule is to complete the 25 Commission paper byl January'10th, year 2000, and following ANN RILEY & ASSOCIATES, LTD.
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312 t 1 that, following direction from the Commission, then we would t
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proceed with a final rule-making, in accordance with the 3 direction from the Commission.
4 That's where we are.
5 DR. POWERS: Do we have a good understanding of 6 the positions, those advocating retaining and those 7 advocating eliminating the 120-month update requirement?
8 MR. SCARBOROUGH: I think for the public comments, 9 I think we do.
10 I think we've gone through those pretty carefully 11 and we have a pretty good feel. Both sides make strong 12 arguments for their case, for their position, which side 13 they would lean to, but currently we're pulling in internal 14 stakeholders, as well.
-~,
(J
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15 There's a lot of comments and views out there that 16 we haven't been able to pull in yet and factor into the mix 17 of preparing a Commission paper.
18 DR. POWERS: Can you give me a thumbnail sketch of 19 the arguments that those that want to retain the 120-month 20 update requirement advance?
21 MR. SCARBOROUGH: In the sense of, for example, 22 the cumulative increase in improvements in the ISI and IST 23 techniques over time that would be -- that you might not see j l
24 by an individual change but might grow over time, I think l I
25 thap'spartofwhat -- one of the fundamental reasons that l l
l l !
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m 7 313 1- .they feel that it would be a good idea to continue the
() -2 3'
1 mandatory 10-year update.
comments.
That's an example of one of their I
l 1
4 The HPSI. issue, to give you a little background on 5 that, in-the proposed rule that was issued in December of 6- '9, there was a proposed back-fit that would have required 7 licansees to supplement their surface examinations of HPSI 8 class one piping welds in-pressurized water reactor plants, 9 PWRs, specified in the ASME code, was ultrasonic 10 examinations, and as we started working through the public
- 11. comments on that and coming up with a final rule, it was 12- determined that, with an industry initiative that was 13 working its way through at this time, that we would defer
,14 action _and -- on this' issue and continue to work with the D) g 15 industry on it in the rule that we put out in September.
16 We did some preliminary risk studies that showed 17 there was-a nominal effect from not. conducting the 18 ultrasonic examinations or the surface examinations that 19- were mandated by the code.
20 So, in the final rule that went out in September, 21 we endorsed but did not mandate the code provisions on 22 surface examinations of HPSI class one piping welds, and we 23' also' discussed in there.that there was an ongoing dialogue 24- of what was the appropriate examination for these particular 25 welds and.that that would be dealc with in the next 1
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'l rule-making.
I 'l 2- So, that'e-where we left it in September, the
- v -
3L September rule.
4 On August 20th of this year, the staff had another 5 ~ meeting -- we've'hadiseveral meetings with NEI and industry 6 . representatives -- on the HPSI class one piping weld 7 specifically and whether there was a need for interim action 1
8 on this issue while the industry initiative was underway.
9 There's a major industry initiative on thermal 10 fatigue that's going to go'-- going to last until about the 11 = year 2001, and the question is should the staff wait until 12- that industry initiative is complete before resolving this 13 issue,_and that's one of the items that was discussed at the 14 August 20th meeting.
'15- The industry stated at that meeting that, in their 16- view, there was.no effective interim inspection activities 17 that:could be undertaken for the' class one piping welds at 18 this time, and in the next slide, I want to point out some 19 of the technical constraints that were raised by the 20 industry at the meeting on August 20th.
21 First, there was the comments that it was a very 22: difficult --
this.small bore piping was a very difficult 23 : geometry to conduct ultrasound examination. ;
24 -Another was that the ability to reliably and i 1
'25 effectively detect cracking.had not been demonstrated with l i
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315 1 this type'of equipment for this small piping and that it q 2 would require additional training and certification of
,3' inspectors to be able to perform this type of inspection.
4 .Another. concern was the lack of appropriate weld 5 preparation. There would have to be a lot of grinding to 6 remove weld crowns and such to be able to allow the 7 inspection to take place, and it might cause additional 8 indications to be observed during the inspections.
9- Another item there was that the inability to size
- 10. the indications reliably might lead to replacement of piping 11 upon indication of detection, and finally, they pointed out 12 that, if they did find indications, the inspection scope 13 would be expanded as mandated by the. code and it might go 14 beyond what the original intent was in the sense of having a
() 15 representative sample.
16 You might end up with a majority of welds being
- 17. examined far beyond what originally was intended as a 18 representative sample.
19- So, those were the points.that were brought out by 20 the industry at the meeting, and the staff considered them 21 to be reasonable points, but industry did indicate that they 22 are working to assess this inspection option for the small
'23 bore piping for HPSI class one and to develop possible 24 procedures and guidelines for the small diameter piping 25 inspection.
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-1 MR. BARTON: .W hat kind of options would they be l 2 considering other than UT?
Q 3 .MR. SCARBOROUGH: I think one of them that's been 4' mentioned has been monitoring.
S' MR.'MITCHELL: As we understood it from the 6 meeting that we had on August 20th, within the nine-month
'7' timeframe,.primarily they would still be focused on 8- ultrasonic procedures.
- 9. .It would be a matter of understanding, I guess, a
-10 little more about what the state of the art in UT is and how
- 11. it could be applied to addressing this particular piping 12 geometry for the purposes of-detecting thermal fatigue 13 cracking.
14 DR. SHACK: Do we know enough that inspection is
() 15 really helpful here?
16 I-mean is:it one of these things that, once the 17 ' cracking ~ starts, you're going to through wall in three 18 months or something so that your chances of actually, you 19 know, finding a crack except --
it's either not going to be 20 -there or it's going to be-a leak?
21 MR ., MITCHELL: That has been another point that's 22 been raised by the industry-in our discussions on this topic 23 in that there may be other options.such'as temperature L
24 . profile monitoring which'are more effective at detecting the 25 conditions which could lead to the cracking rather than
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E I-l 317 l 1 pursuing the' inspection options.
1
( 2 The program which is being pursued by industry 3: also has tasks in it to consider a monitoring program and 4 the implementation of monitoring, along with the potential 5 for inspection options, t
- 6. MR. SCARBOROUGH: One.of the options that had been '
7- proposed during the discussions with the industry was to
'8 . substitute some of the larger piping diameter inspections 9 that are required to be performed with a few small-diameter 10 piping, and decisions regarding that option was that there
- 11- were so many more small-diameter piping welds that you might 12 end up having so many you wouldn't be doing any l 13 large-diameter piping weld inspection.
14 So, that option was explored, but it wasn't felt
() 15 that it should be pursued.
16- So, based on this new information, including the 17L . low' risk significance that was determined from the internal 18: calculations.regarding the weld inspection, regulatory 19 action was deferred for nine months while the industry 20 assesses the inspection option for the small-diameter 21 piping.
22 In the meantime, the staff will work with ASME to J 23 . develop a' code' case for HPSI class.one piping, which as Matt 24' was talking about, might be a more structured sample for UT 25 examinations,- as opposed to the way it is now.
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oc 318 1 Also, the.. Office of Research plans to participate 2; on this thermal fatigue issue,'possibly sharing reviews of a[~\
3 samplesLand_ things of that nature _to try to come up with a 4- . consensus opinion on this issue.
5 And finally,swe plan to clarify the status of the
~
6 HPSI class one' piping issue in-the next rule-making, which 7 is.the 120-month rule-making that we're working on right 8- now. We. plan to clarify where we are with this issue at 9 that' time.
10 So, that's where we are on both these issues.
- 11. I'll be happy to answer any other additional questions you.
12- all might have.
13 DR. SHACK: Would you actually put some sort of 14 interim status:on HPSI in a rule-making?
O)
( -15 MR. SCARBOROUGH: Just in the sense that, in the 16 rule-making that went out on September 22nd, we did discuss 17 that this wasLan' ongoing issue, and because of that, we sort
-18 of left an open door there, and it would be good to provide-
- 19. some information. So, we'll have to figure out some way to 20 say it, just to let people know that it's a still ongoing l 21' ' review, L 22 DR. POWERS: Is the situation that the NRC staff 23 vants to impose these inspections and the industry doesn't 24 want them to, or is it more complicated than that?
l 25' MR. SCARBOROUGH: I would say it's probably more I ,
OA/
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p 319 1 complicated in the' sense that there is real discussions 2- going.on.in terms of what is the best possible monitoring or 3 examination for these. I think it's more than just one side 4 wants the other one to do it and the other one doesn't want 5 to do it.
6 I think there's a real discussion as to what's the 7 right thing to do here, and that was one reason why, in the 8 September rule, we didn't mandate those surface exams, 9' ~because there was a concern that our people are receiving an 10 excessive dose to do these surface exams and it's not 11- . achieving them the goal that they wanted to have.
12 ~ So, I think there's a real technical discussion 13- going on and not just-one side wanting to do something and 14 -the other side not.
15 DR. POWERS: Well, my understanding is that the 16 cracks of interest are those that are generated on the 17- inside, not the outside, to begin with, right?
16~ 'MR. MITCHELL: Correct.
19- DR. POWERS: So, an external examination tells you
'20 whether you've cracked through, I guess, but it doesn't tell
-21L you muchLabout it.
22 MR. MITCHELL: Right.
- 23. DR.-POWEES: Have we had a history of cracking in
'24: these particular pipes?
25- MR. MITCHELL: We have seen instances of thermal i ANN RILEY & ASSOCIATES, LTD.
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1 320 1 fatigue-damage in these pipe systems,.the most, I guess,
.2l notable and recent of'which was the cracking which occurred
'3-at Oconee, I believe, in.1997 in a high-pressure injection 4 make-up, dual-purpose line.
5- DR. POWERS: And what's the' consequences'of having 6; cracking in that?'
' '7 MR.-MITCHELL: The qualitative assessment that the 8 ' staff looked at, at'least at.th'e time of Oconee, was to
~
9 observe that you're looking at a small-break LOCA potential, 10 -potentially affecting the system designed to mitigate a 11- small-break LOCA in the high-pressure injection system, and e' 12 to that extent, when we also noted, coming out of that 13 event, that there was an apparent discrepancy in the code in
'14 not requiring volumetric exams on these particular piping
() 15 welds was how this issue was raised between us and the 16 industry.
- 17. MR. BARTON: What was the size of that weld, of 181 the pipe?-
19 MR. MITCHELL: Ifbelieve, in the case of Oconee, i 20- that was a two-and-a-half-inch-diameter pipe.
21 MR. BARTON: And the root cause of that failure 22- was?
23 MR. MITCHELL: To the best of my knowledge, 24 'although I was not directly involved'in that, it was L25 -attributed-to thermal fatigue associated with a loose ANN RILEY & ASSOCIATES, LTD.
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j 321 1 < thermal sleeve.in thatfnozzle location.
/h ;2 .DR. SHACKi Keith, you had something?
V 3 IMR.'WICHMAN: . Yeah. Keith Wichman, DE. A couple
'4 of comments.
35' I-thinkLMatt alluded to how this issue was 6- . originally raised. The code,Lin error, did not require 7 volumetric examination of high'-pressure injection lines in 8 -PWRs.
- 9 DR. SHACK: Is that based on size, though?.
10 MR. WICHMAN- Yes,.less than four inches. However 11' -- and this was raised -- this was discovered because the 4 12 class.two portion of the -- on the code does require 13' volumetric examination, so -- you know, class one versus
.1-4 class two.
15 So, I wrote a letter to'the code and raised this 16- issue in'1997. .This is how this.whole thing started.
17 Secondly, as far as being able to inspect these
[ 18 lines, the B&WEOwners Group and Oconee, for example, which
! l "19 had~the. failure, Oconee unit two, are inspecting these lines 12 0 successfully,.okay, with UT. These are two-and-a-half-inch 21' lines, and I don't think the.NRC staff agrees entirely with 22- all the industry objections to inspection at this point in 23 time.
24 And finally, as far as strictly high-cycle 25 ' fatigue, that's not the case with thermal fatigue, because Cf k ,/
s
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- 1, you have -- you can have'two components.
(} 2: If you have. thermal stratification, you have very t
3 high bending stresses, and that's-really low-cycle fatigue, 4 okay?
5 So, it's not -- you have a very complex mechanism
'6 at work in some of these lines, and it will not necessarily 7 go through~in three months, as you indicated.
8 So,. inspection can be' effective.
9 DR. SHACK: Any additional comments?
10 (No response.]
11 DR. SHACK: '1L;.7k ,rou very much. I suspect we'll
'12 be hearing from you again yet in the not too distant future, 13 and Mr. Marion, I think you wanted to give us some insights 14 on the 120-month update issue.
15 MR. MARION: Thank you, and good morning.
16 For the record, my name is Alex.Marion. I'm the 17 Director of Programs in the Nuclear Generation Division at 18 -NEI, and I recognize the initial request of this committee 19 was to' speak ~to you about the letter that you had drafted to i
-20 the Commission'on this elimination, but I thought we'd 21 . discuss an uncertainty in modeling techniques used to-22 ' address GSI-23.
23 That-seemed to be the topic of the day, but E24 Ereally, I thought you would benefit from a focused 25 discussion of. industry's position on this elimination that's i
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323 l' being proposed in NRC's rule-making, and what I'd like to do
[ 2 is kind of Let the stage with some background.
3 In 1993, a utility submitted a cost-beneficial 4 licensing action -- CBLA, as they were referred to at the 5 time -- that indicated that they_could not identify any 6 safety benefit in~ applying the 1989 edition of the ASME 7 code, and recognize this is in the '93 timeframe. They did 8 a cost analysis indicating that, for them to update their 9' program, they estimated'it would be on the order of about 10 $250,000.
11 Now, recognize this is one plant, but that cost 12 estimate did not include a lot of the implementation
-13 associated with training, inspections, and testing that was 14 not included in their current version of the ASME code.
(G;) 15 Now, when this was submitted to the NRC, the NRC 1
l 16. recognized the generic implications of this and contacted l I 17 NUMARC at the time, which essentially became NEI, and we j 18 began working with the NRC on the generic aspects of this 19 . issue that was raised, and in 1995, there was a Federal Reg.
20 notice where NRC announced the intent at that time to 21 baseline the 1989 edition and consider eliminating the 22 120-month requirement.
23- Fundamentally, industry supports the elimination 24 of the-120-month update requirement, and that position is 12 5 based upon our understanding that there is no demonstrated l
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l 324 1 increase L it t safety that's commensurate with the cost of b
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2 implementing.that requirement.
3' .It essentially is'an unnecessary regulatory 4 mandate.
5- We:believe'that base-lining the '89 version of the
.6' codeis adequate and sufficient, and the NRC, in their 7 documenta on supporting the proposed rule-making, 8 essentially. feels'the same way.
9 Thefindustry submitted comments to the proposed 10 rule-making on January 25th, and a copy of those comments
,11 were distributed to you, and I would like to draw your 12 attentials to particular areas.
13 -On attachment one, I would like to refer you to --
14 I am sorry --' enclosure one to that package, I would like to
(, l15 . refer to page one, item one, potential effect on safety.
16: -One utility had conducted an evaluation in
'17 ' comparing the '89 and '92 edition of the ASME code, and that j 18 % ' evaluation identified 84 changes, 77 of which were
- 19. editorial, 8 were errata, 52-did not change any 120 requirements, 22 reduced requirements, and 25 increased
- 21. requirements, and these are requirements between the '89 and 22 '92 edition, but ifundamentall'y, the utility concluded that 23 none of these had any safety significance.
24~ I'd like to-refer to --
25- DR.. POWERS: This was the transition between the i
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325 1 '89 to the '92 version.
'2= MR-. MARION: Yes.
[ -3 MR BARTON: It's a snapshot.
l 4 DR. POWERS: And we're talking about something
! -5 that would be moreTlike the 1992 to the 2002 version of it.
6 Do you have any basis for thinking that this is indicative 7 of-'the amount of change that you will get in that time i 8 period?
9 MR. MARION: It's hard to say unti] we see the 10 2000 version of the code or later versions of the " ode.
11 DR. POWERS: But you're asking people to e 12 prognosticate here, and it must be that you think that this 13 is the kind of thing that you'll get in 2002 vis a vis the 14 '92 version.
15 MR. MARION: No, we're not asking people to E16 prognosticate on what it's going to look like in the future.
17 What I'm trying to do is give you a sense of the industry's 18 evaluation of the '89 edition of the code and a comparison 19 of'the '89 to the '92 edition-of the code. That's the only 20 purpose.
21 MR. BARTON: But you're.asking for relief from the 22 120-month update forever, right?
23 MR. MARION: Yes.
- 24. MR. BARTON
- So, some later editions of the code
)
25- .may, in fact, have safety implications and should be adopted a l
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-1 by the in'dustry.
3
- 2)
- MR.'MARION: Well, whether the industry adopts the
- ['
3' code is a. separate question from the NRC incorporating the 4- code in.the regulation.and making it a mandatory
.i
.5- requirement.
6 If a future edition of the code, indeed, contains 7 provisions that relate to'a safet! improvement, then we 8 ' support the NRC making the. regulatory decision, based-upon
'9 the safety threshold and incorporating a requirement of 10 those' safety. provisions in 50.55(a). We're not arguing 11 about- that .
12 'What we're arguing about is incorporating and 13 mandating all of the other stuff associated with code 14 provisions as this cycle of 10-year updates continues.
() 15 We have no argument about the safety case being 16 made on provisions. We're.just concerned about wasting a 17- . lot-of resources and doing allHof the other things that the 18 code requires on this 10-year cycle where utilities have 19 looked at it and can't make a safety case for it.
-20 DR. PCWERS: I' guess I'm struggling here a little 21 bit to understand. l i
22: This group, the ASME, that makes this -- these are 23' .not Martians'that land here with the intent of making life ,
24- hell.on the nuclear industry. 1 mean I presume members from i.
.25 ; the nuclear industry participated in these -- in this code I
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I 327 1 group.to come up with these changes and whatnot.
L. m a
'()- y2 3'
MR. MARION: Absolutely, and I participate in one of the1 groups myself. )
( 4 DR. POWERS: Okay. So, why would these people
' 5 .. . create things that are simply burdens with no significance
, 6.
7 (MR. BARTON: On themselves.
! 8- DR .' POWERS: -- on themselves for no significant 9 reason. I. mean there.must be a reason they're putting in 10 ^these changes.
11 MR. MARION: . Basically, from the standpoint of 12 standards development, there are two fundamental reasons for 13 standards to be developed, and this is an opinion that I've
- 14. been articulating to the standards community ever since I've l L( ) .15 been involved in the standards community, which has been
-16 about-23, 24 years, and those two reasons are very 17 straightforward: to capture current practice and to pave l i
(
18.
the way or develop a framework for the application of new
-19 technology.
20 <
'Now,.the standards development organizations have 21- been_very1 successful as long as they've stayed within those
- 22. _two mandates.and achieved those two objectives. The 23 differenceHis standards are for voluntary use.
24 In this particular case, with regard to ASME --
25 and'I believe it was cited in your letter -- 50.55(a) has I.
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F 328 1 existed since 1971. So, for 28 years, we've had a i
2 regulation that mandates the ASME code.
C[
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l 3 Now, back in '71 and through the '70s, that was 4 the right thing to do and a lot of benefit was had in terms 5 of improving cot.atruction design techniques and inspection 6 techniques of the nuclear power plants.
7 Now, today, people are taking a good hard look at 8 these 120-month updates, and they're questioning the safety 9 case that must be made by the NRC if they decide to impose 10 these code requirements in a regulation.
11 Now, that does not disparage or cast any doubt on 12 the standard development activity that resulted in the 13 standard.
14 Our basic belief is that the standards that come O)
( 15 out of standards-development organizations have to provide l
16 value to the end users, and historically, that value has 17 been demonstrated as long as the standard organizations 18 satisfy the two objectives I mentioned a little while ago, 19 and when that value is demonstrated, those standards will be 20 applied by the end use industry, and I think the NRC is on 21 record indicating that that's happened.
22 There are several hundred standards that are used 23 by utilities across the industry that are not mandated by 1 24 50.55(a), but they're in the design and licensing basis of 1
25 the plants. l l
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7 329 1 There are only about 20 or so that are addressed 4 1
'2 by regulations.
3 So, our point is to make the regulatory decision 4 on revisions to-50.55(a) based upon the safety threshold.
- 5. If the. safety threshold can't be demonstrated, then it j 6 should not be regulated as a mandatory action. That's 7 Lfundamentally.where we're coming from.
8 'I'd like to quickly bring to your attention 9 enclosure two, which is a tabulation of the burden on 10 ' licensees related to this update, and this is -- the first 11 page represents an estimate that was provided by one
-12 utility.
13 The second page tries to capture the range, if you 14 will, of costs based upon the input we've received from a 15 number of utilities.
16 So, the total cost of the industry is somewhere 17 between 55 to 155 million across all the plants.
18 MR. BARTON: This is the '89 and '92 update?
'19 That's.what this item is based on?
'20 MR. MARION: Let me introduce Kurt Cozens. He was I
-21 involved in getting all this detail together to support this e
22 letter..
23 -MR.~ COZENS: This is Kurt Cozens with NEI.
24 The process of, updating the code is a procedural 25~ cost of going through your entire program as it exists, ;
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7 1 -comparing it-to whatever exists.
L2- These costs represent the procedural incorporation
[~
M. )i -
3 of-whatever~new requirements'might be there, independent of 4, the' addition ofLthe update.
~5: This!does not include extra actions that might 6 Loccur due to finding'something through whatever and having
-7 .to take additional licensees' actions to implement some form 8 .of a codefrequirement.
9, So, this is just the procedural --
.10 MR. BARTON: This is like a change that has 11 nothing but editorial errata data in it, it's going to cost 12 .$900,000 for~each utility to implement?
13 MR. COZENS: There's a lot of work going on, 14 because you have to validate how you stand against that
.e
,{ j- 15 requirement through all your procedures.
16 MR. MARION: Thank you, Kurt.
l 17 I'd like-to talk briefly about the rule that was 18 issued.in' final form. This was a revision to 50.55(a) that 19 - was issued the 22nd of this month, last week, essentially
- 20. incorporating by reference the95 edition, '96 addenda, 21- effective date November.22.
L 22- In the rule-making package, the NRC indicated that
'23 .they are giving consideration under a separate rule-making
- 24 effort this question of eliminating the 120-month update.
1
'25
-The situation we have now, gentlemen, is one of !
l I
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m 331 1 coherence, for lack of a better characterization, because
); 2 right now, in terms of the regulatory process you have a 3 requirement calling for a continuing cycle of updates and 14' 'it's' fundamentally unnecessary.
5 There's no demonstrated safety benefit that's been 6 established, and it calls for a continuing expenditure of .
7'
-resources that"could and should be applied to matters of
'8 safety significance,.and'we're encouraging the NRC staff to 9 ' expedite their decision-making process on this elimination,
- 10. and we're looking forward to their decision, and we're 11 hoping that the decision is based upon the safety threshold 12 that's necescary and required to support rule-making on that 13~ particular item.
1, To answer Dr. Powers' question earlier, I got into
() 15' a little' bit of a discussion of standards development, and 16 1'd like to talk about that a little bit more.
17 The National Technology Transfer and Advancement
'18 Act-was issued.in 1995, and'there's an OMB, Office of ;
i'
( 19 Management and Budget, circular that provides guidance to 20 Federal agencies on how to implement that legislation, Land 21 1 it's OMB Circular A-119.
l 22 Fundamentally, it calls for Federal agencies to l
-23 endorse codes and standards or to endorse standards, because
. i i
24 when'a standard's endorsed by a Federal-agency, it j i i 25 -automatically is characterized as a code, so let's just keep l i
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332 1 LitLin the term of standards.
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l2 The guidance calls for the agencies to use u
3' rule-making.to endorse these standards and make them
~
14 . effectively codes.
- 5. Now,.we don't have any fundamental agreement with
.6L that-process.except..that the rule-making decision needs to 7' be1 based upon the1 safety case being made and it should be 8 Lconsistent'with the back-fitting rule, and that's 9 . fundamentally-the differentiation we're making on this 10 particular issue.
11 We're not arguing about the merits of the-12 standard. We think the standard, if it provides value to 13- .the end users, whether they're utilities, constructors, 14 architect engineering firms, consultants or whoever, they
~
- 15 will be used.
16- One position we feel very strong about is that the 17 standard development process, whether it be through ASME, 18' IEEE, ANS, ISA, should not be an extension of the regulatory 19- process, and by that I mean where the NRC unduly influences 20- .the standard development organization to achieve NRC 21 objectives that cannot otherwise be achieved by an open, 22 public regulatory process in making decisions on 23 ' rule-making.
~24' DR. POWERS: Let me say, if I can understand this,
-25 you're saying that the NRC can flood this committee that ANN RILEY & ASSOCIATES, LTD.
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l .. 333 L (1 makes these standards up with folks and create something L
Ld [T .2 that they would not ordinarily be able to do via the
- "3 back-fit rule.
4 MR. MARION: Yes.
5 DR. POWER 5: I don't understand the ASME standards l6 development.
-7 I-have been very~ curious about it, so we've had 8 them here.several times to discuss it with me, and they 9- spend quite a little time explaining to me that, no ,
110 flooding it is not possible, that they restrict the 11 membership so that there's no more than one-third from any 12 particular group, identifiable group there.
-13' So, now, how would one go about_ flooding this if 14 one wanted to?
15 MR. MARION: I would suggest that the way of 16L . influencing an-organization, a standard development 17 ' organization, is through the consensus process by holding on 18 to a negative-ballot, not justifying the basis for the 19 negative, and precluding the work product from a writing 20' committee to move forward'until that' negative is resolved, 12 1 ) and oftentimes to achieve. con'sensus, individuals will defer n- ;
22- 'to?the desires and expectations of the person casting the
- 23. negative ballot, and I'.m not just speculating on this, I
- 24 would suggest that you refer to the. transcript-that was 25 . developed at'the public meeting or workshop that Tom I
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t 334 1 Scarborough referred. ton this 120-month elimination.
- i. ..
- wf' 2l There were statements made by NRC staff involved 3- .in ASME code' activities that support that, and I would let 4 'that1 speak for itself.
-5 MR. IMBRO: I guess I would maybe take exception 6' .to that. .This'is Gene Imbro from the NRC.
'7- I think~there have been many instances where ASME
'8' has put things in the code, you know,.above.NRC objection,
.9_ that the ASME process has a second consideration ballot and 10- that only requires a two-thirds vote to be approved. So, I 11 don't think it's a proper. characterization that ASME can 12 influence the code.
11 3 ' I think, typically, there's only one person on 14 each~ code committee, at most, and some' code committees have n
( 15 none, no NRC representation. So, I guess I would take 1
16 exception to that.
17' MR. MARION: Well, the public record of that 18 particular meeting speaks for itself, and I'd like to move 19 on.
20 MR. WICHMAN: I would agree with Gene. I was at 21- that meeting, and I do not recall that that issue was as you 22- state.
23 MR. MARION: Okay.
24 Let me make it clear that the industry supports 25 .the consensus process. That's been very important in the
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m 335 1 success of standard development over the years of nuclear
() 2 3
energy, and it needs to continue into the future.
But fundamentally, the products that come out of 4 standard organizations need to be of value in today's ,
5 environment, value to the end users, and I'm not talking 6 about cost.
7 I'm talking about fundamental benefit in your 8 processes, whether it be a current practice or allowing you 9 to apply a new technology. That's where I'm focusing the 10 question of value.
11 In order to continue this, there needs to be 12 participation by Federal agencies, by utilities, by 13 consultants and others in the standard development process, 14 That participation is clearly the reason that the process A
( ,) 15 has been successful over the years, and it needs to continue 16 into the future.
17 To give you a perspective the NRC has 141 staff 18 people involved in 254 committees of 16 standard development 19 organizations, and I'm not suggesting they're flooding the 20 process.
21 The consensus process will survive, but in the 22 consensus process, every member has one vote or every 23 participant has one vote.
24 We believe that the use of rule-making is too slow 25 and too rigid and it creates a lot of confusion, especially ANN RILEY & ASSOCIATES, LTD.
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! 336 .
l l 1 when rule-making decisions are not made or, rather, V .
] 2- . rule-making decisions are made on things that relate -- have 3 nct relationship to _ safety whatsoever, and I think that's o4 where a lot of people are starting to question the basis for l I
5 ' rule-making to continually endorse and mandate the ASME code 1 6 through: changes in 50.55(a).
=7 Fundamentally, the tenet of standards development 8 is voluntary:use, and the reason it's voluntary use is 9 because the people developing.these things are confident 10 enough that the end users will apply their product, and I 11 think that speaks'for itself.
~12 There are many, many standards, as I mentioned ;
13 earlier, used in the industry without NRC mandating their 14 use through a regulation, and again, if the NRC decides to ,
() 15 incorporate a standard _in a regulation, then that-16 incorporation must be consistent with the back-fitting rule l l
17 and a safety case or a safety threshold must be determined.
18 Let me just indicate that there is -- during this j 19 process of discussion, public discussion on this elimination 20' that's in the proposed rule-making. There's been a !
21 tremendous' amount of discussion about the standards
'2 2 z development process.
23 As a matter of fact, we got on it a little bit 12 4 today, and.I want to make it very clear that-our issue with 25' NRC action is strictly with regard-to rule-making, and the ANN RILEY & ASSOCIATES, LTD.
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337 1 basis for that I think I've stated a number of times, but i
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s_-
2 there :'s u another aspect of this which is extremely 3 important, and that is NRC's process of endorsing code cases 4 and later editions of the code.
5 The NRC currently uses regulatory guides to 6 endorse code cases over a period of time. Unfortunately, 7 that period of time could be several years frcm the time-8 that a particular code case was issued and approved by ASME.
9 That process needs to be expedited and improved, 10 and we feel -- and matter of fact, back in 1993, one of the 11 recommendations we mi.de to the NRC along these lines was 12 that we think a way to expedite the process is to provide
-13 the NRC a six-month window of opportunity to identify 14 whether or not a code revision or a code case is in direct
'(~~\ 15 conflict with an existing regulatory requirement, and if
)
16 it's not done within a six-month time period, then the 17 licensees will take as an acceptance of that particular code 18 case.
19 We feel that that would be -- will result in more 20 streamlining, more focus of NRC resources in evaluating 21 these code cases in the future.
22 I'd like to just point out that there is a effort 23 that's being spearheaded by NRC research in dealing with the 24 National Technology Transfer and Advancement Act and the OMB 25 circular, and it's part of direction-setting issue number
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F~ l L
E 338 1 :13,'the role of industry, where-NRC'is focusing on the l:>
2 . organization's participation and endorsement in standard
)
g L3 development activities.
4 Fundamental objectives, we support, and right now, i
l .5 -they're spearheading an effort to foster better.
p
! 6- communications with all the standard organizations and t27
'. 7L lto identify a better way, a'more efficient way, a more 8 effective way for NRC1 participation and. endorsement,.and L
9- sI'm, quite1 frankly, honored and pleased to be part of that-11 0 process, and I think there'will be some successful outcomes 11 out of that.
l 12 There was a meeting. held in May, there's another-13 one planned in November,' and I think that's probably
.14 something, at the right point in time, this committee might
() '15 be interested in hearing about, because I suspect that the 16- NRC processes in terms.of their participation in codes and 17 standards will be something that sometime in the future is 18 different than what it-is now.
19 One of-the NRC principles of good regulation is 20: ' clarity, and thislis one of the five guiding principles", and
- 21 by-clarity, it means the regulation should be' coherent, 1
22 Llogical, .and practical.,
23' There should'be a clear nexus between regulations 24: 'and agency goals and objectives, whether explicitly or
'25 implicitly stated.
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'339 1 . Agency positions should be readily understood and
() _2~
3 easily applied.
That's a direct quote from those. principles.
4 NRC's strategic planning activity has changed over 5~ 'the past several years, and one of the interesting things 6 :that's being identified -- and'I hope I'm not responsible j 7 for that gentleman's condition back there -- nevertheless, 8 NRC's implementation of their planning activities focuses on 9 the attainment of four outcomes, and this is something that 10' we've been hearing a' lot in our' interactions with NRC staff 11 and NRC management over a number of issues.
12 Thoseffour concepts are very fundamental and 13 straightforward.
'14 First is maintaining safety, the second is
.15 reducing unnecessary licensee burden, third is increasing 16 .public responsiveness and_ communication, and lastly, 17 increasing the effectiveness and efficiency of key
-18 -processes.
19: So, in conclusion, let me make it.very clear that
- 20. NRC decision-making related_to regulation should be
.21' iconsistent with the provisions of the back-fitting rule and l 22- a demonstrated threshold of safety _ improvement.
l-23 In this'particular case of continuing the 24 120-month' updates, there is no demonstrated increase in 25 safety that'is commensurate with the cost'of implementation.
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340 1 We provided data to the NRC for the '89 code and a im i i 2 comparison of the '89 to '92 code, and we think the time to
\~) i 3 make that decision for the right reasons is here and now.
4 DR. POWERS: I guess I'm still pecplexed. You 5 have this '89 to '92 comparison, and it was what you said, 6 and now there are a lot of things that were of an 7 administrative nature. There's some that weren't. I don't 8 know what they particular were, and I don't know their 9 safety impact.
10 But still, the issue here is not a three-year 11 update, it's a 10-year update.
12 MR. MARION: It's a forever, continuing update.
13 DR. SHACK: Yeah, but you want it to be never.
14 MR. MARION: In a holistic way, the entire code,
/~ i (N,/ 15 most of the provisions that we've seen in '89 and '92 are '
16 not safety significant, fundamentally, what it's all about.
17 I believe Mr. Barton raised the question about something in 18 the future that may have safety significance. That's fine.
19 That should fall into a regulatory decision-making process.
20 We're not arguing about that.
21 We're just saying the process of continuing this 22 10-year cycle and looking at the program in a holistic way i
23 is not providing any value to anyone.
l l 24 MR. MARION: Well, here's my problem, one of my l l
25 problems, is that if I looked in the sky tonight and I f I gO ANN RILEY & ASSOCIATES, LTD.
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341 1 didn't see a comet, I couldn't attest to you that no comets
~
() 2 are ever going to come by, and if I look in the right part V
3 of the sky for five years, I might not see a comet, and I 4 couldn't still say that a comet would never come by.
5 When people set up this rule a long time ago that 6 requires this update in here, were they not thinking, gee, 7 things change, and each individual thing that changes may 8 not itself be very safety significant, but after I integrate 9 enough of them together, they really are, and I don't see a 10 way to easily have people go through an analyze a lot of 11 little things and make sure that they come up to be a huge 12 amount of safety significance, but because I've got this 13 l standards process of lots of bright people and knowledgeable 14 people working on it, it will be a rational update, and I'll r-15 (T) be sure to capture all these little things that together add 16 up into a big thing. I mean I don't see the back-fit rule 17 being necessary here because of the way they set it up la earlier.
19 MR. MARION: I'm not personally familiar with the 20 thinking of the NRC at the time this was originally 21 established as a regulation, but as I understand the 22 position from the Office of General Counsel -- and I don't 23 know if there's anyone here from that office -- the thinking f 24 was to allow a mechanism through 50.55(a) to provide a
- 25 process for de facto updates of future revisions of the h [~'T ANN RILEY & ASSOCIATES, LTD.
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g .--
342
.1. . code, okay?
h~ 2 Now,.as I understand _OGC's position, if it's
. V} -
! 3 ;3: =something other.than a de' facto. update -- by that I mean E
, 14 update the code as. published, no clarifications or 5 ' exceptions, but if there are clarifications or exceptions, 6? -then, in effect that becomes a:new regulatory position, and n '7 Lthati new regulatory position has to be' consistent with the
- 8. back-fitting rule, okay?
9' That's what I. understand to be OGC's position that 10 was. articulated a few years.ago.
11 If you're interested in a copy of that letter, I 12 know we have at it at the office. I can forward it to you.
13 But fundamentally, we're focusing on the 14 regulatory process here as it relates to rule-making action,
- 15. - and the data provided by utilities to us so far have-l'6 indicated.there's no' safety value in these cycles of 10-year 17 ' updates that'have occurred over the past several" years, and 18 fundamentally, if -- let's say in the 2000 edition of the 19 code -- well let's go to.the 10-year -- 2009 edition of the 20 ' code -- I don't know if they're going to do one at that 21_ point in time -- if there are provisions in'that version of 22'
- the code that clearly identify _a safety improvement to be 23' had through the inspection process and activities, then that 24: should be incorporated in a regulation. ;
i 12 5 There's no question from the industry about that. l 1
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r 343 1 It's all of the other provisions that have no impact on O
,J 2 safety 3 And that essentially concludes the comments that I 4 have. I don't know if there are any other questions.
.5 MR. IMBRO: I just wanted to mention one thing, I 6 guess as a point of clarification or maybe to take exception 7 to one thing Mr. Marion said.
8 I think he mentioned earlier in his presentation 9 that the staff supported the '89 code as a baseline, and 10 that's not true.
11 As the rule presently on the street indicates, the 12 baseline is the '95 edition, '96 addenda, and I think the 13 question of whether or not we use the '89 code as a baseline 14 is now -- is off the table.
rs j 15 Any update -- 120-month update would be beyond the 16 '95 '96 code.
17 DR. SHACK: I guess that completes this session.
18 We'll probably hear more about the 120-month update in 19 December.
20 -Back to you, Mr. Chairman.
21 DR. POWERS: Okay. Thank you.
22 At this point, I think I can go off the ,
l 23 . transcript.
124 (Whereupon, at 11:23 p.m., the meeting was 25 recessed, to reconvene at 1:27 p.m., this same day.]
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344 1' AFTERNOON SESSION v)
/ 2 3 DR. POWERS:
[1:27 p.m.]
Let's come back into session, and the 4 next topic'we're going.to deal with is the proposed 5 regulatory guide an'd design basis information, and John 6 Barton, you will take us through this.
7 MR. BARTON: Thank you, Mr. Chairman.
8 The purpose of the session this afternoon is to 9 hear presentations and hold discussions with representatives 10 of staff and NEI regarding a' proposed NRC draft reg guide 11 and design basis information.
12 The staff has been working with NET since 1990 in 13 developing guidance on what constitutes design bases 14 information as defined in 10 CFR 50.2. In October 1997 NEI (I' 15 published a document entitled NEI 97-04, " Design Bases 16 Program Guidelines," and submitted a document for 17 endorsement by NRC.
18 After. extensive interaction with industry on the 19 subject, the staff has prepared a draft regulatory guide, 20 DG-1093, in which the staff proposes to endorse industry 21 guidance in NEI 97-04 as an acceptable method for meeting
'22- NRC requirements. This afternoon staff will present the 23 status of the draft reg guide, and also NEI will make a
-24 presentation regarding the 94-04 document.
25 The Committee is expected to prepare a letter on A. ANN RILEY & ASSOCIATES, LTD.
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345 1 th.is matter regarding the acceptability of the draft reg 2 guide.
3 At this time I'll turn it over to Stew Magruder, 4 who will take the lead for the staff.
1 5 MR. MAGRUDER: Mr. Chairman, I'd like to invite l 6 Russell' Bell from NEI to sit up here at the table with me, 7 if that's.all right. 3 l
8 _MR. BARTON: All right. Stew Magruder and Russ 9 Bell will make a presentation.
]
10 MR. BELL: Thank you, Stew.
11' MR. MAGRUDER: Good afternoon. I'm Stewart 12 Magruder from the NRR staff. l I'm in the Division of 13 Regulatory Improvement Programs. And, as Dr. Barton said, 14 I'm here to talk about a proposed draft regulatory guide 15 which would clarify the definition in 10 CFR 50.2 of design 16 bases. l i
17- The objective, as I just said,:is to provide a 18 clear definition, and so that's understandable to the staff l
19 and' industry, what we mean by design basis in 50.2. j 20 For convenience, I've got the 50.2 definition on a 21 slide, and I'd like to leave that up so we can refer to that 4 22 'for the rest of the discussion today. I think it's
'23 important that we keep referring to that and understand that 24- we're_not attempting'to change the definition, we're simply 25 attempting to clarify it and make sure that we have a common l
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t l 346
.1 . understanding of the definition among the staff and the f 2- industry.
L. Q( O j- :
) 3 I wanted to start out by briefly discussing the 4 ' relevance of design bases. In our discussions we routinely 5 are asked why we worried about this and what's the 6 importance of defining design basis or making a distinction 7 between design basis information and other information. .I 8 guess to! start out with, as you see,. design bases -- the 9 . term.is used in many regulations; 50.34 describing the
~
10 ' content of the SAR - it will be used'soon in the 50.59
~
- . 11' criteria. It's used.to define reporting requirements, the 12- GDC obviously refer to design bases, and Appendix B, 13 criterion 3 on design control, refers to design bases.
14 DR APOSTOLAKIS: How does that fit into the
,() 15. definition on the right?
-16 MR. MAGRUDER: The term " design bases" is defined 117- 'in 50.2'because it's used in the regulations. j
- 18. DR. APOSTOLAKIS: Oh, in the 2 (a) requirement.
19 MR. MAGRUDER: The --
20' DR. APOSTOLAKIS: -How do they fit into the 21 ' definition of --
22 MR. MAGRUDER: The term is used in criterion 3, 23 . design control, which.says a paraphrase that basically you 24 need to keep. control of'the design bases of the plant.
2 5.- DR. APOSTOLAKIS: Thank you.
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a
347 1_ MR. MAGRUDER: Yes, sir.
2 DR. APOSTOLAKIS: Now one last question.
(
3 MR. MAGRUDER: Yes, sir.
4 DR. APOSTOLAKIS: What's the difference between 5 the licensing basis and the design basis?
6 MR. MAGRUDER: The design basis is a subset of the 7 licensing bases. The design bases refers to the actual 8 design of the plant, whereas the licensing basis includes 9 other elements such as programmatic elements, maintenance, 10 QA.
11 -The last bullet here beyond just the utility of 12 defining 50.2 or defining design basis in 50.2, we believe
$ 13 that understanding design bases is important when you're 14 making' changes to the plant or you're evaluating conditions
() 15 16.
in the plant. That's why we think it's an important issue.
Very briefly some background information about how 17 we got to where we are with this draft reg guide in 18- discussions with the industry. This issue has been with us 19 for several years. The engineering inspections are not the 20 first sure time that this issue's been brought up, but for 21 brevity I'll just start there.
22 We. talked about t aese . issues .in the late eighties, 23 .
.and we did big engineering team inspections. In response to 24 those inspections the industry developed guidance which was 25' focused mainly on help ag the licensees reconstitute their
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l 348 1 design bases,funderstand'what information was important, and
() .2 in some cases go back'to their NSSS designers or AEs to retrieve'information it doesn't have.
3 The term was defined
- 4. in that document; however, it wasn't the focus of the
. 5; document.
6- The staff did a series of inspections to look.at 7 what licensees had done and published NUREG-1397 in February 8 of '91. And the Commission' issued a policy statement in 9 August'of '92 which concluded that the NUMARC guidance was 10' : effective in allowing licensees to go back and. reconstitute 11- design basis, and more importantly that the Commission 12 policy statement emphasized the importance of understanding 13 'your design basis and maintaining your design bases.
14 Subsequent to that Millstone, Maine Yankee
() 15 inspections and shutdowns led to obviously a greater focus
,.. 16 on understanding design bases and controlling plant design 17 bases, and'then the Nine Mile Point issue here is one where 18 we've had discussions with the industry on when they should 19 report'when they're outside design bases. And as you're 20 probably aware,,we've undertaken proposed changes to the 3 21 . reporting requirements partly in responce to that.
22' At this point I'd like to turn over the rest of 23 the presentation or the next part of.the presentation to 24' Russ Bell from NEI,.who will go through the industry's 25 guidance.
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349 1 MR. BELL: Would you put this over there?
[%J ) 2 Thank you, Stew, and thanks to the Committee for 3 having me back. It's about I think two months ago I was 4 here talking about the FSAR update issue, and I'd probably 5 respond favorably to an invitation to come back soon on 6 50.59. Today is the third of what Tony Pietrangelo and I --
7 Tony is with me in spirit in the back thare -- call it the 8 triad of fundamental licensing issues L at have been in play 9 for a few years. The FSAR was pretty well worked through as 10 we talked about once before. Design basis is reaching a 11 . climax, we think. And 50.59 is also very well along with 12 draft guidance out for industry and NRC comment.
13 These issues are all interrelated, and in the case 14 of design basis, as Stew pointed out, is the definition that r
15 (h) appears a number of places, the fundamental building block, 16 okay? So it's very important to us as well as to the NRC.
17 I've given you a package of slides. For the sake 18 of completeness, I included some -- in fact, Stew, I also 19 have a background slide, I talk about the Nine Mile Point 20 issue, which was very important in renewing discussion of 21 this issue a couple -- a few years ago. You'll see -- I'm 22 just flipping through these because Stew's already done it.
23 We have a very similar objective in mind.
24 We do add a second bullet in terms of our I
25 objective. Not only is it important to have the common J
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350 )
)
understanding of~the definition'to support the other 2 regulations, but in'and of itself'the definition is 3 import' ant in the sense that design issues'that come up, that 4 .are either identified from the past or come up in the future 5 are characterized. .And'they may be characterized as, you 6: -know, design discrepancies.
7 To the industry if it's characterized as a design
- 8. badisbeficiencyoradesignbasisissue, we take that 9 extremely' seriously, as.your see, because of the way we 10 define that term. And we want that characterization when
.11 it's.used to be appropriate. It~doesn't'do the NRC or the 12 ' industry any favors to characterize issues that aren't quiet 13 so significant as design basis issues when in actuality 14 there was never any question that safety systems would have L15 ~ performed their function, and so on. So that's the other l '16 important part of this activity as far as we're concerned.
17 Stew's word was " relevance." My slide says 18 "importance." But again, similar material.
19 I'might start to get right into the discussion of I' 20 the guidance on this slide. And I'm sorry, I don't think l
! 21: 'they're numbered, but they are recognizable. !
22- As I understand it, the Committee probably 23- -received our August 19. version of this guidance. Now in the last few days we've we think finalized that, and we've sent 25 it-'-- 'this was after another discussion with the NRC, and L
~
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351 1 we've'sent that'over to Dave"-- 4
() 2' 3 Russ.
MR. BARTON: We just got it for the first time, 4 MR.. BELL: Okay.
5 MR.:BARTON: We haven't had a chance to review it.
6 MR. BELL: It_is very similar to what you may have 17 had for a longer time, .the August 19. The few changes that 8 are in there, your attention's drawn to them by rev. bars on o
9 the right-hand margin.
- .10 This guidance is-actually in the form of Appendix 11 B. What you've got there is Appendix B to our Document 12- 97-04, which was an update of the document Stew mentioned
- 13. that we did almost ten years ago, NUMARC 90-12. We 14 revisited.that a couple years ago,. and.actually reaffirmed O)
( 15 .it. Very little'in the way of, you know, changes to the 16- document, but the design basis issue on account of the L 17 Millstone lessons learned and the Nine Mile Point issue, we 18-- determined that we did need to take another look at the 19 guidance that was out there.
20 We did that,'and'after looking at 90-12, we made a 21 few' changes, added a couple more examples I think.to the 22 back, and reissued as 97-04. The guidance you have here is 1
23- .just-Appendix B.from that, which zeroes in on the 24 interpretation of the term " design basis" and contains all 25 the examples.
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e 352 1 MR. BARTON: Is there a specific reason that we're 2 not asking for the whole document to be endorsed through the
[v~)
3 reg guide?
4 MR. BELL: The balance of the document -- in fact, 5 look at the title of the document, " Design Basis Program 6 Guidelines." It was very much to do with, okay, licensees, 7 this is how you could go about setting up design basis 8 programs at your plant. This is where you might go to look 9' for design basis information. This is how you might want to 10 compile it.
Il That really is the bulk of the material. That's 12 really not the issue in play and it's probably more a 13 licensee call as to how he wants to do that.
14 MR. BARTON: Okay.
rN Ll } 15 MR. BELL: The regulatory matter is the 16 interpretation of the definition.
l 17 MR. BARTON: Okay, thank you.
l 18 MR. BELL: And that is covered pretty much by 19 Appendix B and that is the piece we singled out. 1 l
20 In the last year we again revisited the issue of 21 9704 and it was pointed out that we present the definition 22 and we present examples of design bases but in between there l
I 23 was a missing link -- what we call framework guidance 24 criteria for identifying or distinguishing design basis
- 25. information from the bulk of design information. I think l
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- l. 353 I
l 1 that was a fair comment and we undertook to fill that gap
' f~)' 2 with general and specific guidance and some additional v
-3 guidance on doing that that would help you link, see how you 4 got those. examples from the definition, so I think that is 5 what this latest guidance is going to do.
6 It is formatted in a way that highlights what we 7 think is very important, the linkage of design bases to the 8 regulations, okay? The design bases aren't all the design 9 information at your plant. Design basis functions are not 10 all the functions performed by your SSCs. They are the j 11 specific set of functions that are either required to be 12 regulations or that you take credit for in the safety '
13 analyses, in your safety analyses to show you mean Part 100 14 limits, GDC-19 limits, that kind of thing, n
(s ) 15 That is a key principle, as you will see on the 16 next slide that we think this guidance focuses on, the other 17 one being the distinction between design bases and what we 18 call supporting design information, which is a separate 19 underlying set of design information, much larger set of 20 information, some of which resides in the SAR with 21 additional design description, but much of which resides at 22 the licensee's file specifications, detailed design drawings 23 and so forth. That is another key principle that we are 24 trying to get.
25 I will just mention that the format is to present
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354 1 those principles.' Because you; mentioned what is the If) <2 ' difference between. design basis and licensing basis, because 3' it is so important:to understand the-role of design basis in 4' -the regulatory framework we spend a fair amount of' time 5 discussing its relationship to other concepts like licensing
'6 basis still gave you the perfect answer on that, but there 7 are a number of~other relationships that we try and develop, 8 again to underscore that. understanding of what design basis 9 are.
10 We provide'a number of, examples. Design bases
- 11 functional: requirements, design bases controlling 12- parameters, which is where you will get numerical values
'13 that are'the' reference bounds for design, and then again
- 14. examples of supporting design information.
(O) 15 You are well. aware then that we provided the NRC 16 'that on the 28th. You have received it. We had a task 17- force assisting us as we generally do on such things.
18 We are pleased the NRC is on a course to endorse 19' this thing. That is an indication that we have really come 20 ,a?long way on this. I think we have made some fundamental 21- progress: narrowing down a common understanding of this 22 thing.
R23 There are aLcouple remaining issues I think Stu is 24- going'to comment on after I get through and they are on a 25 schedule'to provide the draft Reg Guide, as you know, by the l
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355 1 endsof'this month.
"{ 2- I also had the definition in my package but this
)
43' is a much better idea. These are our basic principles or
- 4 key. principles, the first thing you see in our guidance 5 after-our definition and it drives home that point that --
L 6 well, a'~ couple of points. There are design basis
~
7 ' functions. We think those are tied directly to the 8 regulations, the functions-that are required to meet those 9 : regulations ---license conditions, orders and tech specs, 10 also the functions that you credit in your safety analyses.
! lL1 The. tie to safety analyses is critical in this regard. It I 12 lmakes sense.
13 Those are the limiting values for your parameters l 14 are used in the' safety analyses. That is the basis on which f-() 15 .you received your license'and so we think those actually 11 6 -become your' design basis values, which is the other category i
l 17 of design basis information if these are two separate 18 ' categories.
19 The values themselves -- they may be specified in
'2 0 - regulations; 50.46 has the 2200 peak cladding temperature 21 right in the regulation,-so there is a design basis 22 numerical value that came right from the regulation. Others
-23 .might be chosen from a Regulatory Guide or other type of 24 ; guidance document and.used as an input to an assumption in 25 your safety analyses. Again, the tie to the safety analyses I
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q 356 1 Lis'very, critical. Those become the limiting-values for the
]~s_ -
- 2. balance of your detailed design, so these are key 3 principles.
We call'those general. guidance-in the document.
5 SpecificLguidance -- here is one I haven't mentioned. The 15 design bases functions include the conditions under which 7 those functions must be performed -- I must provide this 8 -much' water from here to there in that much time against this 9 much head. I also need'to know under what environmental 10 conditi'ons that mightLhave to be-performed, seismic 11 . conditions, fire, wind loadings.
12' Those types of conditions under which design basis 13 functions;need to be performed would also themselves be 14 considered design bases.
() 15 Stu mentioned that they are a subset of the
- U5 licensing basis -- the design bases are required to be 17 presented in the SAR. That came from 50.34. That is how 18 the applications were set up, so we think the design bases 19- are located in the SAR.
20 The last key principle is design basis information 21 is at a fairly high level and it is recognized that (2 2 - ' underlying that is a significant amount of supporting design 23 -information. I think the distinction is very important.
=24 1That is why we come back to it quite a bit.
25 I will not go through all of these. I mentioned u.
O (m ,/
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y p
L 357 1: ;that we.tried to place design bases in context with a number
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of.otherJregulatory concepts and terms. including these. I mentioned AppendixLB, licensing basis. Some of these will l 45 come outcas-we continue.
L
~
- 5- If you peeked ahead I can dwell on the aux
~
- 6 .- feedwater for a little bit. After the. general and~ specific L 7 guidance land the discussion of relationships, we get to a 8 number of examples. There'.s-a note-in the front that says.
9 these examples are representative. 'They are intended to be 10' ' actual examples or all inclusive. A given plant may have t' 11. different design or additional design Pases functions or
.12'- values than are presented here.
'13
.That said, we tried to pick a range of different
- .. '14 ' types of tnings -- aux feed,'BWR containment. We included
- 15. the MOV and turbine generator example at the suggestion of 16I the Staff'and at this point-let me.-identify -- the guidance 17 gives the licensee, and this has,been true since back in 18- 9012 -- the licensee had the flexibility to address design 19- bases issues in a topic format.
'20 .You'could take the-aux feed system and say every 21' component in the aux feed' system shall be seismic, EQ, you 22 tornado-proof and so forth. On the other hand, that
'know -
. 23 would create'a very repetitive situation. You need to
.24 repeati that kind of information over and over for system i 25: after, system. Why not take care of.those topically? That Q l -ANN RILEY & ASSOCIATES, LTD.
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l' 358 L,
1 is-what we mean when we say topical design bases.
()
2 In the. guidance'we did a couple examples. One
- 3 - very.important'one is a single failure criterion.
! .. You can 4 treat that' topically rather than over and over. Obviously 5 numerous systems are_ required to meet the single failure l
6 criterion'and seismic, tornado. EQ is another good one, but
-7 I don't think.we did the' example on that.
L 8 -You won't be able to read inis, but you have in
' 9 . your-package - ~this is' simply a page'from the package. The
,10 aux feedwater example I will just comment for a minute it 11- reinforced a couple of things I have said so far.
12 In better understanding design basis, we 13 identified two categories of information -- functions,
- 14. design basis. functions -- and the controlling parameters.
i(n) 15 .used as' reference bounds for design. This is where your 16 numerical values.will show up.
17 uOn this side-you'll notice we state a function,
~18 l generally understood function of the aux feedwater system, 19 and we link it to the basis in the regulation for that 120 function.
l 21 Over.here you will find the "xxx" gallons, "yy" )
22 ' pressure and "in x~ seconds." These are the parameters and 23 the values typically taken from nr used in the safety
]
l s24- -analyses as the basis for demonstrating that the design 25 meets all,the NRC requirements. These are the key j i
I
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359 1:
1 parameters used in the safety analyses, which are the l
[) 2 bounding. analyses for the balance of the design.
3 Also, the'you may not get'from that that it needs 4 to function without any AC power at all in the station i 5 blackout ~ situation, so we have a separate item here, and for L
6 I-am not sure all'but perhaps many plants pressurizer vapor
- 7. space is another limiting parameter used in design in the 8 AFW system.
9 'There is a link here, a relationship to the
- 10 refueling water storage tank. That is a requirement here.
11 This shows how the topical requirements come in. You notice 12 the topic design-bases are in that left-hand column and so
! 13 tied'to the regulation -- GDC-2 for natural phenomenon and 14 so on -- so these have equal importance, equal status as l
(). 15 those very functional, specific functional requirements that l 16 -- we were just.looking.
l 17 DR, BONACA: Is this page out of your guidance?
E 18 MR. BELL: Yes.
19 DR. BONACA: It is? Okay.
20 MR. BELL: Hopefully it is page 10.
21 DR. BONACA: I was just curious because nowhere I
! '2 2 ~ 'see'it for the auxiliary feedwater system specification for 23 how much each pump delivers but in mean in terms of decay.
24 heat, so the redundancy lof the system is not mentioned and
- 25. yet the FSAR, Chapter 10, has definitions of how redundant
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r; 360 1 the system is supposed to be, so there is nowhere you have a t
O '2 requirement for that?.
U 3 .
Is it one of the issues being debated with the 4' Staff?'
5 MR. BELL: In fact, hopefully you.found this one.
6 I am looking at my topical -- I want to say that-we have got 7- the single' failure criterion here, don't we?
8- DR. SIEBER: Page 10.
9 MR. BELL: I apologize. It is hard to read from 10 here.
11 DR. SIEBER: That's it.
12 MR. BELL: Okay, so absolutely it needs to be 13 redundant, and that comes straight from the --
14 DR. DONACA: But single failures means that you've
() 15 16 got to have two trains but the FSAR establishes if you have to have three trains or the level of reliability of your 17 specs, so that would be a requirement, right?
- 18. MR. BELL: That would be part'of your -- that is 19 how you meet this requirement, or how.you meet the GDC --
20 DR. SHACK: And that shows up on page 11?
'21 MR. BELL: Thank you, that's a good idea. Let's 22- go there.
23- DR. BONACA: What is there?
24 MR. BELL: How you meet that requirement, whether 25 you have two trains, three trains, six trains, whether you l
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l 361 i i
1- have a DC pump as your diverse' source.instead of the-turbine
'db. 2 . driven one, that becomes the description of how you meet i
- 3. that' requirement. That is the design in our view rather 4' than the design bases, okay?
5 You are right, that information, how you meet the 6 : requirement,;that you have two trains or three trains and a 7 turbine backup, that is in your SAR -- that is very i 8 .important design information.that was~ reviewed and' approved i 9 by the NRC in granting a license and you maintain that-10 information complete and accurate =and so forth, so I think 11 that is an excellent example of a distinction ~between the
'12 de51gn bases and the design. f 13 .MR. BARTON: But it is also the' basis that the '
14 Staff has got for.'not endorsing the examples in AppendixLB,
- 15. and what they~are-trying to endorse is your Appendix B with
~16 several exceptions, and when you take into account the-17- exemptions they have got for Appendix B, you kind of get'to
~
18~ what is the value of endorsing the NEI document.
19 DR. BONACA: Because that exception is humongous.
20- .I mean if you go throt.gt'and.you take that excep*.: ion, it 21 makes a big difference on every system.
22 I mean if.-- I mean there were expectations after
! 23 TMI that your aux feed system would be more available, so 24 therefore'there was an' expectation that you would have three
-25 : redundant. systems and certain. diversities in the system and i
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362 1 sources and.so and so forth.
(~) 2 All that stuff is specified in Chapter 10, if I
%.)
3 remember the FSAR, and so if you do not specify-those 4 things, you have a very simple definition in fact, and you 5 don't meet those requirements of the regulation right?
6- I mean if you are supposed to have a three 7 redundant system, which means an unavailability of maybe one
- 8. in ten to the minus five, on demand, that is a requirement, 9 right, in the design basis -- or is it? I am trying to 10 understand.
11 MR. BELL: Well, you absolutely need to maintain 12 redundancy or else you are not meeting the GDC. If you are 13 saying, well, I have got four trains and I was licensed that 14 way and I think I might want to take out one of those eT tx_ ; 15 trains,.I will still be redundant, .that would be a change to 16 the design that would clearly involve an decrease in the 17 reliability, let me put it that way, in the system -- I 18 presumably.
19 In 50.59 language it would involve an increase in I
20 the frequency of an accident or a likelihood of a 21 malfunction and you would clearly be into a space where you 22 need to go talk to the NRC about that, so that is not 23 something obviously we are talking about a case that is 24 somewhat hypothetical but that type of information, again l
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363 11 thac becomes the design as-opposed to the design basis.
j) 2 Dr. Barton, you are absolutely right. That is one
%/
-3 of the few remaining' issues we have. I can't argue with you 4 that it is a minor detail.
5, MR..BARTON: This is a major issue with what is 6 really being. endorsed when the NRC really says, hey, we-are 7 endorsing'the Appendix except we're not and'that is really 8' what,the Reg Guide is doing and I.am totally confused as to 9 what we are really accomplishing here when we don't seem to 10' have come.to closure on some major issues, this being one of 11 them.
-12 DR. BONACA: The other thing is that these things 13 have a'long history. I mean the reason why, for example, 14- the number oferedundances.in aux feedwater systems were
()
15 increased was inLpart because for the Westinghouse plants 16 they.had an isolation 1 system.that went in because of steam
!17- line. break concerns that isolated all the main feed every l 18; time you scram, and-that was a big concern because suddenly 19 ' you went from plants-which normally.did not isolate main 20 feed, so.you always had main feed to a new generation of 21 plants that had no main feed because you isolated because of 22 steam line break concerns, and now you have to have more I
23 auxiliary.feedwater pumps to deal with the fact that you
- 24. were by design removing available main feedwater systems, 1
25- okay? l l
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Ii I 364 1- So, you know,:that stuff brings-in a history on
, , 2- development of these power plants which were reflected in "3 the Chapter 10s of the FSARs that is fundamental to the 4 design and that is really the design basis of the plant.
'S I think that is the point Mr. Barton is making, 4 6 that it is a significant' issue. There are not only four 57 ~ issues here, they are big issues.
8 MR. BELL: There is no question that is important 9 design information.
10 'DR. BONACA: I just wanted to get a sense of how 11 .far apart'you were.
12l MR. BELL: Well, one of our concerns -- I didn't 13 list it an objective. It goes without saying you want a 14' definition that is clear, implementable, workable. One j 15 concern that we have with that remaining issue with the 16 staff is once you begin to include certain design 17- information as design bases, it may become very difficult to 18 ' draw th&T line. And where does it, you know, where does it )
I 19 stop?
20 The thing we know we don't want is to identify 21 something as design basis where you're setting yourself up
'22 for a fall somewhere. It might be a minor, or I should say 23' a less significant matter, one with a small discrepancy, and 24 it.would not undermine the ability of the system to perform 25 its-function. That's.where.we've drawn the line at the --
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l
- 365, 1f .if-you preserve the ability to perform that function as
[~'y 2l . credited in the safety analysis, that's where we think we've I N/ ' ~
l3 got a workable space to work in.
>4 So -- and you.can see the range of the type of
- 5. information here -Take the third bullet, the system design
'6 pressure of the system. By that I mean the, you know, kind 7 of ASME code maximum internal design pressure of the system.
8 It might be 1,500 PSIG. To go back to the design basis 9 ' function here, we could say that it might-be 500 gallons a 10 minute against say 1,200 PSIG if, for example, the design --
11- -iflthis was elevated from.what we call supporting design 12 information to drsign basis.
'13 This is a very important aspect of design.
14 There's no question about it. 'It's essential to have a
'(. n) .15 robust design to support the design-basis AFW function.
16 lBut, if you find.one day that your actual AFW system piping 17 or a portion of it may be capable of withstanding only 1,450 18- PSIG, okay, we don't think you want to be in the position of 19 declaring that to be an out of design basis situation 20 immediately.
21 We would say like all discrepancies you would-22 evaluate that~first as am I operable? is it reportable? and
~23' now is it a design basis matter we can categorize. We would
.24J 'say that the capability to perform that function is still 25 preserved, okay? And that's an-indication that this type of
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1" parameter would not~be a design basis. controlling parameter. i i'
2 That's.where we come.from,-;and that's our rationale.
Very l '3 important design information and certainly figured 4 prominently inIthe staff's review of the design originally.
5 -- 'And if there is a discrepancy,. obviously it needs to be 6 , appropriately. dealt with I
7 'But anyway, I think that's probably.enough on 8'
~
that. ;I think I've. underscored some'of the key principles, 9.< the. structure, the' guidance, the tide.of the regulations 10 'that'we think-is so important, and'the: distinction between 11 supporting' design information. Again there's -- when l12 -discrepancies are~ identified, it's important that they be 13 properly characterized and not mischaracterized as design
.14 . basis issues when in fact there was never any qu3stion that 15 design basis' functions wouldlhave been performed.
116; Just.to wrap, we'll keep working with -- in fact 17- we have a meeting.on the 14th to try and address these 18 -remaining issues I expect we'll issue a revised 97-04, and 19 obviously comment on the staff's draft reg guide as
,2 0 - necessary.
- 21. If it's all right, I'm going to stick around while 22 you proceed.
-23, MR. MAGRUDERi Yes, in case there are questions.
24 MR. BELL: Do you want to?
25- 'MR. MAGRUDER: Yes, let's switch.
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. -. c 367 lu As you've pointed out, there are some significant
- ,( ) -2 -discrepancies or exceptions between the staff and NEI still 3 - remaining. I
- would like to say, though, that this list-is 4 much smaller than it was a year ago, believe it or not.
5 MR. BARTON: Yes, but you've had several meetings 6 .in the,recent past and several revisions to the NEI 7 . guidance, and'you still have these large exceptions.
~
8 MR. MAGRUDER: We still do. That's correct.
9- That's correct. Our goal is to endorse the industry 10- guidance. J 11 MR. BARTON: I understand --
12 MR. MAGRUDER: If that's not possible, we think 13 it's important enough that we would issue a reg' guide on our 14 ~ own to make clear what the design basis information is,
() 15 because you're absolutely right that there are some 16, significant-differences.
17 -
And I'd like to try and explain why the staff J18 -feels the-way it does on these issues. And our goal 19 obviously is to put this together in a manner that's 20 understandable and ask the Commission to publish this for 21 public comment to get more input on the process. But your 1
22 views on the subject are important to us and would be )
l 12 3 welcomed.also. l
'24 There are four major issues that we are taking 25- exception to: redundancy and diversity,-design basis values, L
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5 i
- s 368 11 normal operation, .and testing'and inspection. And we've I
-2 concluded a fifth exception in the reg guide just basically
(
3- stating that-the-examples'are not based on the staff's
- 4 ; viewpoints, they're; based on the industry guidance.
5' MR. BARTON: It says.if the industry uses them, 6L the industry's.out1there hanging on a limb, because you
'7 don't -- you guys don't agree with that.
8- MR'. MAGRUDER: That's pretty much correct. [
'9; We would, if they looked carefully, it would be 10 ' clearer which examples we agree with and which we don't, but 11 we' agree that it's not an ideal situation.
12 I'll start with. redundancy and diversity, which 13- we've talked about already here. The staff believes that 14 it's not sufficient to include the statement that the system
()' 15 will be1 redundant'and diverse and meet single failure 16: criteria in the design basis, and that -- a brief discussion 17 'cNE how the system is designed to be redundant and diverse 18 'should be' included in there. That we think that redundancy
- 19. and diversity are design parameters that need to be 20 addressed in the design bases. And that's basically why we 21- think-that they should be included.
22 . Design bases.may include credited features beyond 23 those required to meet single failure criteria, and we think 24 th'at it's important to include those. Examples would be 25- .there~are other design requirements that go into design such t
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369 lL asiseismic requirements 1or separation requirements. In
[~' ~2 addition ~, there are some instances, as Russ has alluded to, s _
i 3- where a plant chooses to install three trains of a system j 4 where only two would be strictly required for a single
-.5 failure. We'think that the fact that it was designed with
-6 three trains and the staff' reviewed it and, you know, for 7 robust Overall plant design with three trains,.it's 8- inappropriate to say'that-only two trains are therefore 9- -design bases =and one train is not' included in the design
'10 bases. 'That's our basic position on that.
11 Design bases values is another' exception, another 12- area where we're still working with NEI. The design basis 113' definition includes we think.all functions, both -- and that 14 would include active and passive functions of an SSC. It
) :15 also includes values associated with functions that. assure 16 an SSCJean. perform its required functions, i 17 Russ already talked about the system design j l 18 pressure for the aux.feedwater. system as an example. We 19 think.that1the integrity of the AFW system piping is H20 critical to performing the safety function of getting water 21 into the steam generator. So we would think that the
_22 function of maintaining integrity should be included in the l
! 23 design bases.
24 MR. SIEBER: Can I ask a question?
25 MR. MAGRUDER: Certainly, sir.
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p 370 1: MR. SIEBER: Just using that as an example, and 2' the further example of.the discovery that it did not meet
.\~/-
3- the: original design pressure, obviously there's relief 4: valves there, but I don't see them specified anyplace, and
- 5. one1could construe.that if you could accept a-lower design 6 pressure, also lower the relief valve setting to protect 7- that piece of pipe and thereby create the possibility of an 8 accident should you get an overpressure in'the system which
~
9 would relieve and rob you of flow.
10 MR. MAGRUDER: Um-hum.
- 11 MR. SIEBER: And so where does the subcomponents 12- like relief valve settings or other instrument settings that
~
13' 'are designed to protect the integrity of the system fit in?
.14 Is that in some notebook someplace, or is it in the design
( j' ' 15: basis or a design value?
E 16 MR. MAGRUDER: We think that the relief valves or 17- other components such as that, that their functions are
'18 . important, and that's the reason why we think system design j 19 ' pressure should be included in there, because when you size 20' relief valves, obviously.you need to know what the important 21 parameters are. The valves themselves, a description of the 1
22 r valves'themselves we don't think should be included in 23 design basis. That's-supporting information about how the !
24 plant.is designed. But the fact that you need to design it ;
25 so that it doesn't -- it can relieve -- to maintain 1,500 i
1
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371 1 PSI is inferred.from the design bases.
( 2 MR. SIEBER: Right. Thank you.
3 MR. MAGRUDER: The third bullet here talks about 4 code inputs that we think should be included or may be 5 included at times'in the design bases. An example of that 6~ is the cumulative usage factor used in the fatigue
- 7. determination for other ASME code requirement for design.
8 Where they are values associated with design basis functions 9 we think they should be included as part of the design 10 bases.
11 Normal operation is another issue here. I think 12 that if I had to characterize these, I think the first two 13 issues we talked about are probably the most significant 14- issues that we have. The remaining two are important but I -
15 less significant, I would say, and the reason I say that is 16 I think we are closer to agreement it cosers a smaller 17 population of SSCs. We think that it is important to 18 understand that design bases values and functions can be
- 19. generated or inferred from normal operation as well as 20 ' accident conditions in that systems that are only required 21 during normal operation also have design bases.
22 An example.of this is the fuel that in most cases 23 the most limiting conditions are found during normal 24 operation and most of the design inputs are based on normal 25 operation, so we don't want to leave the impression that
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372 l:
k . 'll safety analysesfor the Chapter 15 analyses alone provide the
] 2 design bases for the plant'.
3 DR.'SIEBER: Maybe I could ask another question.
L 4- MR. MAGRUDER: Of course.
5 DR. SIEBER: If you move to risk inform regulation 6- you somehow or other shift your emphasis from Chapter 15 to 7 .another set of incidents that could occur at the plant.
8 Does-that change the design basis?
9: , MR. MAGRUDER: Under the current scheme, once we 10 are through with Option 3 or whatever, if we define a new l
11 set of design bases accidents cn: include severe accidents in 12' the analyses, _then the. design basis of the plant would L '13 change, but'the design bases are derived from requirements 14 :in other regulations so they would - follow from the l
15- requirements in the regulations.
16- The next issue is testing and inspection. The 17' . point here is that many general design criteria specify that 18 ~ design systems should be designed so that they can be tested 19- and inspected and Staff feels that testing the 20 . capability, is an input into the design and should be
~21- considered design bases.
22 I would point out though that we are rethinking 23 that issue and the issue comes down to whether testing and 24 inspection are functions and required functions and whether
'25 ' it is' performed by the system or on the system, and so I i
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4
I 373 lE ithink we are still -- we get into these discussions on these
~
() ?2 1 3 issues and I think we'can talk some more about that.
For. completeness, I would.like to point out, as 4; you mentioned, Mr. Barton, that the examples as currently SL written in the guidance.do not reflect all the Staff 6 positions in the draft Reg Guide so that we have included E7 that as an exception as well.
8 That. concludes my presentation. I am sure.Russ 9 and I would be happy to answer any more questions, if you 10 have any.
11 DR. UHRIG: What is the. implication of including, 12 for instance where you.have optional three trains instead of 13 two ofLincluding it in the design basis? This then brings 14 it into the tech specs and all the rest of the requirements?
) '15 MR. MAGRUDER: No, we are not attempting to
.16 redefine the. tech specs. Some' systems which are covered by
~
17 tech specs -- let me put it this way. Many more systems 18 have design bases that are included in the tech specs and i 19 .the tech spec treatment is. separate from the definition of 20 design bases. I don't know if that answers your question or 21 not.
-22 DR. UHRIG: Well, in going back to the case where 23 it was four trains versus three trains on instrumentation l
24 and it wasia question of who got-the margin, the margin for >
25 operation or the margin for safety, I sort of see the same
- p)(_
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374
-' 1'.
- issue evolving.here.
'2 MR. MAGRUDER: We are not attempting to solve that 3 . issue with this discussion here. I am not an expert on tech 4 specs, so I couldn't answer that question I don't think.
5 DR. UHRIG: I don't really see what the issue is 6I then. .)
7 1 01. MAGRUDER: I am not sure I understood --
8- DR. UHRIG: The difference between the two 9 -positions. What is the significance of including that third 10' train in there?
-11 MR. MAGRUDER: Oh, I see what you are saying.
'12 Okay.
13 'IM1, UHRIG: What is the practical aspects of it?
- 14. MR. MAGRUDER: The practical aspects are that we 15 'think it is important that the operators understand why 16 three trains were installed in the plant and why the Staff 17 reviewed or approved the design with three trains.
18 There may be other reasons that are not 19 immediately obvious to the operators why there's three
- 20. trains there, and we think it's important to include all the f
l 21 ' design or all the facility and the design bases so that the i
L 22' operators will understand the importance of it.
l 23 DR. KRESS: Did those extra -- I will call them L :24 extra trains play some role in the original decision to i
25 . grant the license?
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375 i
-1 14R . MAGRUDER: Very likely they would. They could
( 2 have.
-3 DR. KRESS: If they did, that to me would be a 4 reason to have them in the design basis.
5 DR. BONACA: To give an example, you know, if you 6' look at many Westinghouse plants, they have what they call 7 the G spec, which is the General Spec, and then they have 8 the E spec, which is the equipment spec. They are cookbook 9 specification design to build, and if you go through those 10 and you can read through what requirements are coming from 11 .the regulation.
12 In fact, the question I was going to ask is, you 13 know, this is in existence already. The designers had to 14 deal with these issues and they didn't put in four pumps
() 15 because they liked to spend more money and put in pumps. I 16 mean there was some requirement there that came from 17 somewhere. .I quoted before the requirement of isolation for
-18 the. Westinghouse plants, that they had a concern that if you 19 had a steam line break that you would have a runout 20 condition and overcool and return to power, so they put an 21 isolation system on the main feedwater.
22 Well, suddenly you have this totally different 23 design wherv all.your main feedwater system, which we have 24 pumps running, are isolated, so you-are putting more demand 25 on the auxiliary feedwater system. They resolved that by O ANN RILEY & ASSOCIATES, LTD.
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4 376 L
L 1 going to three trains.as a minimum commitment. Actually, i
' ( )I- .2 the packet explains it, also tells you when you have to 3 deliver the' water,Lfor. example,'before you-dry out the steam
~4 generator,=so they have some' calculation to show dryout time 5 'and'the. time.for delivery.
l
- 16. So those things'I mean have -- that's the point
-7 .you are: making. Exactly ~right, Tom.' They were in the 8 original-design. LWithout it, you could not make a PRA 9 Lbecause you-wouldn't know how many redundancies you have-in 10U that system.
.11' DR. UHRIG: but there are cases were -- nd again
-12 I go.back:to this example of the instrumentation trains.
13 'The fourth train was put in for the purpose of giving you 14 ' additional. operational flexibility in the' event that you had
( f '15' one train out for testing and you had fault, instantaneous 16~ failure on the third train, if you had a three hour to four 17 requirement, which'is what got imposed on this instead of !
18 the two out of three -- the original intent was to have two
- 19 out of four -- which would have been just the same from a 20 safety standpoint as a two out of three, but the three out 2 11 of four got imposed because they wanted additional margin.
22 Of course, we wanted'the additional margin at'that time for 23 . purposes of operational flexibility, and it was -- I don't
. 24 4 remember;-- 10 million dollars or something was put in there 25 specifically: to gain that margin. that's got lost. Eventually L
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V
'2 :MR BELL: If I may, I heard'a couple things I 3 just wanted to. speak to and one is this notion that, well, it was: considered at the original time of licensing.
4 It may 5, have been.very important and might make it in this category 6, of' design' basis. You see, that is. exactly the problem. An-
_ .7 -enormous amount'of.information was considered, okay?'-- even 8 nore'than is summarized ~in the SAR, so as a criterion we 9- Efind that to b'e not determinant --
.10 .DR.~KRESS: It's not.a real' good quantitative --
11, :MR. BELL: Okay. Our goal is to teve a scope that 12 .is. finite, meaningful -- okay -- we want to distinguish
.13 design bases as a meaningful term, meaningful concept from 14' .the balance of design.
15 You know,.the folks who have got three trains
.16 versus four. trains, fluid systems, I&C systems may of course 17 know why they_have those. They frankly don't need us to 18 tell them, wel), it's design basis or it is not, to remind
- 19. them how significant'it is, so your question about, well,
, 7 20. what.is the difference I think is very valid, and I think it
- 2 11 has come up at.every meeting we have had, trying to-remind 2 2.- ourselves why this is so important.
23 DR. BONACA: But, see, you are telling me that,if 24 :you'canideliver'and can remove decay heat, it doesn't matter
- 25- i.f.you can.do it.with one pump, five pumps?
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- 1. w-
378 1 MR. BELL: If you only have the one pump, you are
['w /) 2 going to be in violation of a GDC requirement.
3 DR. BONACA: That's right. GDC is implying 4 redundancies and diversity and the design basis defines what 5 it is. I mean it is in the FSAR, so it is just hard for me 6 to understand how that specific piece of information would 7 not be critical.
8 We would discuss here in the ACRS in fact the 9 validity of existing PRAs given that there are discrepancies 10 in the design basis. Well, assume there are no 11 discrepancies in the basis, but you don't know if a system 12 is two redundant or three redundant. You can never know 13 what the PRA will give you. I mean then we can forget about 14 that because that is exactly the question the PRA will ask.
()
15 DR. KRESS: Why does the PRA necessarily have to 16 be tied to the design basis?
17 DR. BONACA: Well, as a minimum you have to 18 understand how many times you can deliver a function to have 19 an availability for the system.
20 MR. BELL: We would say, of course, *he PRA 21 reflects the design.
22 DR. KRESS: Ought to reflect the design.
23 MR. BELL: Well, the design basis is almost a term 24 of art that the regulators have used and licensees have 25 dealt with. You know, in field it really has very little
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e -
379 11 meaning to' folks, but it is used throughout the regs. We 2 need to understand what it means.
'3- It is misused at times when design issues come
! 4 up - 'because I,am down a train, it does not mean -- down a I
! 5 train might be maintenance. It does not mean I am outside 6 :my i design basis. We would not want it to go that way.
l 7 'I would still have redundant diverse capability as
! 8 I must to meeting not'only -- you know, I misspoke earlier.
9 If you had only the one pump not only would you be in p .10 violation of the GDC but you would also be out of your
! 11 design. bases because the' single failure criterion, as I 12 mentioned before, we would consider that part of the design 13 bases, j 142 DR. BONACA: Don't take the one literally. I just
. 15 wanted to give you the difference between one and five.
l I 16 DR. UHRIG: The difference between two and five 17 may not make any difference.
18 MR. BELL: .To bounce these issues off of our 19' . principles, the redundancy, diversity issue, okay.-- how is 20- -that-tied.to the regulations? You remember that is very l 21 important to us and-it is one of the key principles that we l 22 have up in. front of our document.
23 Well, the tie relies by the single failure 24: criterion. That .4s as far as the regulations go, and so we 25- would say that the-design basis of the system needs to ANN RILEY & ASSOCIATES, LTD.
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i 380 1 satisfy the single failure criterion, and that is as far as (L ,J; - -2' the design bases would go. How you do that would be part of 3 the design, a very important part of the design but still 4 part of the design.
5 MR. MAGRUDER: And the Staff would say that just 6- ' stating that you are redundant and reverse and you meet 7 single failure is not sufficient, that the parameters, the 8 design basis parameters, as discussed in the definition, 9 . include how you meet redundancy and diversity, so that the 10 two pumps or the three pumps or three trains or however many 11 trains you rely on, aside from what you installed for ease 12 of maintenance or whatever, that is a separate issue. I 13 understand now the issue you are talking about, that the 14 Staff feels that that fundamental design information is
( 15 design basis. I
- 16. DR. UHRIG: Well, it was more than ease of 17 maintenance, it was a case of remaining in operation if you 18 had a glitch -- when you had one channel out -- that kept 19 the plant operating.
20 MR. MAGRUDER: Okay. l 21 DR. UHRIG: Otherwise it would have gone down.
22 DR. KRESS: Well, certainly you would think 23 diverse implies an entirely different kind of system to 24 provide the function and the description of that in the 25 parameters, how it works, ought to be part of the design
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E 381 l
- 1 basis.rather than just saying it is diverse.
is
() 2 3-MR. MAGRUDER:
DR. KRESS:
Right. .That is our position.
Yes, but if you have more than one or l-l 4 two of these that are needed to meet your design basis i
l :S requirements in'the rules, then probably those spares that L
i 6 were.put in there for some other reason might not have to'be l
7 part of'the.-design basis.
8 MR. MAGRULER: .Right, and we want to make sure 9' that the' operators and the engineers at the plant understand 10- why they are all there.
11 DR. KRESS: Why they are there.
12' MR. MAGRUDER: Right.
13 DR. UHRIG: But it isn't the case that you have to 14 have these two. It is "two of" that are the requirement.
15 It doesn't make any difference whether it is number one or 16 Hnumber two or number one and number'three -- it's a two out 17- of three or two out of four requirement. There is no 18- specific two.
19 MR. MAGRUDER: -That's true.
20: DR. POWERS: But --
21 MR. MAGRUDER: That's true, but there's probably, 22 like.we've stated-before, there is a reason why all those 23 were installed and the reason why they are there is ;
i 24 important, and it may-not be for redundancy. It may be for 25- another reason.
a l
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rv 1 L 382 1 DR. SIEBER: Nell,fregardless of the reason.your t - -
j
'\ /) . 2' ' design basis ought to at least; recognize that they are {
' s/ i
'3 there, right?
)
1 (4 -MR.~MAGRUDER: -Right. That's correct.
~5- DR. .SIEBER: -Then;you could-spell out-further what -i 6' ' combination meets the' design requirement or the licensing 7 ' requirement.
J 8 MR. MAGRUDER: Exactly.
t-9' ,DR. KRESS: .If'there is a system put in or 10 . component put in by the designer and the licensee because he 11 , wants it there for some' reason, it helps him do his job, but
- 12. it's not needed to meet your design basis requirement or 13 .your GDCs.or anything. It is just there for his use.
- 14 :would view that-as something like margin that ought to be I 15' his -- he ought to be able to put - if he doesn't want it
-o '
16' 'anymore, he ought to be able to throw it out and he l'
17 cshouldn't have.to worry about it being in the design basis.
18- Ir"that the feeling --
11 9' MR. MAGRUDER: I think the Staff wou?.d agree with 20' -that also.
21 DR. KRESS: Okay.
L 22 DR. POWERS: I don't understand that.
(
L 23~ DR. KRESS: Well, I don't understand what the 24- problem is then.
'25 DR. POWERS: It seems to me they gave an answer
[ls; i,
s
\.
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P~ .
I' 383 l 1 that I wouldn't.have given.
V N '
2 DR. KRESS: Yes.
-( l' 3 DR. POWERS: Four systems and --
4 DR. KRESS: And'you only need two --
ST DR. POWERS: -- and you only needed two, but it l
6- .seems to me your design basis would still have all four 7 described'.
LB- MR ., MATTHEWS: The Staff would agree with you.
l i 9 The design basis would still include all four systems. The I 10 design basis can be altered. This isn't inalterable, but it
- ll- is the design basis for whatever reason.
-12 DR. SEALE: In order to meet the two out of four 13 requirement all four systems have to be of a certain l-14 qualify. They have to meet the design basis. .
() 15 DR. POWERS: You have got a two out of three 16 requirement but you put in four. I still think you need to i I i
17 have all four.
]
l 18 DR. SEALE: That's right, because all -- the two 19 -that are there at the time have to meet the requirement.
l 20- MR. MATTHEWS: Because whichever two they might 21 be , and they.may be any of the four,.so --
22 DR. KRESS: Right.
l 23- DR. UHRIG: The issue that came up originally was 24' not design basis. It was tech specs.
25 DR. BONACA: We are confusing the things. ,
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m 384 1 DR. UHRIG: That is why I was wondering whether
- p. .
lT 2 .this implied tech spec --
V 3 MR. BARTON: Don't confuse the issue here.
4: MR. MAGRUDER: No.
5 MR. MATTHEWS: No. It does not also afford an
'6 opportunity for discussion of-what treatment rules need to
- 7. be applied. It is a question ~of what the design basis is 8 and then your treatment rules deal with that design basis --
L9 excuse me. I am David Matthews, Director of the Regulatory 10 Impro. ament Programs.
11 I wanted to add that although we characterized it 12 that the Staff views it this way, or the Staff is of the 13 opinion, that is clearly how we articulate it, but we view 14 the positions we.have expressed as deriving from the
(). 15 definition that we put_up on the board. That is why we 16 continue to go back to that.
17 We take reliance on these interpretations out of
~18 'words like " specific function" and ranges of values and 19 controlling parameters.
-20 Those are-the bases for us-establishing these 21, positions. It is not just a question of our preference or
'22 . what we would like to see. We think that is what the 23 regulation has directed us to identify is design bases.
24 I think Stew did a good job of clarifying that, 25 but we are sometimes cast into the vernacular of speaking as
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385 1- if it's!just a staff ; ,eference. It's really not a staff
- 2. preference'in this instance., it is-a staff interpretation of M(#~).
3 .w hat the regulations require.
4 I. wanted to add another comment that we have gone
-5 hammer and tong'on some of these issues, as you might
'6 expect, and we have not reached consensus on all issues, 7 although I think, as was'also commented on, we have come to 8 closure on many, many issues, like a lot of the regulatory 9 process issues we've been discussing over the last couple
'10 - years with all of you, 50.59 and issues related to FSAR 11 updating, there was a lot of areas that needed 12 clarification. So I think we have come to closure on a lot 13 of those areas. And we're continuing to work, and we do
-14 have a goal of endorsement.
() 15 And as Stew also mentioned, ACRS input on these 16 specific points, given the breadth of your experience in 17 -this. area, would be appreciated. But we are committed to
~18 generate a draft reg guide for Commission consideration by
-19 the end of October. We have not decided at this juncture to 20 go forward with_a separate guide. The significance of the 21- remaining discrepancies, as we meet once again in the n.
22 future with.NEI, may warrant'such a separate guide, and .i 23 that regard Dr. Barton and I appreciate that there's a point 24: where you have to make that go/no go decision or you end up 25 with;a questionable -- a document of questionable utility. j l
l
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E 386 1- . MR . '. BARTON : Right.
i 2 MR. MATTHEWS:
[ In-all.our activities of the last
- 3. -few years in bringing to_ closure some'of.these issues, we
'4- .have tried to'look for.the; practical impact of our. outcomes I
5 -- with regard to what. Sam Coll. ins likes to refer to as at the 6- -interface, which is clearly.on the plant floor and in the 7_ interactions at the. staff and licensee level. So, you know, 8 'if it isn't going to work there, there's_probably very
'9 little utility in generating such a reg guide. So we want 10 that to be the ultimate test wit-h regard' to whether we would 11 go with a. separate guide or utilize the NEI document with a
'12 limited number of exceptions that might be warranted and
= 13 '- appropriate.
l 14 Upcoming management review of this issue is going
! 15 to be continuing through October as we progress. So, you 16- 'know, we do not have the final answer on this yet, but we 17 will'look forward to facilitate or inform that process.
l ~18 DR. POWERS: I guess that brings us to the l l
19 _-question that's uppermost in my mind right now, what is it L '20 that we're going to produce?
21- MR. BARTON: We're going to produce a letter.
22 DR. POWERS: 'We don't have enough information to
- 23' -produce a letter, I don't think. I don't even understand
(
I 24 .the discrepancies between the two positions based on these i 25 presentations.
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387 1 MR. BARTON: Well---
/ 'i 2 MR. PIETRANGELO: Can I add something? I think I b' 3. can help Dr. Powers on that last one.
4 Tony.Pietrangelo, NEI. The issue you just went 5 through on the redundancy and diversity, I mean, if we're 6 going to be convinced that the number of pumps or trains or 7 whatever is a specific value or range of values chosen for 8 controlling parameters with reference bounds for design, 9 fine. Call it design basis.
10 I don't think that's the most significant issue.
11 It really doesn't have any practical impact on anything in 12 the field in terms of calling the number of trains design 13 basis or not. So that one I'm less concerned about, because 14 again it doesn't have any practical impect. The big one for (O) s/
15 me is the one that Russ went over on whether the design 16 pressure of the piping is part of the design basis.
17 MR. BARTON: The design basis values argument.
18 MR. PIETRANGELO: That's right. That's right. We 19 think that's a step beyond what's required by regulation or 20 the function credited in the safety analysis. If we found a 21 design discrepancy in the piping, we wouldn i t be able to 22 make a call at the outset of whether you're inside or 23 outside the design basis of the plant. If the staff in the 24 staff view of choosing 1,500 pounds is the design basis 25 pressure, you're already outside the design basis of the
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388 L 1- plant. We would have~to evaluate _it and look at things like F -
' /
2 relief values and overspeed trip settings and what you
- Q) _
- 3. , pressurize the header to and what that does-to flow to see
~4 if-we met the 500 GPM at 1,200 pounds which you've got SL credited in the safety analysis. But by going one step down 6 to things that I use to assure myself that the' actual 7 function will be achieved, that's different than the 50.2 8 value.
9 That's our point. And that's what I think is the 1011 big difference between the two! positions. We think we can i 11 appropriately bound the 50.2 definition using our general 12 and specific guidance. But the exception the staff took on 13 this design pressure one would make it practically 14 unbounded.
t (f. 15 I don't know -- and what really raised this issue,
- 06 and most of you are probably aware of it -- was this Niagara 17 Mohawk blowout panel issue where a bolt was missed on the 18 blowout _ panel, and the lift pressure went from 45 PSF to 55
-19 PSF. It was designed to -- for the integrity of the
- 20. secondary building, which was 80 pounds. So it still met 21- its design basis function, yet that was called outside the 22 _ design basis of the plant, one hour reporting, and even in 23 the. discussion between the licensee and the NRC, the 24- position in the NRC letter was that design basis was 25 anything the staff relied on to approve the design, quote I
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p
! 389
'1 unquote. And that's really what we've been up against the
.2 last year,..trying to struggle with and get a bounded, 3 accurate. description of.
4 So that's what's at stake here, and I hope that
'S helps you, Dr. Powers, on what the issue is that we're 6 trying to; address. But the redundancy / diversity thing, I
'7 mean, again, we can go either way on that. I think the 8' other two are.also less.important. We've already put normal 9- operations in our' definitions. We don't think testing and 10 inspection are really 50.2 functions. But it's really the 11 first issue on where you draw the.line from design to design 12 basis'that has'the most-impact.
13 DR. KRESS: Are we necessarily stuck with this 14' 50.2 definition, because that seems to me like the problem.
(_j 15 Everytime I' read it, I read something else into it, and it's 16' -awfully hard --
17 MR. PIETRANGELO: Well, at this point I think we 18 a r e ,: Dr. Kress.
(19 DR. KRESS: We are stuck with it; okay.
20 MR. MATTHEWS: Notic,e my white knuckles gripping 21 the. table.
22 Let me simpl3 ans-ci yes, I think we are, unless 231 we were to demonstrate or somebody were to come to us and 24 demonstrate that it.isn't serving a useful purpose.
25- MR. BARTON: .Does that help you clarify -- 1 l
l
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390 1 DR. POWERS: I'm appalled at how little I can I~' 2 understand what the differences in the positions are. I l.
3 mean, it's just not laid out in the way I can see that -- I i
4 seem to have a pretty good layout of the staff's position on l 1
5 some things that apparently are the questions. I just don't
, 6 understand where the other people are coming from.
7 DR. SEALE: It's very ecclesiastic, isn't it? I 8 DR. POWERS: No. It's not that either. It's just 9 confusing.
10 If we're going to write'something on this, maybe 11 we should walk back through Mr. Magruder's presentation of !
12 positions and understand where the difference is. Right now 13 quite frankly do not understand this.
14 MR. MAGRUDER: We can certainly do that, or we can (O) 15 try that, Dr. Powers.
16 DR. POWERS: Well, I've got a problem. I've got i 17 another six speakers coming today. j 18 MR. BARTON: You've got 15 minutes.
19 DR. POWERS: And you guys just have not given me a 20 presentation that I can write anything on.
21 MR. MAGRUDER: Okay.
22 MR. BARTON: You've got 15 minutes to try and do 23 it, and I wouldn't spend much time on the testing --
24 MR. MAGRUDER: No.
25 MR. BELL: I'd spend most of the time on the t
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g-391
[. ,
1'. design basis --
U p i
MR. MAGRUDER: Let's.try to do the design basis 3; values'again.
4 MR. ' BARTON:: Design basis value is the biggie.
'5 'MR. MAGRUDER: The first point I think from the 6 definition is that"the definition talks about specific
- 7. functions to be performed. It doesn'.t say only active l Et .functionsfor only passive functions. It.just says 9' functions, i ,
10 <
DR. KRESS: -Is there any disagreement there? You 11- guys agree that passive and active are part of the design 12 . basis? So that's not an area of disagreement, that first --
13 DR. POWERS: You see, I'm already getting into 14 trouble. These are the ones that I thought were the (O) 15- problems. And-now they're not problems.
16 MR. MATTHEWS: .Could I maybe -- let's try an 17 illustrative example to try to bring focus,to it. We would 18, use -- forgive me:for this, Russ -- your handout, which is 19 'the one onfauxiliary;feedwater system, and go to the page 20 which NEI has~ entitled " Examples of Auxiliary Feedwater
~
~21 Systems Supporting Design Information." That would be --
22 it's page 11.
23 MR.'MAGRUDER: Yes.
24 RHR. MATTHEWS: And what I'm going to suggest is 25 that the three bullets on page 11, if you're all there, all l
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392 1 three'of those would be statements which in the staff's view 2- should be viewed as' falling within the definition of design-
[~)T' 3 ' basis andL treated that way in the FSAR.- And all three of 4 them, just' happenstance they demonstrate the three principal 5: -areas'that the staff is concerned about.
.6 The firstione addresses the specificity that'the 7 staff. believes the definition calls for in terms of specific 8 functions, and addresses the issue of redundancy,and 9 diversity. .The second one addresses the' issue of the 10 staff's concern that design bases aren't confined to mode or 11 ' conditions such as normal, accident, off normal. And the 12 third one relates to the design basis values that the staff 13 views as being design basis information,.such as piping 14 design pressure, temperature. So, you know, as an 15 illustrative example.--
16 DR. POWERS: No,.it's not an illustrative example 17 of anything.
18 -MR. MATTHEWS: Well, the staff --
19 DR. POWERS: It's a set of issues. What do you 20 disagree with him on?
21 MR ., MATTHEWS: Are you asking that question of 22 NEI?-
23 DR. POWERS: Yes. ;
24 MR. MATTHEWS: Okay.
I 25 MR. BELL: I think as Tony indicated, the first
. l
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I r 393 g
- j. l' one is the redundancy / diversity-issue, and in terms of its p4 f '2 practical impact, it's.probably very little. And I think l :3 his-words were we can!go either way on that. We have 4- 'another meeting scheduled to resolve these.
5 The second-one, these.are legitimate uses of the 6 aux--feed' water pumps. However, they are not the functions 7' credited;iti the: safety analyses,for that system, nor would I
- 8 . expect that they be the source'of. bounding or reference 9L . values.for the design.of'that system. In other words,.the 10' accident' demand on.the AFW'I would expect to drive the 11- design, because.it's the most limiting.
-12 So the fact =that its used during these other L13 modes is part of the design, not part of the design bases.
14 To include these would violate one of the principles, that 15- 'being the tie to the safety analyses, and the reference 16 . bounds for design.
17 DR. POWERS: So what you're saying is these ;
18.1 ' functions,'the auxiliary feedwater system, are not the i i
19 limiting. function for:that. j i
20 MR. BELL: I would expect not. I'm not a 21' designer, .but -- ;
22' DR. POWERS: Out of-hypothesis. Hypothetically --
' 23- MR. PIETRANGELO: For example, Dr. Powers --
24 DR. POWERS: Hypothetically, they are not.
25 MR. PIETRANGELO: You could use an aux feed 9 ANN RILEY & ASFOCIATES, LTD.
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F, 394
, 1 system --
i
- 2 DR. POWERS
- No,.I'm trying to understand.
l .3 MR. PIETRANGELO: Okay.
l 4- DR. POWERS: We'll say hypothetically they're not.
5 There is other' function performed by the AFW that you really l
6 think.is really the limiting design, taxes it the most. So 7 it's-justLan omission on their part.
8 MR. PIETRANGELO: An omission on --
9 -DR. POWERS: The guy that wrote this just left out 10 one of the functions 11 MR. BELL: No. No. In fact, the safety or the 1
12 design-basis function of this system is of course the one, l
13 you know, in the table a couple pages back. This is the
-14 function credited in the safety analyses that upon loss of
) 15 -- main feedwater, he needs to provide for heat removal from i
j 16- the_ core. These other functions -- so this -- so you would
- 17. not list tluit function back here. These are other functions 18l 'that might be performed by the AFW pump. Okay.
19_ MR. PIETRANGELO: For example, on startup a lot of 20 people feed their stean generators with aux feedwater pumps, 21 -particularly if they' don't have a startup feedwater pump.
1
- 22. But that's not part of the safety analyses that the staff J
23 goes through on this. That's just nice to have that was l 24 . built into the system.
, 25. That function we don't think -- although we do say l I
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e 395 1 in our general and specific guidance that normal -- you
-[^)
%)
2' should consider normal operations as being a potential for 3 being the bounding condition, and on the fuel, that's 4 probably correct.
5 MR.'BARTON: But for a plant that doesn't have a 6 startup feedwater pump, this auxiliary feedwater pump is 7 part of the design basis for that plant, right?
8 MR. PIETRANGELO: No.
9 MR. BARTON: No?
10 MR. PIETRANGELO: The function -- not by our --
11 the principles that we laid out. That function is not 12: required by the regulation and it's not credited in the 13 safety analysis.
14 DR. SEALE: Is it required to run the plant?
.() 15 DR. BONACA: Because in the safety analysis you 16 .have it only as a backup to the loss of feedwater or 17 feedwater line break. That's the point they are making. J 18 MR. SIEBER: But I'm not exactly sure what the 19 harm is in listing it as one of the design basis, because 20 you actually do have to design it to run in, for example, 21- the startup mode. I mean, it just doesn't happen to work 22 out that way if it's designed just for loss of main feed.
23 MR. BELL: Now you are into -- you've -- l 24 MR ,. PIETRANGELO: Should I do a one-hour report to 1
25 the NRC if I can't feed with -- starting up with the aux i
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_ __ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ _ _ _ _ = _ _ _ - _ _ _ - _ _ _ _ _ - __ ______ _ _ _ _ _ _ _ _
-l '396 1-- !feedwater pump?-
[)
v 2 MR.-BARTON: I see where your problem is, but I 3 don'tlknow how-to resolve it. . Your problem is there are
'4' :always going to be on'one-hour reports always outside the Si design basis:--
6 MR. SIEBER: If it doesn't work and you can't
~7 start it up, then'you don't start'up.
8- DR. BONACA: Right.
9 .R. PIETRANGELO:
M What safety issue? Why should 10 the NRC get involved with that aspect of it?'
=11 : MR. MATTHEWS: The staff's of the view that the 12- reporting issue'is separate from this issue.
- 13. MR. MAGRUDER: Right.
14- MR. MATTHEWS: .The regulations that exist today do
)" 15 have these issues crossing-because of the definition of 16 ~ reporting requirements being tied to whether you're inside 17 or outside design basis, but we have proposed a rule that 18 would --
19 DR. SEALE: Separate those two.
20 MR. MATTHEWS: Separate those two issues.
21 So the reporting issue is not the one that --
22 MR. BARTON: All right, Tony, what's left?
23 MR.'PIETRANGELO: What's left is -- even'though 24 the reportability aspect is gone -- and Dr. Bonaca would 25 _probably know this better than anyone up here -- how many 1
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h 397 t
1 plants have gone through this design basis issue, okay? We I"Y 2 . find a' lot of discrepancies when you go through design basis 3 reconctitution programs. A lot of them are paper, a lot of
(
c4 them are in the field, and a lot of them have to get l 5 evaluated. We've lost quite a number of plants in the-last 6 couple of years spending a lot of money trying to address
,7- this issue. And that's why we put in our letter about the EL characterization of what the design discrepancy is.
9 When you say a plant doesn't meet its design 10 basis, that ought to mean something significant, not that
.11 you can't feed, you know, to start up with your aux 12 'feedwater pump, it ought to mean something like you can't 13 -place the plant in a safe condition following an accident.
'. 14 That's what we're talking about here. And that's the danger
()
15 of trying to say a lot of these bullets on the left here
.16 are, you know, part of the 50.2 design basis.
17 MR. BARTON: But some of --
18 MR. PIETRANGELO: So it's beyond reporting, it's a j 19 characterization issue also.
20 DR. BONACA: Let me just go back again. If you go i
21' back to the original design, it's because -- one of the ;
i 12 2 unfortunate things, that on one side we have the industry, j 23- the other one we have the regulators But the guys who 24 designed these plants, wrote the book on how you do it are 25 not here. But if you go to the book, having read it, it :
i
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398 1 .doesn't'say anything about these conditions for the
/I 2' auxiliary system, because design of the system was for the V
3 most limiting conditions, which is full power, and we assume
~
4 'if you' lose all feedwater -- or you have a feedwater line 5 break, which case is more limiting, and from that you derive 6L limiting conditions going to the design of the system.
7 Some of those are relegated to design basis, 8 because they have regulatory significance.. But the point is 9 .that -- so I can understand why, you know, someone's 10 definition -- I mean, some of this may define expectations i
11 of the systems for which there is no basis anywhere at the )
i 12' site. I mean, because it was never evaluated under these l
13 conditions. It had no limiting. You use it as a system, i 14~ but there is no basis.
() 15 MR. SIEBER: .I guess your argument stretches right 13 back to the definition in the next to the last line. It l 17 talks about postulated accidents as opposed to any other j 18 form of operation. ;
19 MR. PIETRANGELO: Although we're not excluding.
20 If normal operation happens to be the bounding condition for l
21 the thing, fine.
22 MR. SIEBER: Like the fuel.
23 MR. PIETRANGELO: Like the fuel. Exactly.
- 24 MR. SIEBER
- I' understand.
25 MR. PIETRANGELO: All right.
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ry 399 y 1_ DR. POWERS: I think we've got a problem here I i
'oh ~2-
'3L don't think we cantwrite a letter.
MR. PIETRANGELO: You can copy our letter. 1 4 MR. BARTON: Well, where do you want to go from l 5: here? We've got~five, minutes.
6 DR. POWERS: Yes. I mean, it seems to me that the l.
- i. 7 . situation is they're not done with their deliberations, and 18 they certainly have not toned down the differences in 9 opinion closely.enough.for me to understand them. If these 10 are-the ones, the' slides.related to the. staff positions,
' 11 ' then I find out every other one of them the NEI'didn't have 12 any troubles with. I d.on't know which ones they have 13 troubles with and which.ones they don't.
- 14. MR. BARTON: Well, I think we're down to the
.15. design values as the issue that we can't seem to get closure 16 on.
17 DR.1 POWERS: So you're saying that out of all of 18 this, the only thing that we have to worry about is the 19 . design basis could include values that are code inputs and 20- values associated with function, assure the SSC's will 21 perform the required function. That's it? That's the only 22 ' difference in opinion here?
23 DR. BONACA: That's the one that --
24 .MR. BARTON.: Yes, I think so.
25 DR. BONACA: Dr. Pietrangelo said was the --
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400 li MR. BARTON: I'think between now and the end of f 2 October the staff and the NEI will come to some closure on
- L-
~
'3- 'the'other.three> issues. That's what.I heard here, 4 between -- I heard NEI and Dave Matthews describing. I 5 think'those three will:come to a mutual resolution by which 6 you can'take the reg guide and endorse the NEI: document. I 7: have not heard the path to resolution on the design basis 8 values question.
9 DR. BONACA: Let me ask a question to see if he 10- -clarifies it. It will take just.about ten seconds,- and he 11 fcan' provide an answer.
12 Now if I understand it -- let's take the example 13 of the third bullet, system design pressure is excess PSI in 14 temperatures dot dot' dot. That has to do with -- say that pj -15 you'have a-pipe for which you have a commitment in the FSAR 16- -to pass say' steam, and you have a certain pressure for 1,000
- 17. PSI,.okay? And certain temperature. There are limits for 18 those two values that you use in the design. I mean, that 19 .you have to deliver in an accident analysis or whatever.
- 20. Now you go out and get pipe that-is capable of
-21 2000-psi'and twice as high a temperature as that. Is the 22L position of the NRC that now you are bound to have 2000 psi 23 and'I mean.what was procured,-is it what you would consider 24 'your_ design basis-~for the pipe, the procurement values, or L25 the process parameters that is described with the 1000 psi l
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1
r 401 1 and the temperature?
[~)
V 2 MR. WESSMAN: Let me try and help out, Stu. This 3 is Dick Wessman from the Division of Engineering.
4 No, I don't think the Staff is looking at things 5 like procurement values. I think we are looking at things 6 that develop margin to support that function, and so the 7 concept of it has to be able -- the function is 1200 psi and 8 the Staff would view as a design basis value that there 9 is -- the margin that gets you the 1500 pound pipe, and then 10 the designer buys whatever the right code is that gets that 11 margin.
12 I think we tend to think the same way in the area 13 of cumulative usage factor. That would be to us a design 14 basis value and, yes, if the licensee discovers that they
()' 15 have exceeded the CUF of one, they would be outside the 16 design basis and they would need to report it to us. It may 17 mean that the analysis is detailed analysis or some other 18 analysis determines that no, they are not really outside of 19 1.0, or they really are, and yes, they must make a 20 replacement, but these are the type of numbers that provide 21 this margin that I think where we on the Staff think they 22 are essential in reaching that decision on a design basis.
23 DR. BONACA: So essentially it would be a process 24 parameter times some factor that you have for ASME codes or 25 whatever that is a standard process?
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1 MR..WESSMAN: Yes. I
[' )
.q) 2 DR. BONACA: 'Which is not a procurement value but 3- it is somewhere below?
4 MR. WESSMAN: We are seeking that assurance of 5 margin we think fits within this overall concept of 6 controlling parameter. Obviously NEI and the_ Staff are not 7 in agreement on this or we wouldn't be having this 8 discussion.
9 DR. BONACA: And NEI would propose what?
10 MR. WESSMAN: NEI would propose -- I am speaking 11 for Russ -- that the bounding value of just 1200 psi and x 12 flow is all that is necessary, .and we are seeking that 13 margin on it.
14 DR. SHACK: If I go to the NEI guidance document, ;
,~s !
(j '15 is it this last phrase in the definition of design basis 16 values that causes the problems?
- 17. MR. BARTON: What page are you on?
18 DR. SHACK: I am on page 1 of the draft guidance 19 of Appendix B, and they are defining design basis values.
20 Do you guys want to put a period after " standard 21 or guidance document"? Would that make you happy?
22 MR. BELL: How would that change the meaning?
23 DR. SHACK: It is just that the values then would 24 be-set by the safety analyses from the code, the standard or 7
25 guidance document. As I understand it, you guys then want
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403 l 1. to restrict that to only.those values which are necessary to j 2= meet the' design basis functional requirement as in Chapter 3- 15.
4 MR. WESSMAN: I think we get closer with the 5 period, but I think we have to sit and think about it a 6 little bit and again discuss it with NEI. I mean this has 7 .been an ongoing struggle and this has gone on in quite a 8 succession of meetings.
i l 9 MR. BELL: I would have just added to Dick's 10 answer, which I appreciate, you are right. We would choose 11 the process parameters and we would say that the design
'12 provides the. margin to assure performance and design basis 13 functions, so when'we identify design bases I am not sure --
14- you know,. margin does not come into it, except that design l) 15- bases values themselves have margin. We are not on the 16 ragged edge when we say 500 GPM at 1200 psi.
17 UR. KRESS: I think that is where the problem is.
L '18 We've got all sorts of marginc floating around.
19 MR. BELL: Yes. That word almost doesn't come up 20 in'our meetings and I think that is appropriate.
21 Our view is the design is -- you prov'oe a robust 22- design to assure that you perform those design basis --
l '23 DR. KRESS: You should put the margins in your 24 value in the first place.and not say, well, we are going to 25- .put a value but we are going to come in lower to get margin.
1 l
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l 404 1 You should have the margin built in there in the first
,- m 2 place.
(v) .
3 MR. MAGRUDER: Right -- and the licensee 4 chooses --
5 DR. KRESS: And then we wouldn't have this 6 argument. l 7 MR. MAGRUDER: Right "bu icaff agrees. The 8 licensee chooses whatever margin they want. I mean it is l
9 . based on code guidance in a lot of cases, but whatever the 10 licensee picks as their design value we believe is the i
11 design bases because it controls not only that piping but it 12 controls the design of the rest of the system and other 13 interfacing systems too, so that is why we feel that value
- 14. is critical.
/
'(_,% ) 15 DR. BONACA: But there are always two values 16 because there is one from the analysis that says 1000 psi 17 and then there is the one that the DAE implements, the 8 in 18 1000. He went back to some kind of guidance from the ASME 1
35' code and said apply 10 percent or apply 20 percent and then j i , that was the value to each measure. Now then he got 21 something that was more capable than that so he can get 22 that, so the question is -- there are three values and the I 23 question is which one do you pick.
24 It seems to me that you are at both ends of that 25 spectrum. One say7 the process parameter, one says I don't j i
1 1,
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1 405 L l' know what --
f.
l 2 MR.'MAGRUDER: Well, we'd take the middle one, I 3 think.
l 4 DR. BONACA: --
so there is some confusion.
5 MR. MAGRUDER: To choose other than the process 6 parameter you are sacrificing the principle about the tie to 7 the safety analyses. It is only the process variables that 18 come from there.
9 MR. PIETRANGELO: It might be licensing basis --
10 DR. KRESS: We can hear you but he can't.
11 14R. PIETRANGELO: It is not that those other 12 values aren't important and it's not that they are not 13 described in the SAR. Most of that is described in the SAR, 14 but it is different from what is credited in the safety
() 15' . analysis. We are trying to make 50.2 in the context of 16 nuclear safety focus on fission product barrier integrity.
17- We went through this whole discussion last year on 18 50.59 and I think we came down the right way when we came 19 through that discussion. We think that the guides we put j20 together on design basis is consistent with that 50.59 21 guidance, okay? -- and again, just because it is not 50.2 22 doesn't mean.it is outside the licensing basis. In fact, 23- most of this stuff is, but it is in terms of how do you 12 4 = : appropriately bound that term and characterize issues that 25 come.up in the field that matter.or are of concern to us.
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(
L 406 l' DR. KRESS: And George, this has nothing to do 2 with the PRA.
3 MR. PIETRANGELO: Yet.
4 DR. POWERS: .I am coming to wish the PRA did have something to do-with it.
l 6' [ Laughter.]
1 7 DR.-POWERS: I:think that we are going to have to 8 move on.
l 9 MR. BARTON: Any other questions?
10 [No response.]
i 11-MR. BARTON: I thank the Staff and NEI for their 12' insights and opinion, et cetera, et cetera' . .Thank you.
13 I will~ turn it back to the Chairman.
14 DR. POWERS: The next topic we are going to deal
() 15 - with is the proposed resolution to Generic Safety Issue 16 B-55, improved reliability of Target Rock safety relief 17- valves.
18 Jack, you are going to take us on this one?
19 DR. SIEBER: Yes, sir.
20 For your information, the information that was 21 provided to the committee _was developed by the Staff and is 22 in Tab 16'of the black book. We also got a copy of that in 23 the mail, I believe, and actually this is a pretty old 24 issue.
25 The-first occurrence of this occurred in the 19'i0s
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i 1
407 l
11 and'was described in NUREG-0462 in June of 1978. By my
/TL 2 count, and this may be different than yours, there's 22 O
3 older BWRs.affected and it includes 166 safety or power 4 operated relief valves, all power -- pilot operator relief 5 . valves built by the Target Rock Company.
6 I am aware of at least one PWR that has the same 7- kind'of valve that did not have the same kind of problems.
8 The early valves in about half of those plants were 9 three-sta'ge valves and in'the later ones were two-stage 10- valves, and the' problems thet existed at the time were 11 . spurious opening with excessive blowdown, failure to open at 12 the set point -- in other words, the pressure went beyond 13 the set point.before it opened, and sometimes accompanied by
.14- excessive blowdown, a third problem was that it opened
,() .15 properly at the set point or within the tolerance of the set 16 point but failed to reseat after blowdown, or lastly 17 excessive leakage. i c18 It . turns out that the older three-stage valves do 19 not have the set point drift, they don't exhibit that to the 20- extent that the two-stage valves will do. .
21 During this session the Staff will describe and 22 -discuss the issue, fixes, repairs, remediation, actually l 23 greater tolerance on the setting of the set point and the 1r l 24 . current status-of this valve issue with the intent to try to 1
! 25' close out'this Generic Safety Issue. I am sure they would l O ANN RILEY.'& ASSOCIATES, LTD.
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I 408 l' like to do that today, at least with us, but I think that t
[~')
v 2 have a little bit more additional time should we need to 3 consider that,- but-certainly by the end of the year it would 4 be appropriate to meet their goals.
5 So I would like to introduce the Staff members.
6 Could you introduce yourselves and begin your presentation, 7 please.
8 MR. HAMMER: Thank you. Yes, my name is Gary 9 Hammer. I am in the Office of NRR. I have with me my 10 supervisor, David Terao, and there are several other NRR I 11 Staff here as well as Research, who can help me if you have 1 12 questions.
13 At you mentioned, this is an old issue. You can 14 tell that by the nomenclature, the B-dash and the 55. They f7 t
v) 15 don't use that designation anymore for generic issues.
16 DR. WALLIS: They must be very old, i 1
17 MR. HAMMER: Yes, I think the B-dash designation j 18 comes around the TMI. time period, the late '70s.
19 DR. WALLIS: Most things that have the new 20 nomenclature are pretty old too.
21 [ Laughter.]
22 DR. SEALE: They are mature, Graham.
23 DR. WALLIS: I wish I were.
24 MR. HAMMER: On BWRs safety relief values -- this 25 is just a real quick background -- are required for ANN RILEY & ASSOCIATES, LTD.
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409
- 1 basically.two functions. One is overpressure protection and
~
'( 2f the.other is the ADS function, which is a part of the
~3' emergency core cooling for a BWR.
- 4 lThe Target Rock valves are pilot-operated valves u 4 5 with. auxiliary actuators that are pneumatically powered.
6 The original design was the three-stage design and 7 the two-stage design was developed a little later. Page 4 8 of yourfslides has these illustrations.
9 You can see there is-the main stage which has a 1 10 big: piston and a disk that controls the main flow stream in all both of them. One of these is shown at a right angle. It
.12 is' supposed to be the other way, but anyway, for ;
i 13 illustration purposes, and here on-the top of the valve is the air diaphragm actuator that is controlled by solenoid n)
( 15l . valves so that'you can actuate the valves with external 16- power regardless of what the system pressure is. That is 17 basically -- let's see. Okay. Let's go back. I am not i
<18- Equite finished with that. slide. I i'
'1!L ~Just as general' statistics there are 11 BWRs that 20: ' currently have the three stage valves; aleo, 11 have the 21- two-stage valves.
22 DR. SHACK: Of the 11 with the two stage valves, 23 how many of-them have~always had three stage valves? Are l 24 these'the original valves? l L l
, '25 MR. HAMMER: I believe that is true, except for l
)
l l
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rt 410 ,
J 1 Limerick Units 1 and 2, which recently installed -- l
']
a 2 EDR . SHACK: So it is nine out of the 11 are sort 3 of original?
4 MR. HAMMER: That's correct. Now there are some 5 BWRs which are no longer operating, like Shoreham, Millstone 6 and Browns Ferry 1, which also had Target Rock valves. I 7 think those were all two stage plants.
8 The newer plants have a little different design.
9 That is shown on page six of your slides, just for 10 interesting background information. This is what they look 11 -like. They are much, much more massive than the l
12 pilot-operated valves. They have very large bonnets and '
13 spring mechanisms.
14 The pressure basically has to overcome the spring (n) 15 force in order to open. There is no pilot involved and they 16 also have the pneumatic actuators that physically compress 17 this big spring, so those are quite a bit different in 18 design.
I 19 As mentioned earlier, there were several three 20 stage inadvertent blowdowns back in the 1970s, which were 21 most troublesome and basically when that happens you have an i 22 uncontrolled blowdown into the suppression pool, which l 23 causes the plant to be shut down.
24 You basically have a small break LOCA that you are i
L 25 trying to manage, heating up the pool. It was fairly l
I
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p 411
'l undesirable. It'is.not something that can't be coped with,
- ()
l-2 with the.available safety. equipment, but nevertheless it was j 3- something that the industry wanted to remedy, and they 4 designed the'two. stage valve as a modification for.that.
5 What they did is they essentially replaced the top 6- works, which is this part of the valve. This is a blowup.of
'7 ijust the. pilot stage of that.other valve that I showed you a 8 moment ago.
9 And what,happens is this parting line here where 10 these bolts are bolted to this flange, basically you just 11 hook the old three-stage actuating mechanism off and put on 12- the new two-stage, and what they eliminated was basically a 13 -second stage, i.e., now it's only two, a pilot and a main, 14 instead of having-an' intermediate which -- and it was this
() 15 intermediate stage being~ actuated.that was causing the
- 16; blowdown problem. So essentially they cured that problem 17: with this particular fix. .There began to be problems with 18 the two-stage design, though, and --
19 DR. WALLIS: You've turned it around or something?
j 20 MR. HAMMER: Beg your pardon?
21 DR. WALLIS: Turned it around. The three-stage l 22 doesn't look like your picture, that's all. You say you 23 fixed the three-stage by making it a two-stage.
24: -MR. HAMMER: Oh, okay. Go back to -- l 25' DR. WALLIS: I have to sort of mentally turn it i, ,
l'
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412 1- around to'do that.
O 2. MR. HAMMER: Yes.
b 3- DR. WALLIS: Yes.
4 MR. SIEBER: Yes.
5- MR. HAMMER: Yes. As I-mentioned, this is not 6 oriented correctly for illustrative purposes. It really
.7 should be turned 90 degrees to the right.
8 MR. BARTON: Then you have to turn your head to 9 read the writing. l
~ 10. MR. SIEBER: Yes.
11 DR. UHRIG: Is there an error in this footnote on 12 page 7.about Limerick? This is opposite to what I 13 understood you said.
14 MR. HAMMER: -Oh, I'm sorry. Maybe I did say it
() 15/ wrong. LThey'have had two-stage valves since their initial 16 startup, but recently installed three-stage valves.
17 DR. UHRIG: Which is going the wrong way.
18 MR. HAMMER: Well, it turns out the three-stage l
.19 valve has had better performance, so they've gone back to a l 20' previously known quantity and they've had success with it at
! 21 .another plant, and --
l 22 DR. UHRIG: I must have misunderstood you. I'm l'
E 23; sorry. ' Okay. -
24 MR. HAMMER: Yes. Yes, you're right, it is going ls 25 in the'other direction.
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413 1 DR. UHRIG: So the three is really the better --
( '2 MR. HAMMER: It has turned out to be the better.
-3 DR. WALLIS: It has been replaced by a two-stage?
4 MR. HAMMER: Can you repeat that? 1 5 DR. WALLIS: It has been replaced by a two-stage?
6 The picture that you showed us with the color, 7 which I'm not sure is in here.
- 8. MR. HAMMER: Okay.
9 DR. WALLIS: That was used to replace the 10- three-stage?
Il MR. HAMMER: This was the two-stage design, which 12 is basically the top works that couple onto-the old 13 three-stage' body.
14 DR. SHACK: Yes, they replaced the three-stage in 15 some plants with two stages. 'It was-a fix.
16 MR. HAMMER: Right.
17 - DR. WALLIS: But it was not a good fix, because 18 the three-stage is really better. Is that what I'm hearing?
19 DR. SHACK: All fixes are not good fixes. We ;
20 couldn't say-.
l l
- 21 MR. SIEBER: Well, they solved one problem and !
22 bought into another one. !
23' MR. HAMMER: Right.
L L , 24' DR. SHACK: I guess that was my question. What 25l did they do for the three stages to fix the blowdown problem
-p -
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g 414 1 'that - when it didn't replace? Change the maintenance
( 2 procedures?
3' MR. HAMMER: .Yes. I'll get to that. Yes. They-4, started to have problems almost as soon as they put in the 5 .two-stage valves withisticking. They had quite the opposite 6 . problem. :They wouldn't open at the correct pressure, they
\
7 would stick, and'it had positive set point drift, and that 8 became troublesome as well. j 1
9 So some people, like I-noted a moment ago, there 10 were several plants that kept the three-stage design. For 4 l
Ell .those GE issued some recommendations to. raise the simmer
- 12. : margin, which is the. difference between the valve actuation 13 pressure and the operating pressure, and that made them less 14 prone to leak and to inadvertently blow down. They-also t
('%
'] )
i 15 improved the. maintenance procedures and the testing 16 frequency, and basically that has proved to be successful.
17 There have been very few blowdowns since those events in the
- 18. seventies.
- 19. But at the time the blowdowns were occurring, and l
20 shortly after that, into the early eighties, the staff 21 prioritized a generic issue to investigate the problem, see 22 how serious it was, and based on the three-stage concern of 23 the blowdown, the' increased LOCA situation, it was 24 .prioritized as medium. But at the same time you started 25 having these two-stage events were sticking, and that was I
i
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R' 415
~
1 also put into the. generic issue, and really that's the issue
() 2 3
that we're left-with today.
In a significant event which occurred in 1982 at l
.4 Hatch involved upward set-point' drift of all 11 valves, and 5~ that was troublesome to the staff.
-6 DR. UHRIG: Was it a common mode failure? I 7 MR. HAMMER: Yes, common mode failure. The 8 owners' group. formed not long after that, and they began to 9 investigate the. problem, and they contracted GE to develop a 10 resolution for the problem. I n ,9 8 4 , about a year later,-GE 11 issued their findings based on investigations of several 12 valves, taking them apart, doing some laboratory work. They 1 13 even did some analysis work to see how significant the 14 problem was, how much overpressure the system could s) f~%L ,
i '15 withstand and still have a safe system. .And they came up i 16 with.these findings.
4 17 They.found that at that time it looked like more 18 of the drift was coming from up in this area of the stem, 19 called the labyrinth seal area. This stem also has to lift 20 up in order for the pilot.to change position, and it looked 21 like they were getting some misalignment, poor clearances 22 and this' kind of thing, so they issued some recommendations 23 regarding that-to improve those measurements and i
24 . refurbishment when they were refurbished.
c25 As I mentioned, they did some analysis work, and ANN RILEY & ASSOCIATES, LTD.
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416 1 they were able to demonstrate that even with 10-percent
[T
- %,1 2 drift on all valves, you still had a significant amount of 3 margin. You could stay within the ASME allowable pressure 4 of 110 percent of the design pressure, even with that kind 5 of drift, which is a nice thing to be able to fall back on, 6 but you're still left with this issue of compliance, the j 7 valves don't meet their technical --
8 DR. WALLIS: I need to ask you, that margin would l 9 exist maybe for other reasons as well, so you've now eaten 10 it all up with this one cause. Drift has now eaten up all 11 the margin. If it's 10 percent and you've gone from 100 to 12 110, drift has now eaten up all the margin that may have 13 been there for some other reason as well.
14 DR. SHACK: No.
<~
(_,w) 15 DR. WALLIS: Am I misunderstanding?
i 16 DR. SHACK: All it is is he just wants to make l
l 17 sure he doesn't overpressurize his thing, and so this thing 18 has to lift before he overpressurizes the vessel, and all 19 he's saying is that even with this drift, he's still going 20 to relieve the vessel before it gets to its limit.
21 DR. WALLIS: Yes, but I think what he was then 1
22 saying was there isn't any margin left. It was 10 percent I i
23 before --
l-24 MR. SIEBER: You can't go any further.
25 DR. WALLIS: And now he's taken it all up with ANN RILEY & ASSOCIATES, LTD.
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417 L
l- 1 'this. drift. There's~no more margin left. Is that still L
j -2 true, what I said?
3- MR. HAMMER: Well, it depends on how you-define 4l . margins. By definition, you still have significant j 5- structural margin; even if you've reached the ASME limit, l
6 you're allowed to reach that for upset events. And so what 7 you're doing is getting closer'and closer to that limit.
8 MR. SIEBER: But the set point is set by tech 9; specs, the tolerance, right? The staff at one time for some p 10 plants -- from plus or minus 1 to plus or minus 3. I'm not 11 aware that they went any further than that. ;
12- DR. WALLIS: Percent?
'13 'MR. SIEBER: Percent.
14 MR. HAMMER: That's currently the situation. We t 15- have a --
16 MR. SIEBER: So if you have a profile of plants 17 that are regularly exceeding plus or minus 3 percent, my 18 memory is that you sent in an LER, listed the valves and the
.19 as-found-pressures, and sent them out to a shop, got them 20' refurbished, tested, put them back in the plant, and you 21' could do that refueling after refueling. How does the staff i 22- tend to cause further improvement or at least compliance 23 with the tech-spec?
24 MR. HAMMER: Right.
- 25 DR. SEALE
- What's the process? l l
l f
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7 l ; 418
~
1 -MR. HAMMER: Yes. The process of filing an LER,-
l
( 2 that's interesting, and the LER's I've been seeing on this f3 . issue address fairly well the corrective action part of it,
- 4~ which-is.something that's important. You don't want to just
'5' put them back in service having reset the set point and then 6 have this happen all over again. You want to have something 7 that's' going to make it better.
8 MR. SIEBER: Do you have data'that shows that the 9 ' number of exceedences of,the' set point is declining through i
11 0 the. years? This has been' going on for-20 years. Anything l 11 like that?
12 MR. HAMMER: Well,-yes, I was going to present the l i
13 data a little later.
14- MR. SIEBER: Okay.
- A) i!s 15 MR. HAMMER: I'll show you where --
16 MR. SIEBER: We can wait until you get to it.
17 Okay.
18 MR. HAMMER: Okay. Okay, there was one other 19- bullet there. After they issued this report identifying a j 20 labyrinth seal area as the primary area where this stiction 21 'was occurring, they started to see greater and greater 22 occurrence of disk sticking, and going back to the drawing l l .23 again, .w hat they were seeing when they would take the valves j 24' . apart and do microscopic examination,-they would see
~
25 corrosion in this conical seating area of the pilot disk, I I
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i
y 419
- .1 and they would do diagnostic tests to measure the force it
( f2 took to pull it out, and they found some significant
- l. 3 sticking in that area. So that became more and more the
~4 focus, and this was after the issuance of that report.
5 So -- well, I'll tell you what I need to do. Let 6 me show you that plants that have a three-stage valve. This 7 is what.they --' this is just some various statistical 8 information showing you the numbers of SRV's.
9 A lot of the three-stage plants rely primarily on
- 10. the regular spring safety valves for overpressure 11 protection. Some have a few power-actuated relief valves,
'12 and the SRV's are in this column. They're generally BWR 3's
-13 and 4's, with the exception of Limerick that we've recently 14 added-to this table. It's got a lot of valves. Two-stage O 15 (f plants'are generally BWR 4's, with the exception of Pilgrim,
-16 which is a little different design, and they have only, as 17 you see on the table here, four Jafety valves. So they were 18 the~ focus of GE's study in terms of a bounding situation.
19 If you're going to have a problem as a result of 20 sticking of valves, you would have the most effect on this 21 one-, because'you'd be affecting the overall relieving 22: capacity.the most. So -- and Pilgrim had had a significant 23- ? amount of sticking. So they -- so in.1984 they embarked on 24 an-interim solution. They put in a new disk design, 25 Stellite-21, that they felt would or should perform a little l
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'h 420 p
LU 1 better. EIt.shouldn't have the -- they thought it shouldn't 4
i b( ) 2 have.the' interactions of the? carbides that were in the disk
'3- microstructure right at the. seating area, and even though
, 4 you would get1the corrosion, these large carbide particles ia.
L would not interact _so negatively.
s 6E DR. KRESS: When.they made-this change, did they 7 ' develop -- when they made'this particular change, did they 8 develop a prototype of the new valve and stick it in a test 9 bed'and. test it-for quite a while, or did they just make.the 10 change and stick in the reactor?
11 MR. HAMMER: They -- well,.I!d have to refresh my 12 recollection about what exactly they did~do. We did get a 13 report from them about their investigation. !
l 11 4 - DR .' KRESS: Um-hum. I 15 MR. HAMMER: I think it involved some actual 16 ~ laboratory testing to measure the sticking forces and this
~17 kind'of thing. But as_I'll get into later a discussion 11 8 about how the owners' group and the industry really came to.
- 19. understand.the nature of this sticking problem a little 20 'better,.that they really didn't understand at this point in 21 time.
22 So what they did was they came up with this 23 j interim fix. At about the same time or a little after that 24' ;the staff encouraged the BWR owners' group to also pursue a l 25 permanent resolution, whether it would be to adopt Pilgrim's l
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421 1 interim resolution or to come up with a separate one, and 2 -along in 1985 they came up with a new disk material that
}
3 they wanted to try, a precipitation hardening stainless, pH 4 13.8 MO, which they felt like would not corrode in this
7 DR. POWERS: What'is.it that precipf. cates in that 8 alloy?
9 . MR . HAMMER: Beg your pardon?
10 DR. POWEPc: What is it that's precipitating in 11- that alloy? The pH 13?
12; MR. HAMMER: I don't think I can tell you what 13 that is, really. I don't know whether it's an austinetic or 14 what it is. I think it's a very hard alloy. You needed a
( 15 very,'very hard material for this application.
16 DR. WALLIS: I'm looking ahead to the next two 17- slides. You seem.to -- the history seems to be they get an 18 idea, they try it, and after a few years it didn't work so
'19 well, so they get another idea, they try it, after a few
-20 years it didn't work so well. They still seem to be in that
- 21 state today.
22 MR. HAMMER: . Well, yes, that's basically been the
'23 process, in a way of speaking, that they would start down 24: some path and not be able to achieve much improvement, and
'25 then: start on something else. That's true. We think ANN RILEY & ASSOCIATES, LTD.
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p 422 1 they're in a little better shape today, though, than they
) 2 were. We'll go into that a little later.
3 And they initially had some success with the 4 stainless steel material. That was installed in several 5 reactors. I think they put in like half of the complement 6 for the plant in at a time, so they could have some basis 7 for comparison with the Stellite data, and -- but then they 8 started to see some sticking in that as well, and beginning 9 in 1987 I think they started to see that they were sticking 10 just about as bad as the Stellite 6B disks had been 11 sticking.
12 I guess what I left out of here is what's happened 13 to Pilgrim at about that time, and of course they've had a 14 couple of cycles there by the late eighties, and it turns
/n (s_/) 15 out their data was looking pretty good for the Stellite-21.
16 DR. WALLIS: So is anybody going to tell us if 17 this is risk-significant or not?
18 MR. HAMMER: Beg your pardon?
19 DR. WALLIS: Is this risk-significant, all this 20 sticking and not sticking?
21 MR. HAMMER: Yes, I'm going to try to address 22 that.
23 DR. WALLIS: Get on to that, too?
24 MR. TERAO: This is David Terao. I just want to 25 be clear that at this point, this is still historical data; ANN RILEY & ASSOCIATES, LTD.
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423 1 we haven't1gotten to the fix yet.
( )' 2 DR. WALLIS: Just wonder where it's going.
3 'MR. TERAO: Okay. We're just talking about the
'4 problem.so far. We haven't told you what the solution is.
5 DR. WALLIS: Where we are today would seem to be )
6 important.
7 MR. TERAO: Right. So if maybe we could just 8 hurry through the --
9 MR. HAMMER: -Okay. Well, we'll pick up the pace a 10 little bit, if that'll help. Okay.
11 In 1990 the BWR owners' group revised their plan 12 again, and this is a key point. They started to concentrate 13' on the environment that the valves operated within, talking
. 14 ' about.the internal steam environment. What they found was
.f" T ,15 that there's not really steam in there, it's almost pure 16 oxygen.from the radiolytic gases that are generated in the 17 reactor, and it's a stoichiometric mix of hydrogen and 18 oxygen, and so it's a very corrosive environment. And so 19 they concentrated on that and said well, gee, maybe we can, 20 you know, make the environment less corrosive, which is what they've done.
22 DR. WALLIS: How does it get to be that way?
23 MR. HAMMER: How does the radialysis occur, you l 24 mean?
i l 25 'DR. WALLIS: -That all the oxygen and hydrogens
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424 1 .havefaccumulated in-this place rather than --
()
l .
2: MR. HAMMER: Okay. What happens is the valves are 3 Lat a slightly subcooled temperature because --
4- DR. WALLIS: .Is there condensation going on?
l 5 MR. HAMMER: Yes, there is condensation.
6 .DR. WALLIS: -- breakup of the condensables, 7 okay --
.8 ;MR . . HAMMER : 'The condensate just runs back out of 9 the. valve.
10 DR. WALLIS: That's what it is. It keeps
.11 concentrating.
12 MR. HAMMER: Yes, and it keeps concentrating. It j l
13- only takes a very short time for it to reach.a saturation 14 condition.
() 15 In parallel with that, the Owners Group about that 16' time recommended-a parallel approach which was to put in a 17 ' pressure actuation system, which would externally actuate 18 the valves with power.
p 19 DR. WALLIS: It's interesting -- excusr, me -- if ;
i i 20 it had leaked enough, it would have just swept out this l 21 oxygen and you wouldn't have the problem, or am I --
22- MR. BARTON: Cheap modification. )
23 DR. SIEBER: Now the installation of the pressure 24 switches is contrary to.the current version of the code for 25 a self-actuated valve,.is that correct?
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=
425' 1 MR. HAMMER: Yes.
() ,
2 3;
DR. SIEBER: And would there be code relief for an
. exemption from-that code requirement to rely upon the t
pressure switches as.part of the actuating mechanism?
5 MR. HAMMER: You are asking whether the code would 6 ~ allow pressure actuation --
7 DR. SIEBER: Does it now and, if not,'will the
-8 code be changed or will an exemption be granted?
9- MR. HAMMER: Okay. I can give you a little status 10 on that.
11 We feel like, as I am going to cover here, we have 12 reviewed the pressure actuation system and feel like it is a 131 . reliable system therefore we feel like it is sufficient to 14 counteract -- counteract being the key word -- the effects h
( //
15 of setpoint drift.
16 Does it completely meet the code of record? A lot j i
17 ~of the old plants that.we.are talking about didn't have
-18 provisions in the ASME. code for using power actuated relief 19- cvalves in this way. Now the later BWR-6s incorporate this 20 into-their design. They take credit for the power actuation 21 mechanism and so there's been discussions between the Owners s
22 Group and the ASME code and what they have basically come up 23 'with is that since this is covered in the later editions of l - 24; -the code what the licensee would have to do in order to get
[
l 25 formal credit for this overpressure protection function are L
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426 1 the pressure switches.
/2-d'- =They would have to reference the newer code
.3 edition and then resolve any inconsistencies between the new t4 -code.and the old code that might exist in that area, so it
~5- is something that is -- I consider it a fine point.
6 DR. SIEBER: It is a path to a solution --
7 'MR. HAMMER: Yes.
8 DR. SIEBER: -- but maybe not the most desirable 9 path, but it's almost a combination hardware and 10 legislative?
11 MR. HAMMER: Yes. Well, something that can be 12 said for their pressure switches, it is not, they are not 13 susceptible to the corrosion sticking. There are problems 14 with electrical I&C systems, but not the same kind of thing
() 15 that you have got going on here.
16 Okay. I was going to give you a little current 17 ' status then on where we are at today --
18 DR. SIEBER: Let me ask one other question
'19 MR. HAMMER: Okay.
20 DR. SIEBER: I would presume that the phenomenon 21 that is going on is corrosion and so now you put a pressure 22 switch and then when you later on, at the next refueling or 23 whenever you test the valves, you test them with the 24 pressure switch and pneumatic mechanism intact, which then 25 the valve would test okay.
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_ l
E 427 1[ Does.that mean you don't clean out all the 2 _ corrosion and the next time you test it it doesn't work at
( }
3 all or.just, you know, where do you end up in the further 4 maintenance because a fix.that comes in'from the side, if 5- _you know~what I_mean, will cause.somebody to say everything 6 is just' fine.and then the maintenance won't occur and the 7' corrosion gets worse -- is there a discussion or a plan that 8 relates to that kind of'a consideration?
9 MR. HAMMER: Well, I could tell you, I just looked 10 at an LER from Browns Ferry. Now Browns Ferry has put in 11 the pressure switches, as you can see at the bottom of this 12 slide. They are one of the plants that have done that, yet 13 they still credit the-mechanical actuation of the valve.
14 They took these valves off and tested them. There 15
' U) was'significant setpoint drift when they did the 16 certification testing, and they had to report that even 17 though they got the pressure switches. j 18 'DR. SIEBER: Okay, and so you sent them over to 19 .Wylie or someplace like that and do not use the pneumatics 20 to test the valves?
21 MR. HAMMER: They_do not, no .. When they test the 22: mechanical ~setpoint, they are just testing that by itself.
23 DR. SIEBER: Will all licensees do that?
l 24 MR. HAMMER: That is required by the ASME code.
25 You are not allowed when-you do the test to use a power i
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428 1 actuated assist mechanism to determine what the setpoint is, 2.
'( if that'.is your issue.
3 DR. WALLIS: _ When they do a test, they take this 4
thing away,'they put'it on some test facility and test it?
'5 MR. HAMMER: Right. l 6 DR. WALLIS: That's how they do it? So do they
'7 . clean it up ahead of time or sweep out the oxygen or do 8 anything different? I mean is thing as tested on the test 9 the same really as the thing existing, having sat in this 10 environment in the plant?
11 DR. SIEBER: I might be able to answer that. They 12 put it in a box, put the box on a truck --
13 DR. WALLIS: Seal it up --
14 DR.-SIEBER: Yes, and seal it. It's in plastic f-s
'( 15 'because it has been in containment.
16 MR. BARTON: It's contaminated --
17 DR. SIEBER: And it is sent 500 miles or 1000 18 miles on this truck, a whole bunch of them usually, and it j 19 goes into a lab so the environment that it is in is 20 different. It's not hot --
l 21- DR. WALLIS: So there's no pretest maintenance or I 22 anything like that?
l 23 MR. HAMMER: No.
l 24 DR. SIEBER: No. It just.goes in a bag.
25 MR. HAMMER: The setpoints, the as found setpoints
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1 429 {
l cw 1- that~are reported are the'first lift and we have seen a lot f
(k 2:
of setpoint. drift when-we'do that, so apparently the shipping or.the handling and that kind of thing doesn't have 1
3 !
4 any effect in breaking the bond.
5 DR. SIEBER: Well, the valves themselves, the 6 l springs and all, areLpretty' strong.
7 MR. HAMMER: Yes, theyLare substantial components, l
.8 Let's see. Brunswick developed a process whereby.
- 9. they>could apply this platinum coating with an ion beam 10 . process.
11 The Owners-Group tried something before, which was
- to disperse a small amount of platinum throughout the melt
- 13 cof the disk. )
14 Such that there is a'very small, 0.3 percent. And I
( 15 .and that didn't change the metallurgical' properties of the 16 disk,1but'it did provide some platinum. {
17 Now-that didn't work'very well, but at the same 18 time' Brunswick developed their own process, whereby they 1
19 applied this ion beam coating.of-platinum, and they've had j
-20 very good results with that, i 21 -We think'there's a few reasons for that. The l 22- platinum' applied in that way-gives a greater surface area 23- and. contact with the oxygen and hydrogen that you're trying i
'24: to recombine, and.it also provides a barrier between the 2 5.. oxygen and the underlying Stellite, .so.that the Stellite's .j i
[ f .
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'1 not'able to corrode. They've_had very good success with 2 that.
[}
3 As I mentioned-earlier, Pilgrim has also had good 4 success.with their Stellite-21, and Cooper has decided to 5 also install Stellite-21. They have a cycle of operating 6- ' data with that, and that also looks fairly good. And there 7- is a short' table showing you the status of what all of these 8 . plants that have two-stage valves are doing as of now.
9 They've either all installed pressure switches or new disks, 10 one type 'cn the- other, and Fitzpatrick is the only one that' 11 hasn't done it yet, but they've committed to do that in the 12 fall of 2000.
13 Now as a -- they did get a-few unexpected high 14 pops on some of the ion' beam disks, and they weren't really
() 15-16
_all that high. I think they were in the-3 to 4-percent range, which is fairly low compared to some of the other 17 data we had seen earlier with the Stellite disks. But 18 nevertheless they decided to investigate that and they found 19 that some of their maintenance practices had not been 20 followed properly.
- 21. .Some of those maintenance practices were performed 22 by Target Ro'ck personnel, so right now the owners' group has 23 a correctiva action program. They're going to be auditing 24 Target Rock.at their corporate office to see if they have 25 .some breakdown in their organization or if there's some h
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431 l
\
1 problem in the field with the way they're training the
\
/^\ 2 individuals that do the maintenance. So they'so assured us
(.
3 that they're going to get to the bottom of that, and they're 1 4 going to do some of that this fall.
5 So -- you had asked about the data, and I was 3 1
6 going to show you, here's the way these valves were 7 performing in the form of a histogram, a statistical sort of 8 analysis, for the Stellite 6B disks, and this is data that 9 was taken up until 1995, which was the point in time where 10 we started to see some of the ion beam disks be installed.
11 So this is all data that we know looks pretty bad because of 12 all the sticking. You can see this is not a normal 13 distribution. It's highly skewed in the positive direction.
14 They've got a big group of outliers here that are even
( ) 15 greater than 10 percent drift. i
%/ \
16 DR. WALLIS: What is your criterion for I 17 acceptability of something like thie?
18 MR. HAMMER: Well, I guess the short answer is 19 that the plants have a technical specification that says 20 you've got to meet a certain value, and that's either plus 21 or minus 1 percent or plus or minus 3 percent if they've 22 justified that. If they don't meet that, they're pretty i 23 much forced into taking corrective action to improve the 1
24 performance until it does.
25 DR. WALLIS: So we could say .Looking at this --
i 1
)
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'432 L ;1 MR. HAMMER: Coming up with a program --
g
!,9 2 DR.'WALLIS: This is a significant number of
,%)
3: . plants or.whatever that don't meet the tech specs with this
- 4 ~ kind of a picture.
5 MR. HAMMER: Right. .Right. Yes, so there was --
- 6. yes, I mean, your point's well taken, there were so many 7- . data points.that just didn't meet the criterion at all. And 8- this.is a large number _of data points, so this is 9 statistically valid, and-you can see the average drift there 10 doesn't look that high. It's 2.81, but it's got a big 11 spread,- and you can see that reflected by the standard
.12 deviation point -- I mean, over 4 percent.
13' 'DR . KRESS: .Is a negative drift just'as bad as a
- 14 ' ' positive one?
() 15' MR. HAMMER: The negative drift is in the 16 ' calculation of the standard deviation as well as --
17; DR. KRESS: Is it just as. bad to have a negative 18 drift as it is a positive?
19 MR. HAMMER: No. Actually, in terms of
'20 overpressure' protection,.it's not. But'the ASME code for
'21 testing basically says that you have to meet a limit on 22 both. And the tech spec has a minus limit.
23- DR. KRESS: Okay. So as far as regulatory space, 24 -it's just as bad; 25- MR. HAMMER: Right. But it could be argued l
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433 1 there's a different safety significance on the minus end --
l' T 2 DR. KRESS: Okay.
\v/
3 MR. HAMMER: Than the plus end, obviously.
4 DR. WALLIS: There's an adjustment -- you go 5 ahead.
6- MR. SIEBER: This gets back to my earlier 7 question. If a valve fails to lift at its set point or a 8 nun. e r of valves, you file an LER, mail it in, tell the lab 9 or the manufacturer, you know, see what you can do about 10 this. They refinish the valve, you put it back in. You 11 could actually do that for many years unless somebody steps 12 in and says this kind of performance cycle after cycle is 13 unacceptable. Has the staff or the region or anybody ever 14 done that, where relief valves have consistently failed to
( ) 15 perform as expected?
16 MR. HAMMER: Yes. On my last slide I'll talk' 27- about the regulatory mechanisms that we have to take action.
18 But I think one of the important things that has happened in 19 recent years was the -- regarding problems like this -- was 20 the issuance of the maintenance rule, which basically says 21 that for a valve or'any component like this the licensee is 22 compelled to come up with an aggressive corrective action 23 -program to -- now that took effect in 1996, I believe, so a 24 lot of this data we're looking at was pre-maintenance rule.
25 But I think with that and some of the other regulatory l.
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434 1- mechanisnm we have, licensees are pretty much compelled'to l'
() 2 3
not-live with this. kind-of a situation.
1DR . BONACA:
For these statistics, I mean, do you l-L4 .have.many repeats'for the same valve, or are they scattered 5: through the_whole population of these SRV's.
6 MR. HAMMER: It's fairly scattered. It didn't 1
7 seem'to have any correlation between actual valve, va2ve 8 position -- all plants had. drift, significant drift at one 9 Lpoint or the other. It didn't - t it wasn't plant-related.
~10 The average of --'if you take the average of all the drift, 11 year by year, you can see it go up and down a little, but 12 not a lot.
13 DR. BONACA: LSo if left in the field now the same 14 valve could one day have a drift of 4 percent and another
() 15 time have a drift of 2 percent?
16 MR. HAMMER: From one outage to the other.
17 DR. BONACA: Well, assume that you left it, and 18 there is a history -- I don't know if there is -- but would 19 the same valve have always the same drift pretty much, or 20 would it be --
21 MR. BARTON: No. No , I don't think you'll find 22' that.
23 DR. BONACA: Okay. .There was no correlation of i 24 that type.
25- MR. HAMMER: No, it didn't --
fairly random I a
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1 1
435 1 guess is the word.
[ '\
x) 2 DR. WALLIS: How about repeatability? It goes to 3 a' test stand, you pop it, then reseat it again and pop it 4 again. Do you do several? You just pop it once.
5 DR. SHACK: It's the first pop that's the --
6 MR. HAMMER: It's the first pop that counts. Now 7 if you want to do a signature to find out if it drops on the 8 second pop --
9 DR. WALLIS: Does it go back to its original set 10 point, or does it -- what does it do if you pop it again?
11 MR. HAMMER: If you pop it again and it's the 12 corrosion sticking, generally it goes back pretty close to 13 what the set point's supposed to be.
14 DR. WALLIS: I would think it would.
() 15 16 MR. HAMMER: That's one of the signature tests that you can do to see if it's corrosion sticking.
17 MR. SIEBER: Now this 6B data is pretty early 18 data.
19 MR. HAMMER: Yes, this is pre '95, and it's --
20 ME. SIEBER: And the other ones you're going to 21 show us are later on?
22 MR. HAMMER: Right. Right. Yes --
23 MR. SIEBER: Why don't we look at that?
24 MR. HAMMER: Right.
25 DR. WALLIS: There's a correlation with time or
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436
-1 with material,-one or the other.
p ['k 2 MR.'SIEBER: Or both.
V 3- M
- R. HAMMER
- Here's the histogram for the IM beam 4 -data; You can see --
5 MR. SIEBER: Now this'is pretty' late. Right?
6 MR. HAMMER: It's about the'same size chart, which 7' is unfortunate. I mean, this is - you.can see the -- but-8 this only is.like a,-you know, goes from minus 6 to 6, and 9 all1of the data is between 4 and 4.
10 DR. KRESS: Is that considered better performance 11 than.the-other one?
12: MR. HAMMER: Yes. Yes, this is much better 13' . performance, and you can see it r'eflected in the average 14: drift, which means that we've got an' equal or more number of
()
.m 15
~16 minus' drift-than'we do plus drift by having a negative average.
17 DR. WALLIS: I was going to ask you about that,
.18 because'this drift is from some zero. Now the zero is
-19 . determined'by having been' tested at .its set point prior to 20 installation and adjusted in some way?
-21 MR.~ HAMMER: Yes.
22 DR. WALLIS: How closely to zero does it get when 23 'it's adjusted?
24- MR. HAMMER: Well, they're required to set it 25 within plus or minus 1, plus or.minus 1. So you could have L
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m 437 l
1L some scatter within the plus or minus 1, and unfortunately 2 that - - you suffer that penalty later, maybe. But a lot of 3= facilities are able to set-it tighter than that.
4 MR. SIEBER: Yes, but it is difficult, and it
-5 takes a lot of pops. On the other hand, what it does is 6- give you a spread within the distribution that reflects your 7 inability to set it.at' exactly zero or at exactly the set
'8 point,'along with whatever's happened over the 18-month or 9 .2-year cycle. 'Just makes.it wider.
i 10 DR. KRESS. Can you superimpose that other slide, 11 the earlier one, or just set it up there along with it, just i
12 to --
13 MR. HAMMER: Actually I have a slide where I i
14 squeezed all three of these together. Maybe that's --
() 15 DR. KRESS: Now if I were looking at the top' slide
- 16. .and the bottom slide, and consider some sort of a 17 statistical. significance test of it, I would judge them 18 . equally as bad,'probably.
19 MR. HAMMER: You would judge --
20 -DR. KRESS: I would judge the second slide equally 21 as bad as the top one if.I did a statistical analysis of it.
22 DR..SEALE: The second one or the third one?
23 MR. HAMMER: I'd have to differ with that. This i
'24 is, as.I mentioned, this has got drift all the way out here.
25 There's a tail that's not shown on this --
p) s_
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438 L 1 DR. KRESS: That's because you've got a lot more L.
.[ 2- ~ data.
l 3 DR. POWERS: Let's say, _ Tom, that you were -- that l-( -4 thece'are normally' distributed for fun.
-5 ~ DR. KRESS: Just for fun would help.
) 6- DR. POWERS: Okay. To what questions you would 7 ask,:what question you'd ask, are the means from the same 8 population?
9 DR. KRESS: Yes.
10 DR. POWERS: And --
- 11. DR. KRESS: A statistical --
11 2 DR. POWERS: That would be a student's T test.
13 DR. KRESS: T test. And you're going to do an 14 analysis of variance, and ask if the variance is G 15-
g significantly different.
16 DR. POWERS: Yes.
17 DR. KRESS: And --
18 DR._ POWERS: That's an F test.
19 DR. KRESS: Yes, F test. I think your probably 20 get something.like well, they're pretty _close to each other.
21 _But without doing it I'm not sure.
1 22- DR. POWERS: Yes.
123 IMt. WALLIS: This is because of the inference of 24: the small number of tests in the bottom figure.
75 -DR. POWERS: No , it's the -- the difficulty lies MG1 RILEY & ASSOCIATES, LTD.
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439
.1 in the size ofothe standard deviation, and the fact that
[
)
L2 they're from different' sample sizes, you can compensate for 3 Ethat.
4 DR. KRESS: 'You'can compensate. That's part of
~5 .the --
-6 DR.. POWERS: The problem really is the standard 7 deviations are so big here.
8- 'MR. HAMMER: Yes. Well, when I computed these 9 . standard deviations, I followed the rule that you see in.
10L textbooks'of including in the formula N minus 1 points
<11 rather than N if it's a numbe'r less'than 50.
112 DR. SHACK: He's not arguing over that i i
13 computation. He's now arguing over the significance of the 14' difference that you see between the two, which is a
() 15-16 different statistical' test.
MR. HAMMER: I'm not sure.
17- DR. POWERS: There are two questions that you 18 have: Are the means significantly different? and are the 19, standard deviations significantly different? And I guess I 20 have~to admit,. Tom, I think the means will come out to be-21 the same;within a substantial confidence rate. I will' bet 22' thatLthe standard deviations don't.
23 DR. KRESS: Yes, it looks like the standard 24J -deviation is going to'be smaller.
25 DR. POW 2RS: Yes, that's because the number in the N . ANN RILEY.& ASSOCIATES, LTD.
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e 440 1 F test, anything -- get two or three in the --
2 DR. KRESS:
[V') But it's not much of an improvement.
3 MR. SIEBER: No, but there's one that they haven't 4 showed yet, which is the application of the pressure 5 switches, at 3 percent, everything else disappears.
6 DR. POWERS: If we looked at the bottom --
7 MR. SIEBER: Tolerance of the electrical 8 equipment.
9 DR. POWERS: And compared to the top one, I say 10 that those two are dif ferent.
11 DR. KRESS: I would definitely say so.
12 MR. HAMMER: I have to apologize. I had a cold 13 earlier this week, and I'm having an awful hard time hearing 14 you gentlemen. Is there a --
g (vj 15 MR. SIEBER: I think what we're searching --
16 MR. HAMMER: Some question that I could --
17 MR. SIEBER: Yes, I think what we're searching for 18 and we're not quite getting it because it probably isn't 19 there is that we're looking for a correlation that would 20 tell us that through history, time, all these fixes, the i
21 problem is getting better --
22 MR. HAMMER: Yes.
23 MR. SIEBER: Getting solved.
24 MR. HAMMER: Okay. >
25 MR. SIEBER: And we really don't have that, and
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F; 441 1: we're.-- I think that's what we're all trying to get at.
f I. 2 MR. HAMMER: .Okay. All right.
D.
L3 DR SHACK: Well, he thinks-he's demonstrated it 4 here, and the question is, has he?
o .5 MR. SIEBER: Has he, and the answer is probably f 6- not.
7 :MR. HAMMER: Yes. Well, you know, we thought
-8 about;this, how would be the best way to present this data
- 9 in.some concise fashion, and we tried a different approach, 10 Let me show you a backup' slide that I've got, and actually_
11 we got this suggestion from Mr. Sieber last week to try to 12' plot this kind of a -- let's see, it needs to go a little
'13' higher. Okay.
- 14. 'Now this has got some -- this isn't a perfect I 15 representation of -- because there's something arbitrary 16 'about it.
17 What I've done is I've tried to plot percentage of l
~
- 18. set points that were greater than plus 3.
Well, the plus 3 19 is an arbitrary basis for. comparison. So if I'd picked 4 or 20 -5, then a~ lot of these points that are down here are all of 21 a sudden going to fall to zero. I think you have to realize .
22 that when you look at this.
23 So it's not a -- but the thing you can see is that 24 all ofithese round dots are way up he in this range where ;
25 you had, if you were using a plus 3 percent criteria, all of ANN RILEY & ASSOCIATES, LTD.
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u 442 l.
1 these points were, you know, in the 30 to 50 percent range,
!'Y 2 were above that --
- Q.
3 MR; SIEBER: It would also appear --
- 4 MR. HAMMER: And here are the other materials down 5 here.
6 DR. UHRIG: The ion beam suddenly went bad in '98.
7 MR. HAMMER: Well, you see, that's the funny thing 8 about this plot. This is only based on a couple of points, 9 because,-you see, what you do when you try to divide it by 10- year, you don't have very many points per year. So now 11 you've got^a really heavy weight on a single failure.
- 12 MR. BARTON: That's right.
13 MR. HAMMER: And the other thing that's not 14 reflected in this kind of a representation is yes, you've .
i f
f -
15 got 20 percent failed this criteria, but this valve was 16 only -- I think there was two valves. One was 3.1 and one 17 was 3.9, or something like that. Some of these valves 18 were -- you've got to remember.were greater than 10 percent 19 DR. SHACK: How many cycles of the ion beam have 20 these plants been through?
21 MR. HAMMER: I think Brunswick has had three on j 22 all -- both of their reactors. Hope Creek has two -- one 23- cycle, excuse me, one cycle at Hope Creek. Fermi has
-24 installed them --
12 5 MR. BARTON: They're in their second cycle. They ;
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443 1 had some last. cycle and they tested them, and one of them
'T (d 2 3
was a 3-percenter -- a 3 point something, MR. HAMMER: Oh, I was not aware of that.
4 MR. BARTON: Now they're in their second cycle.
5 MR. HAMMER: Okay. Now they installed a full 6 complement, I believe.
7 MR. BARTON: Yes, they did.
8 MR. HAMMER: Okay.
9 MR. BARTON: They got all 15 ion beams.
10 MR. HAMMER: Okay. And we were expecting that 11 data a little later this fall, I believe. Does that sound 12 correct?
13 MR. BARTON: Their outage is next spring.
14 MR. HAMMER: Oh. Okay. Okay. So we won't have
( 15 that. But we're hopeful that --
16 DR. SHACK: A platinum coating is not terribly 17 wear resistant, and it's not very thick.
18- MR. HAMMER: Yes, it's --
19 DR. SHACK: The ion beams drives it in a little 20 . ways.
21 MR. HAMMER: Yes. My understanding is it's only a i
22 few molecules thick, and it has to be reapplied each cycle. l l
23 DR. SHACK: Oh , they do reapply it each cycle. j 1
24 MR. HAMMER: Um-hum.
25 DR. SHACK: Yes, so the ion beam, just make sure
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r 444
'l it lasts the cycle.
() 2 MR. BARTON: Gets it through a cycle.
3 MR. SIEBER: 'Now this will'be a challenging 4- question, but:can you'make a conclusion about anything by 5; looking at,that, and if so', what-would your conclusion be?
-6. MR. HAMMER: Okay. Yes. In my thinking, 7 realizing what I've done here and how I've contrived this, 8 it does show that -- some significant' improvement, I 9' believe, over the p evious valve performance, all of these 10 round dots up here, Stellite 6-B being so high, I believe 11 1 that that's what,that tells me, especially realizing that 12 some of these exceedences here over 3 percent were so 13 slight, _and many of these were so great.
14 That coupled with this thing, which tells me that
[ l 15 I've'got a tighter band of the data around zero -- well, I
%.J 16 can say that about the ion beam. The Stellite-21 is still 17 skewed to the right, but it's bound by a much smaller band. ;
H18 Now that's reflected in the standard deviation here. You've
.19 got a much lower number for both'of these'than you do -- so 20 those two together_ help me with that.
21 Mary Wegner, who was formerly with AEOD, and who l 22 used to compile data and look at it and analyze it and 23, stuff, has been kind enough to -- even though she's not in j 24 AEOD_anymore -- to put together another viewgraph for me.
25 This is a backup slide I don't have in the I
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445 1
1 package, but she's attempted to plot the averages of all of 2-( the plants -- there's a different symbol here for each 3e : plant'-- by year. Now this is just average of all of the 1
4 valves, so, I mean, it won't tell you anything about any 5 particular test. ;
6 So you can see how that moves it around and this 7 is the average of the' averages, if_you will, this line that 8 goes up and down, and this has basically come back down
.9 , because what happened in '97'and '98 was we added in some 10 - ion beam data.
.11 DR. WALLIS: .Well, this looks a bit like the story 12 that you presented early on, that every three or four years 1 13 there seems to be some new-thing that goes wrong and it goes 14 up again. Here there is no consistent trend over this i 15 period of time, 16- MR. HAMMER: Right, and this probably isn't the 17 best type of a statistical analysis to look at because it 18 doesn't tell you the spread of'the data. It 's just an 19 average. All'of these points are just averages and then c20 this'is:the average of.the averages.
21 'DR. WALLIS So any' measure of an average against
- 22 some criterion,'you are suggesting 3 percent might be a
~
23 criterion,~and it looks here as if.at least half the points 24 are most of the time above that 3 percent, so it's not all ]
25 :that reassuring.
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1 l
o_
ci; l 446 l- 'l DR. SIEBER: I am not sure that is a really good b ..
2 .way.to try and get-at what we are trying to understand.
l I.
3 DR. WALLIS: .You've plotted it some other way to
,4- look better, is that what you are saying?
l 5- MR. HAMMER: To give you some idea -- I didn't j ~6 -know you would want to get into this to the degree that we
- 7. have, but I also brought along another histogram. Now this l 8 is not a. Target' Rock valve. This is one of the spring safety valves, the Dickers model, that was one of those that 9
10 .I'showed you earlier.
11- Now you can see out here they have some valves, 1
12 some population that's greater than 3 percent, but they have
- 13. an equal. amount that is less than three.
14 The thing that is interesting about this is - I 15- mean if'you want to say that Target Rock is-on a-par with 16 these or not, you know, I mean you could make that 17 comparison, but the interesting thing is that there is the 18- spread. It is centered'around zero and they are not perfect 19 but these.are considered to'be-really nicely. performing t 20- valves.
21 DR. WALLIS: It is kind of interesting that zero 22 is one of the least.likely of these values.
23 (Laughter.]
24' MR. HAMMER: Yes. Right.
25 DR. KRESS: I'think that is an artifact. You have L
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p 447 e 1 -to really draw it with a perf through the thing, use all the l-L '( ) 2 data to fix~the curve. That-is not a double mode curve, I'll 3 bet you money.
! .4 DR. SIEBER: Maybe you could go to your
- 5. conclusions?.
6- MR. HAMMER: Okay. We need to get moving here.
17 1 Based on'all'of that, we believe that based on the
-8: success for the three stage valve since they have improved I
9 the performance'since'the 1970s,.we don't believe there is j 10 any. improvements that are necessary at all for the three 11 stage valves.
12 They were the valve that this issue was initially 13 .prioritized for.. The improvement.is.far beyond the value 14 impact statement that was made in the assumption for the
- n() 15- .prioritization so we feel like we have got a pretty good 1 16 case for closure:on that.
17 For the two stage valve, we are not saying that 18- the-performance is perfect, but we feel like because of the 19 large margin in the system, which is rather. tolerant'of 20 setpoint drift it is not a very: safety significant
- 21. ' phenomena.
22 DR '. KRESS: The margin to the design pressure of 231 .thefpiping?
24 DR. SIEBER: Right.
'25' .MR. HAMMER: Yes.
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l u
n 448 1 DR. KRESS: Are there other functions.of these if'T
- V'
'2 valves.like rate 1of depressurization needed to avoid
'3? something like'a pressure-driven dispersion of material in 4~ case of an accident? Is the rate of depressurization 5 important and'does this affect.the rate.
.6 MFL HAMMER: Rate of depressurization -- you mean 7' once-the valves open - -
.8 DR. KRESS: .Yes. I'am assuming you pop'open all
'9 the valves at some pressure. 'I presume the rate is high --
10' the pressurization is a little higher-because it is at 11 higher pressure because they are sticking -- well, some of 12~ .them not open at all.
13- DR. POWERS: Well, it's'all going to be tripped --
14 I mean if there is automatic depressurization, they are 15 ~ going;to:be open.
16 MR,: HAMMER: Now the automatic depressurization 17 functions'--
18 DR. KRESS: -It doesn't affect'the ADS function is 19- what you are.saying?
20 MR. HAMMER: lit doesn't affect the ADS function at 21 .all,Jyes.
- 22. DR. ~ SHACK: This is really a-setpoint -- you know, 23 this.is. pressure vessel overprotection.
~
.24t fDR . KRESS: 'It's strictly overpressure protection 25: we areLlooking.
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E I
449 1 MR. BARTON: All these don't have to lift either, t.
() 2
'3
.you have got -- there's extra valves there. You may only need-nine valves but you have got 14 on the steam line.
4 DR. KRESS: Yes, but a lot of the time it is just i 5' one of them'that does that job, because it's set at the low i
- 6 value.
7 DR.-POWERS: I think you are thinking about PWRs.
l 8 These are BWR things.
9 MR. BARTON: Yes, this is BWR stuff.
10- DR. KRESS: .I knew that.
11 [ Laughter.]
12 MR. BARTON: All I am saying is if some of these i 13 ^ stick,-you are over-designed, to put more valves on the 14- steam line than you need --
15 DR. KRESS: I caught a.few of them.
-16 MR. HAMM8R: O'tay,-and the third bullet there is
.1 */ ~we_ feel--like the industry actions have significantly 18 improved.or. counteracted,the effects of setpoint drift by 19-- using-the ion beam platinum or the' stellite 21 disks. We 20- feel like both of those things will be performing rather I
21 'well right now and even though.noc. formally credited for >
22 overpressure protection, it is sort of a -- I think.it's l 23 .been called a suspenders L and belt type thing.
24 You-can add, you can increase the reliability. It 25 'is a reliable system.
l:
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450
~
l l's 1- So based'on that, the. Staff is not recommending
'2 lany.new regulatory. requirements as a result of this issue,
(}
- 3 .andiwe have got a fallback. If the-setpoint performance 4 does not continue!to be adequate, we feel like there are 1
5 already_ sufficient regulatory mechanisms available to pursue
~6 any needed-improvements -- for example, adding pressure s7 - switches.
'st If valve disks just' don't perform like we see them 9 performing now, and they have been performing at Brunswick
~10- and' Hope Creek, and the pressure switch option is available
~
- 11. and, you'know, we could pursue that with the industry and we
'12 feel like we've got three mechanisms for pursuing those 13 things ~and there are even other things that I haven't listed 14 such as the general design criteria and.some other things i
() -15 16 but hereLare the three big ones, I believe -- the Appendix B criterion, which is quality assurance, and, as I mentioned 17 earlier, the maintenance rule, and there is also 10 CFR
- 18. 50.55 (a) codes and standards, which comes into play because 19' thatLgoverns the inservice testing requirements for the 20- Lvalves. =If you don't meet those requirements, you have to l .
L 21 find out the cause and take corrective action.
22 So this is what we are proposing. I guess that is 23- all the slides I have.
l 24 -
DR. SIEBER.: I might point out, while we are 25 wrapping up,-that Mr. Joseph Ondish, BWR Owners Group, is l
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! i i
u 451 1 here. He tells me he doesn't plan to make a presentation '
2' but I wanted to acknowledge he is here.
(}
3 MR. HAMMER: I guess that is all we have right
! 4 now. We would be glad to answer any further questions.
5 DR. SIEBER: Are there any further questions from ,
- 6. the committee?
7 DR. KRESS: These valves -- are they tested every 8 . cycle, fuel ~ cycle? How often are they tested?
9 MR. HAMMER: I'm sorry?
10 DR. KRESS: How often are these valves tested?
11 MR. HAMMER: Oh, how often are they tested? The L
12 ASME. code generally governs the frequency, but in the case 13- of these BWRs, and this goes back to the three stage 14 problem, they test them more frequently than the code
() 15 requires, which basically puts them into testing every other 16- cycle.
17 DR. KRESS: Every other?
18 MR. HAMMER: So every two cycles they will have ,
19: tested all of the valves.
20 Now there is a penalty portion of the ASME code -- j 21 now this is interesting. If you fail a test, you have got
- 22. to pick two more and test them for.every one that fails, so 23' what happens at a lot of plants, they send all of their ;
24 valves every outage because they know they are going to have l
l 25 ~some ---
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F 452 1 DR. KRESS: I understand.
p
}
2 MR. HAMMER: You don't want to have that on your 3 critical path, having to yank another valve off.
4 .DR KRESS: Do any of the valves every stick 5 closed and not open at all? They've got this percent drift, 6 but do they ever stick completely' closed and not open at 7 all?
- 8. MR. HAMMER: We have never seen that. We have 9 seen some that were stuck to the point where if you 10 pressurized it high enough to lift it you would have 11 exceeded the design pressure --
12~ DR. KRESS: The design pressure --
13 MR. HAMMER: -- and so they just stopped the test 14 at that point'and say its adrift, but.then in later IT 15 diagnostic-tests they take those valves apart and they use a V
16 pulling mechanism.and they measure the force.
17 Now that has been done in a lot of cases, to see 18' just what the forces were, so the answer is no. If the l 19_ pressure got really high, they would open.
20 DR. KRESS: I think most of those valves have a i
21 way to manually open them if you have to? !
22 MR. HAMMER: Yes. Yes, the operator can open them 23- simply by turning a switch if he wants to with the 24 . electrical,. pneumatic actuators, and we mentioned earlier 25 the ADS function, which is completely automatic.
I l
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p-453
.1 DR. KRESS: What I am searching for is to ; if I i
2 can' find any. risk significance to this problem and for the 3- life of me I can't find any.
4 MR. HAMMER: Well,'it is interesting. I think the 5 more.important function that the valves.do perform in the 6 . ADS function.
7 If you didn't have that, there would be certain 8 LOCAs that you would have trouble --
9 DR. SIEBER: There may be some risk significance 10 ' associated with failure to reseat, just continue to blowdown 11 to the suppression pool, but I don't know what that number 12 is, but that problem has-basically been solved a number of 13 years ago.
14 MR. HAMMER: Yes.
'D 15 DR. SIEBER: 'The failure to reseat.
4 16 MR. HAMMER: -Well, in terms of risk significance 17 on BWRs for LOCAs,.it is generally'a small contributor to
.18 the.overall core damage frequency, and that is mostly ,
i 19 because of all the makeup. systems that you have on a~BWR.
20 DR. WALLIS: When we make decisions like this, I 21 think we'should look at the consequences. -You have given us
-22 this new information that they test all the valves each l l 23 cycle?- That means they have to have spare valves so they !
24L 'can ship away one' group and leave the others on, put the 25 .other ones on?
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454 1 MR. HAMMER: No. They usually -- now some plants 2 do have spares but not all.
[J) 3 DR. WALLIS: So now if you close this issue, are 4 they going to stop testing all the valves? Are you going to 5 stop getting the information --
6 MR. BOEHNERT: No.
7 DR. WALLIS: Or are they going to keep testing all 8 -the valves every cycle? So you are going to keep getting 9 information about valves --
10- MR. HAMMER: Yes.
11 DR. WALLIS: -- if you close the issue.
12 MR. HAMMER: Yes.
13 DR. WALLIS: The same way you do today.
14 DR. SHACK: They didn't pass any new rules.
r'N
) 15 DR. WALLIS: Yes, but I mean --
16 MR. HAMMER: Right.
17 DR ., WALLIS: -- there might be some incentive 18 after the issue is closed to say the valves are no longer 19 such a problem, we won't test so many --
20 MR. HAMMER: We are not proposing to relax any 21 ' requirements at all.
22 IM1. SIEBER: My impression is that if you close 23 the issue nothing will change. If that is incorrect, maybe 24 you can --
25 MR. BARTON: Hopefully the valves will get better.
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455 1 DR. SIEBER: If we start using more platinum with L -t 2- the pressure switches on.
3- MR. HAMMER: Right.
4' DR, SIEBER: But is that or is that not the case?
5 MR. HAMMER: Yes.
6 DR.'SIEBER: Nothing will change?
7 MR. HAMMER: Yes. In my discussions with the 8 Owners Group they have advised me that they plan to continue 9 with their' effort to evaluate the setpoint drift, pursue any 10 fixes that are necessary in the future.
11 DR. SIEBER: Any further questions?
12 [:No response.] 4 13 DR. .SIEBER: If not, I would to thank the 14 gentlemen from the BWR Owners Group and the Staff for their J
() 15- presentation and turn it back to you, Mr. Chairman.
16 'IMt. POWERS.: Okay. What I want to accomplish
- 17. tonight is to try to hit'each one of our Class A letters, 18 okay? I don't think I intend-to do anything at all on the 19 - Class B letters tonight; that is, GSI-148, the B-55 issue 20 and.the design basis issue we won't get to at all.
21 I guess we can get off the transcript at this 22 time.
23 [Whereupon, at 4:22 p.m., the meeting was 24 concluded.] !
25- l r
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[' i before the United States Nuclear Regulatory Commission in
(_)
the matter of:
NAME OF PROCEEDING: MEETING: 466TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
PLACE OF PROCEEDING: Rockville, MD f~~r
% j) were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and 1
accurate record of the foregoing proceedings. l 1
l Mark Mahoney Official Reporter Ann Riley & Associates, Ltd.
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Resolution of Generic issue 23 O
"RhACTOR COOLANT PUMP SEAL FAILURE" l PRESENTATION TO THE ACRS O Mark Cunningham, DRAA Jerry E. Jackson, DET Arthur J. Busiik, DRAA October 1,1999 9
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GSI-23," REACTOR COOLANT PUMP SEAL FAILURE" o Agenda:-
Introduction / Background RCP Seal Cooling Plant Specific Analyses / Risk Considerations Conclusion O
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GSI-23 RCP SEAL FAILURE i O . Introduction / Background RCP seal failures that would lead to a small break LOCA l 5 during normal operation i
i Staff Actions: '
-Tests of sea 8 material
-Test and analysis of seal hydraulic stability
- Development of Rhodes seal model ;
1994 SECY-94-225 (8/26/94) Proposed Draft Rule sent to the l Commission required licensees l (1) take action to reduce dependencies to ensure core I cooling or l (2) demonstrate risk from seal failure sufficiently low that further reduction not justified i O Commission disapproved rule 1995 (SRM 3/31/95) i
-Insufficient basis for gains in safety )
- No generic basis ( issue plant specific)
- Concerns with seal evaluation models
-Industry addressing in IPE program O '
Hi ALARM ~
o X l,F"' et-100 cc/hr
'- #3 SEAL
= LEAKOFF '
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ALARM F
.- #2 SEAL -
3 9PH j W3 SEA 1.
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PUMPS LEAKOFF
, o n - #1 SEAL ,"
" " C '*2 SEAL RUNNERi l 5GPM SGPM - LEAKOFF HI LO ALARMS 7L
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' RCP's 325 psig 8 #1 SEAL. I
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,L 21GPM ac s$ -
SYPASS o .5 GPM LO 8 i TO ALARM SEAL WATER l LOWER l HEAT EXCHANGER I RADIAL g i SEARING l I
\ I Al I/ l SEAL INJECTION FLOW 8GPM j (Charging Pumps Cooled -
by CCW/ESW) 1 !
ooooooo !
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100T DAAWN TO SCALE Po olbg Water n,ygf p p f.
t SHAFT i Y
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Seal FLOW Diagram 4
i-
- c. .
f RISK CONSIDERATIONS 0 -
Scope of GSI-23 includes:
- Plant specific reviews 1
- Plants meet intent of the SBO rule Loss of CCW/ESW systems
- Preliminary (screening) analysis
- Based on IPEs and Rhodes model
-Identify plants with potentially high contributions to CDF
- Additional plant specific reviews for outliers, plant specific backfit as appropriate O '
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RCP SEAL MODEL USED FOR LOSS OF RCP SEAL O COOLING .
RHODES MODEL FOR WESTINGHOUSE PUMPS We use a slight simpilfication of the model of Dave Rhodes, given in Appendix A to NUREG/CR-5167 Two types of RCP seal failures on loss of cooling
- 1. RCP seals " pop open".
The seal opening forces on the movable seal ring of the second seal stage are increased, for a given seal face separation, as a result of two phase flow thru the seal faces, and the second stage seal faces separate.
The third stage face seals open with probability one, given popopen of the second stage seal faces.
Fapopen occurs at ten minutes after loss of RCP ,
seal cooling, when the hot reactor coolant reaches the seal package.
The probability of the popopen mode is 20%;
epistemic uncertainty. If the seals of one pump pop open, the sea!s of all pumps pop open.
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Rhodes Model for Westinghouse Pumps, (continued)
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The leak rate from one RCP given popopen of the 2"d and 3'd stages is 182 gpm, for a pressure of 2250 psia and temperature of 550 deg. F.
There is a 50% uncertainty in the flow rate from the two phase flow correlation; this is the dominant source of uncertainty in the flow rate.
Use a 95% upper bound flow rate of 300 gpm.
- 2. Westinghouse 0-Ring Failure Westinghouse."old" O-rings fall at two hours after loss of RCP seal cooling, with probability unity. The associated leak rate is 300 gpm for P=2250 psia and T=550 deg. F. Westinghouse O "new" O-rings do not fall during the mission time, unless the seals have popped open. The Rhodes model assumes that with the improved 0-rings i there is a 50% chance of first stage O-ring failure, l given popopen of the second stage.
Rhodes gave no credit for decreased probability in popping open from operator depressurization of RCS. No credit for increased time to 0 ring failure. ,
O 7
TIMES TO CORE UNCOVERY. Westinghouse Plants O -
Assume, for station blackout, that the operator cools down plant according to procedures Then the core uncovers in about 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> if only the popopen mode occurs, without 0-ring failure (consistent with Rhodes model)
If have 0-ring failure at two hours, core uncovery occurs in about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, when the popopen mode of failure of the seals occurs at 10 minutes, and between 4 and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> if only the 0-rings fall.
(consistent with Rhodes model, for old 0-rings).
We simplify further, and assume that core uncovery occurs at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, whether only the O P P Pen mode occurs, or the 0-ring failure, or both.
Results are not sensitive to the probability of 0-ring failure, for new O-rings, given pop-open of the RCP seals.
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Rhodes Model for non-Westinahouse Pumos
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We assume no failures of polymer seals during the mission time.
We assume a 20% chance of the popopen mode, just as for Westinghouse pumps We assume a leak rate of 182 gpm per RCP, and core uncovery times as for a Westinghouse reactor.
The maximum leak rate will be less than the 300 gpm leak rate assumed for Westinghouse pumps, for the pop-open mode of failure, but the sensitivity study given later assumes that it is 300 gpm, as a bounding case.
O These assumptions are for want of more information.
In particular, the leak rate of 182 gpm per RCP may prove to be conservative for non-Westinghouse pumps. For example, NUREG/CR-4821 (Rhodes, Hill, and Wensel) predicts analytically that Bingham International 2"d and 3"' stages will popopen, but that
-the leak rate could range from less than 1 gpm to more than 100 gpm, with a nominal predicted leakage rate of 50 gpm. Also, the results of a SCE test on a ,
Bingham International seal assembly, and comparison !
to analytical predictions, indicate some conservatism in the analytical predictions of instability thresholds.
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I RISK IMPLICATIONS OF THE LOSS OF RCP SEAL 1 O COOLING,'AND IMPLICATIONS FOR THE STATION BLACKOUT RULE
]
STATION BLACKOUT Station Blackout (SBO) rule,10CFR 50.63, coping analysis considerations Estimates of core damage frequency (CDF) from SBO initiated RCP seal LOCA sequences (external events, internal flooding, and fires not included)
Will show that the intent of the SBO rule, an industry average CDF from SBO of about 1E-5 per year, is still met.
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- O IMPACT OF RCP SEAL LOCA ON STATION BLACKOUT COPING ANALYSIS The station blackout rule,10CFR50.63, states that each plant must be able to cope with a station blackout of a specified duration.
Plants are placed into two categories: 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> coping i plants and 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping plants ,
Given the validity of the. Rhodes model, plants in the ,
four hour category will still be able to cope with a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> station blackout, even considering RCP seal LOCAs, if best estimate models are used.
There are just 7 PWRs that are 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping time Q plants; we looked at each one separately.
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SBO. (continued)
O All plants in the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping capability. category have alternate AC sources. These alternate AC sources can maintain seal injection and CCW, but do not have ECCS pumps on their list of loads, and may not have the power to operate them.
The alternate AC for Turkey Point Units 3 and 4 is available in 10 minutes after SBO. For all other 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping plants, the alternate AC is available in one i hour. Although the alternate AC could restore seal l Injection and RCP thermal barrier cooling, current Westinghouse SBO emergency response guidelines i state that RCP seal injection and RCP thermal barrier cooling should not be restored once the RCP seal package heats up.
O -
The pop-open mode will not occur for Turkey Point Units 3 and 4, given the alternate AC works and comes online in 10 minutes. Therefore, SBO-induced RCP seal LOCAs do not affect the SBO coping analysis for the Turkey Point units.
l For the other 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping plants, where it takes one hour to startup and align the alternate AC, the popopen mode occurs with 20% probability, leading to a leak of 182 gpm per pump, in our model. For Westinghouse plants with old, unqualified 0-rings, the O-rings fall at two hours, and, in our model, there is a conditional probability of unity of core uncovery, given a SBO exceeding 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
O 12
Sensitivity Studies. SBO o -
Sensitivity study: core uncovers in 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. This represents the 95% upper bound case for the leak rate corresponding to the pop-open mode, followed by failure of the O-rings.
Except for plants with Westinghouse pumps using the old 0-rings, the CDF from SBO-induced RCP seal LOCAs is proportional to the probability of pop-open of the RCP seals (ceteris paribus).
For plants with Westinghouse pur,ps using the old 0-rings, the CDF from SBO Induced RCP seal LOCAs is only very weakly dependent on the probability of pop-open.
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CDF FROM SBO-INDUCED RCP LOCA, FOR PLANTS WHICH MUST TCCOPE WITH AN 8 HOUR SBO Plant - AAC EAC_ P(EAC) F(sw- CDF CDF time success losp) from from criteria RCP RCP seal seal LOCA, LOCA, on SBO on SBO Tuncov Tuncov
= 2.5 = 4 hrs hrs Turkey Pt 10 1 out of 2 .003 .0305 3.2E 6 2.5E-6 <
3 and 4 minutes /yr /yr /yr Indian Pt 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 out of 3 4E-4 .005 /yr 7E-7 /yr SE-7 /yr Unit 2 Indian Pt 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 out of 3 4E-4 .005 /yr 7E-7 /yr SE-7 /yr
- Unit 3 Millstone 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 out of 2 3E-3 .035 /yr 1.8E-5 1.4E-5 Unit 2 /yr lyr Millstone 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 out of 2 3E-3 .035/yr 1.8E-5 1.4E-5 Unit 3 /yr /yr Robinson 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 out of 2 3E-3 .005 /yr 2.6E-5 1.8E-5 Unit 2 /yr /yr Koy: ,
AAC= Alternate AC source F(sw-losp)= frequency of severe weather LOSP EAC= Emergency AC source CDF= core damage frequency P(EAC)= Probability EAC is failed SBO= station blackout LOSP= Loss of Offsite Power l O'
14
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SUMMARY
, Effect of RCP seal LOCA on SBO sequences 0 -
Plants which are required to cope with a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> SBO can still cope with a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> SBO, even taking into account SBO-induced RCP seal LOCAs, when best
- estimate values and models are used.
For a four hour plant with Westinghouse RCPs and old 0-rings, the contribution to the SBO core damage frequency from RCP seal LOCAs is estimated at about 2E-5 per year, not taking into account the fact that even without a'RCP. seal LOCA core damage can occur for a SBO exceeding 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (e.g., from battery depletion at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />). For non-Westinghouse pumps, or Westinghouse pumps with new O-rings, the corresponding contribution is 3E-6 per year.
Q -
For the eight hour plants the contribution to the SBO core damage frequency from RCP seal LOCAs is estimated to be about 1E-5 per year for two of the plants,2E-5 per year for one plant, and 3E-6 per year or less for four of the seven units .
The intent of the station blackout rule,10CFR50.63, of having an industry average core damage frequency from SBO of about 1E-5 per year appears to be met, even considering RCP seal LOCAs on SBO.
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LOSS OF RCP SEAL COOLING: LOSS OF COMPONENT Q COOLING WATER (CCW) AND ESSENTIAL SERVICE WATER (ESW)
Will give results of scoping estimates of CDF from CCW/ESW initiated loss of RCP seal LOCA sequences for a non-random sample of plants, biased toward plants where the risk was initially assumed to possibly be larger than average (external events not included)
Indicate the nature of the plant specific considerations which enter into the assessment of risk from these sequences Give the results of a survey of plants where because of plant specific considerations the risk is O likely I w, fr m these sequences Conclude that the risk is highly plant specific, that the risk is likely significant for only a few plants, and that the issue should be closed as a generic issue, with plant specific backfits pursued as appropriate.
1 o l 16 l
4 O PRELIMINARY (SCREENING) ESTIMATES OF THE CONTRIBUTION TO THE CDF FROM RCP SEAL LOCAS AS A RESULT OF LOSS OF COMPONENT COOLING WATER (CCW) OR LOSS OF ESSENTIAL SERVICE WATER (ESW)
RCP seal cooling is supplied by two redundant systems !
in plants with Westinghouse RCPs, or in B&W plants.
One system uses CCW to the RCP thermal barrier. The other system uses RCP seal injection supplied by the charging pumps.
In most CE plants, the only means of RCP seal cooling is with CCW to the RCP thermal barrior. ;
O 1 i
O 17
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I RCP seal LOCA caused by loss of CCW/ESW. (continued))
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Classic sequences:
- 1. Plants with RCP seal injection A. CCW is lost. The HPl and charging pumps are dependent on CCW for seal and pump motor bearing cooling. Therefore, there is consequential failure of the charging pumps, and both means of RCP seal cooling are lost. A RCP seal LOCA l occurs, with some probability. The LOCA cannot i be mitigated because the HPI depends on CCW, and fails.
B. ESW is lost. The CCW heats up and cannot i perform its function of cooling the RCP seals, or l O cooling the charging pumps. The sequence proceeds as in A.
l
- 2. Plants without RCP seal injection.
Here, the loss of CCW leads directly to loss of RCP seal cooling, and a RCP seal LOCA with some probability. The HPI depends on CCW and therefore the RCP seal LOCA cannot be mitigated. !
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'18
l RCP seal LOCA caused by loss of CCW/ESW. (continued))
O -
There are many variants of these sequences, depending 1
on plant specific features A. For plants with seal injection l
.1. The charging pumps may not require cooling (Westinghouse 2 loop plants: Ginna, Kewaunee, ;
Point Beach Units 1 and 2, Prairie Island Units 1
-and 2.) Alternately, the plant may have a backup pump independent of CCW/ESW to suppy seal injection (South Texas, Catawba, McGuire, the Oconee units). Then RCP seal cooling is I maintained on loss of ESW/CCW, and the RCP seal '
LOCA does not occur.
~
O 2. The charging pumps may be cooled by ESW.
Then loss of CCW is not a concern, only loss of ESW. (For example, Beaver Valley Units 1 and 2, ,
Braidwood Units 1 and 2, Byron Units 1 and 2)
- 3. There may be a backup cooling system for the charging pumps, from the fire water system or ;
other system. (For example, Turkey Point Units 3 and 4,' H.B. Robinson, Three Mlle Islared Unit 1, North Anna, Summer).
O 19
RCP seal LOCA on loss of CCW/ESW. (continued)
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B. For all plants
- 1. The plant may have the ability to mitigate a small break LOCA without HPI by cooling down and depressurizing using the steam generators and using low pressure injection systems. The LPI may operate without cooling i in the injection mode, and provision may be made to refill the refueling water storage tank and continuing in injection instead of going to recirculation. (Shearon Harris).
l
- 2. The HPl may not need cooling in the injection mode, and, for a sufficiently small LOCA may even operate in the recirculation mode, l O provided cooling is not lost to the containment fan coolers. l
mitigated. Losses of ESW, however, may be important.
The importance of the sequences will also depend on the initiating event frequency for losses of CCW and l losses of ESW, which depend on plant specific considerations.
For Westinghouse RCPs, the use of the new O-rings decreases the ilkelihood of the RCP seal LOCA.
O 20
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BRIEF
SUMMARY
OF PRELIMINARY ESTIMATES OF CDF O CONTRIBUTION FROM RCP SEAL LOCA INDUCED BY LOSS OF ESW/CCW Fourteen units (nine plants, some dual units) were selected for quantification of the cdf contribution from loss of ESW/CCW- !
Initiating event frequencies were taken from the IPEs, and these were combined with the Rhodes model.
When the Rhodes model was used, the preliminary l estimates of the CDF contribution ranged from 1.4E-3 per year to below 1E-5 per year. For nine units the CDF was below 1E-4 per year.
For comparison, for these plants, the IPEs obtained no O '
CDF contributions greater than 7E-5 per year, from RCP l seal LOCAs induced by loss of CCW/ESW. The differences in results arise solely from the RCP seal l model used. .
This was not a random sample of units, but rather an attempt was made to select plants with a high contribution to the CDF from RCP seal LOCAs induced by loss of CCW/ESW, when the Rhodes model was used.
In addition to the quantitative estimates, plants were looked at qualitatively to see if their ' design precluded a high contribution to the core damage frequency from RCP seal LOCAs induced by loss of ESW/CCW.
Twenty-five units were identified where this was the O case-21
m 8 i Summarv. CDF contribution. RCP seal LOCA on loss of O cewfESw -
39 of the 73 PWRs were reviewed. Of these,5 plants were identified as needing plant specific followup Screening of the remaining 34 plants will be completed in the next few months.
Based on the plant specific nature of the risk, and the results obtained on the 39 units reviewed, the risk from RCP seal LOCA on loss of CCW/ESW is low for all but a few plants.
FUTURE WORK Those plants identified in the screening analyses as O having a possibly significant risk contribution from RCP seal LOCAs induced by loss of RCP seal cooling will be the subject of plant specific followup; RES will work l with NRR to determine whether or not plant specific backfits may be appropriate.
- Some plants, in their IPEs, identified plant improvements which would impact the CDF contribution from RCP seal LOCAs induced by loss of CCW/ESW. If these improvements were made, their effects will be incorporated in the estimates of the CDF contribution.
O 22
CONCLUSION O
Basis for Closure:
Commission's SRM
-Insufficient basis for gains in safety-
- No generic basis ( lasue plant specific)
- Concerns with seal evaluation models
-Industry addressing in IPE program Changes made in Plants:
- SBO rule reduced likelihood of RCP seal LOCA by addition of alternative power sources in certain plants
-IPE plant specific changes
- Maintenance rule reduced likelihood of loss of CCW/ESW systems
-lmproved normal operation RCP seal performance Q (no leak rates greater than 100gpm since 1980)
Plant specific analysis:
-SBO
- Loss of CCW/ESW The staff concludes that:
-The closure.of GSI-23 is appropriate
~
The staff requests ACRS agreement that GSI-23 should be closed O
23 l
- 6 b
v NUCLE AR ENERGY INSTITUTE I
David J. Modeon GN MSION BY E-MAIL June 25,1999 .
TO: NEI Administrative Points of Contact
SUBJECT:
Comment on Proposed Rule, Industry Codes and Standards; Amended i Requirements (10 CFR 50.55a)
On June 25,1999, NEI submitted comments to the NRC on the supplemental ;
i proposed rule that would eliminate the 120 month update for 10 CFR 50.55a. The NEI comments are enclosed. Please nrovit.e this information to the individual (s) in your organization responsible for responding to the l proposed rule.
We encouraged the NRC to issue the rule eliminating the 120 month update requirement with the exception of the rule's plan to implement ultrasonic test gnalification criteria contained in Appendix VIII of Section XI to the ASME Code.
Our comments reiterated the industry positions developed for the May 1999 NRC workshop on the supplemental proposed rule.
l To ensure that the NRC understands the official utility position. we l encourare each licensee to submit a letter to the NRC endorsing the NEI !
response or expressing its nosition.
If you have questions, please contact Kurt Cozens (202-739 8085; koc@nei.org) or me.
l l
Sincerely,-
0 ~Af $k -
David J. Modeen l KOC/
Enclosures e
! c: NEI 50.55a Task Force V) 1776 i STREET. NW SUITE 400 WASHINGTON. DC 20006 3700 PHONE 202.739.0084 F AX 202.785.1998 camCm or0
I l
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David J. Modoen EN ENTON MSION 1
l June 25,1999 ,
' l l
Ms. Annette L. Vietti-Cook, Secretary l U.S. Nuclear Regulatory Commission )
Attention: Rulemaking and Adjudications Staff j Washington, DC 20555-0001 l
l
SUBJECT:
Comment on Proposed Rule, Industry Codes and Standards; Amended Requirements (64 Fed. Reg. 22580)
Reauest for Comments l PROJECT NUMBER: 689
Dear Ms. Vietti Cook:
, The Nuclear Energy Institute (NEI) submits these comments on the supplemental l proposed rule to eliminate the 120-month update requirement contained in !
i 10 CFR 50.55a. With the exception of the rule imposing Appendix VIII of Section XI to the ASME Code, we find this rule beneficial and encourage the NRC to ;
issue it on the previously announced schedule after addressing the comments provided in Enclosure 1.
NEI agrees with the NRC staffs comment from the Statement of Consideration that some ASME Code revisions have strengthened requirements while others have relaxed requirements, bw that in recent years the safety significance of the periodic revisions has declined. This places an unnecessary burden on licensees. Therefore, l we conclude that the 120 month update should be eliminated from 10 CFR 50.55a l and that later editions of the Code should be adopted by the NRC for voluntary use l by licensees.
l 1 NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect / engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy industry.
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w Ms. Ann:tte L. Vietti Ook June 25,1999 Page 2
- k~ The supplemental proposed rule states that the NRC intends to require licensees to implement the ultrasonic qualification criteria contained in Appendix VIII of Section XI to the ASME Code, as discussed in the initial proposed rule (62 Fed. Reg. 63892). The initial proposed rule stated that the Appendix VIII l criteria was justified under the provisions of the compliance exception contained in l 10 CFR 50.109 backfit rule. The use of the compliance exception for L implementation of this new' requirement is inappropriate. The technology and methods contained in Appendix VIII did not exist when the regulations cited as the basis for the compliance exemptions were issued.' Therefore, it is unclear how the cited rules have always required the application of the Appendix VIII methodologies. The incorporation of the Appendix VIII criteria requires a cost- i benefit analysis in accordance with 10 CFR 50.109. Appendix VIII should not be added to the regulations unless a positive cost bene 6t is demonstrated.
The NRC staff conducted a public workshop on May 27,1999, to discuss additional areas that would assist the NRC in deciding on whether or not to issue the supplemental proposed rule. Using input from utilities, the NEI 50.55a Task Force developed responses to the topics identified in the Federal Register. Enclosure 1 provides a summary of these responses. No response was provided to the issue on Potential Effect on State and Other Organizations that Rely on the ASME Code in their Interactions with Nuclear Power Plan Owners.
At the workshop, ASME code representatives expressed concern that the 120-month update requirement would impact the level of participation in the ASME Code and
. would therefore reduce the level of balanced deliberations. It is difficult to state
. with absolute certainty the effect of eliminating the 120-month update on utility participation. However, it is reasonable to conclude that individuals participated in standards development activities because of the perceived value to the individual as well as to the sponsoring organization. The ASME Code has traditionally provided i value to the industry and we believe it will do so in the future.- Other standards l development organizations have adequate industry participation without updating l requirements mandated by regulation. Therefore, we believe that industry will l continue to appropriately participate in ASME Code activities when the 1%conth !
update requirement is eliminated.
Some members of the NRC staff expressed concern that the elimination of the 120-month update would result in a reduction of their ability to impose new requirements, thereby resulting in a more cumbersome regulatory process. The current regulatory process is adequate. The elimination of the 120 month update will not change this; the NRC staff will still have the ability to impose new
-- requirements that are necessary to assure public heath and safety.
F . .
i.,
Ms. Ann:tte L. Vi:tti Cook
- ., June 25,1999 Page 3 l(A l
The supplemental proposed rule (64 Fed. Reg. 22580) and the initial proposed rule (62 Fea. Reg. 63892) failed to address an important implementation issue. Neither defined a method to adopt revisions of the ASME Code or ASME Code Cases in a timely manner. Whether or not the 120-month update requirement is eliminated, the timeliness of the NRC adoption of new editions and addenda of the ASME Code and Code Cases will remain a significant issue. If the NRC staff cannot develop a process to rapidly adopt new editions and addenda of the ASME Code and Code Cases, licensees will continue to make unnecessary submittals to obtain approval to use new criteria. The NRC should either implement an automatic process to adopt new Code editions, addenda, and Code Cases, or revise 10 CFR 50.55a to eliminate j adoption of the ASME Code and Code Cases by reference. l If you have questions, please contact Kurt Cozens at (202) 739-8085 or koc@nei.org.
Sincerely, David J. Modeen KOC/edb Enclosure !
c: Mr. Stewart L. Magruder, Jr., U.S. Nuclear Regulatory Commission ;
Mr. Thomas G. Scarbrough, U.S. Nuclear Regulatory Commission I Dr. Brian W. Sheron, U.S. Nuclear Regulatory Commission ,
l Dr. Jack Strosnider, U.S. Nuclear Regulatory Commission NRC Public Document Room, Project 689 1
k . .
ENCLOSURE 1
~..
- ' NEI RESPONSES TO THE ADDITIONAL INFORMATION REQUESTED BY THE SUPPLEMENTAL PROPOSED RULE
-Item 1 - Potential Effect on Safety: The elimination of the 120. month update
- will not have a negative safety impact.
Most of the changes made to the ASME Code in recent years are editorial, errata, neutral, or a reduction in requirements. An evaluation of ASME Code changes that updated the 1989 edition to the 1992 edition was performed. The evaluation identined 84 changes, of these 77 were editorial,8 were errata, 52 did not change requirements,22 reduced requirements, and 25 increased requirements. None of
~ these were safety-significant or even addressed a specific safety issue. These ASME Code changes have no safety significance.
Of 25 generic letters issued by the NRC concerning issues considered within the scope of Section XI, none were initially addressed through changes in the ASME Code. In some cases, the ASME Code was revised to match up with licensee commitments after the fact. Industry does not typically use the standards development process to address emerging safety issues. If a safety issue should be addressed through the ASME Code, the 10 CFR 50.109 provides method for adoption of the appropriate criteria.
O
- h Item 2 - Selection of the Proposed Baseline Code Editions: The 1989 edition of the ASME Code is an acceptable baseline for ISI and IST, since more than 80% of licensees have already adopted this edition and the remainder will adopt it in the next few years. The 1989 edition provides an adequate level of safety.
The current regulatory requirement for the IWE and IWL subsections of Section XI is the 1992 Edition through the 1992 Addenda. Some licensees have implemented the 1992 edition including the 1992 Addenda, but needed numerous relief requests to have a functional program.. The 1998 Edition of the Section XI addressed the relief request issues. - However, if the final rule requires a baseline using the 1998 C rio edition, then licensees using the current requirement will either need to adopt the later editions or seek a relief request. Therefore, we recommend that the baseline edition for the IWE and IWL requirements be the 1992 edition with the 1992 addenda. In addition, the supplemental proposed rule should adopt the 1998 edition of the ASME Code for voluntary adoption by licensees. This action will
- eliminate needless relief requests.
The supplemental proposed rule would require licensees to implement Appendix VIII of Section XI in accordance with the 1995 edition with the 1996 addenda. The initial proposed rule, December 1997, improperly imposed Appendix VIII based on the compliance exception to 10 CFR 50.109, Rockfitting. The compliance exception should only be used when there is a failure to meet an explicit regulatory l
1 1
.h h requirement (or written commitment), i.e.,~ a "known and established standard," in the words of the Commission in the Statement of Consideration for the 1985 backfitting rule. Citing broad standards such as the General Design Criteria (GDC) or Appendix B results in regulatory instability through constant reinterpretation of requirements, something the Commission warned against when it promulgated the backfitting rule.
Consistent with the Commission's stated intent in the backfitting rule, the compliance exception should only be used in the following circumstances where:
L. A licensee fails to meet an explicit regulatory requirement (or written commitment) because of omission or mistake of fact e ' Plant systems structures or components fail to meet regulatory requirements, such as the functional requirements of a Technical Specification The NRC staff has not made this case in imposing Appendix VIII.
If the NRC does sctisfy the backfit criteria defined above and imposes Appendix VIII, the baseline criteria should be ASME Code Case N 622, not the editions cited in the supplemental proposed rule (1995 Edition including the 1996 Addenda). The 1995 edition with 1996 addenda contain criteria that is impractical to implement.
The NRC staff acknowledged this at the May 27,1999, public workshop. Code Case
. (h .
N-622 provides appropriate criteria that can be implemented by the Performance Demonstration Initiative.
Item 8 - Regulatory Benefits (or Hardships) to Licensees, Industry Suppliers (Including Vendors), Nuclear Insurers, States, Standards Organizations, and Others: The elimination of the 120 month mandatory update
- willincrease the regulatory stability at nuclear power plants. The establishment of baseline ASME Code editions will reduce the unnecessary burden to make changes not essential to safety. The continuing plant implementation activities will be correspon'd ingly reduced. The result of this stability will be higher quality inspections by the licensee and its vendors with more efficient use of resources on matters directly related to safety. In addition, licensees will eliminate the re-submittal of relief requests associated with the 120-month update. We estimate that this will eliminate between 20 to 30 re-submitted relief requests for each plant.
This will result in a reduction of 2000 to 3000 re-submitted relief requests to the NRC staff every 10 years.
At the NRC_ workshop, the representatives of the ASME Code expressed a concern that licensee participation at its meetings would decline if the mandatory 120- '
month update was eliminated. This might, in their opinion, result in a future
'. reduced ability to develop necessary safety impmvements. In summary, the ASME
'1- Code representatives indicated that elimination of the 120-month mandatory update would be a hardship. The logic for this conclusion is not readily apparent.
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- Revisions to the standards _ of other standards development organizations (SDO) are
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not regulated by the NRC. Yet, these SDOs are still viable and provide value to the industry. We believe that as long as the ASME Code provides value to the industry that utilities will participate in the Code process.; It is also noted that the SDO activities and resulting standards should not be used as a surrogate for regulatory ,
activity managed by the NRC staff. 1 i
' Item 4 - Reduction in Burden on Licensees ~ to not Update their ISI and IST
- Programs and Related Procedures: Based on inputs from severallicensees, it is estimated that a typical plant will spend between $550,000 and $1,550,000 to
- update their IST, ISI, and IWE/IWL programs each 10-year interval. The elimination of the 120 month update provision of $50.55a will save the nuclear utilities between $55 million to $155 million every 10 years. Further details of these cost estimates are provided in Enclosure 2.
Item 5 - Potential Effect on the Reduction in Number of Licensee Submittals (e.g. Relief Requests) Associated with ISI and IST: The elimination of the 120 month update requirement wil) delete the need for licensees to re submit its relief requests because of the update. Currently, a typical plant has 20 to 30 relief requests that could require re approval by the NRC staff as a result ;
of the 120-month update. Implementation of the proposed rule could eliminate the !
C need for the NRC staff to re-approve 2000 to 3000 relief requests. I Some relief requests occur because the NRC staff has not endorsed published ASME Code revisions, updates and code cases. This rulemaking does not contain any ;
provisions for the NRC staff to expedite adoption of these documents. Therefore, licensees are likely to continue to have a need to submit relief requests for later ASME Code criteria. However, these are only a fraction of the total number of relief requests requested by each licensee. In addition, some licensees are likely to choose ;
to selectively implement a portion of a later edition of the ASME Code rather than ;
to adopt'an entire edition of a revised Code edition due to cost benefits. l At the May 27 NRC public workshop, a question arose concerning how many of these relief requests would be eliminated iflater editions of the Code were adopted by a licensee. While a rigorous survey oflicenooes has not been performed, we did_
- obtain input on the number of relief requests submitted by one licensee to the NRC staffin the interval between 120-month updates. This licensee submitted 35 relief requests to' the NRC during the 10-year interval period. Of these,24 relief requests
sought NRC permission to waive an inspection due to lack of access or undue hardship. These 24 relief requests are likely to require NRC re approvalif the 120-
! month update requirement is retained. The other 11 relief requests sought NRC permission to use a Code Case or other special criteria. Some of these 11 relief requests would have been absorbed into the licensee's programs iflater editions of (Q the ASME Code were adopted as a result of a 120-month program update.
3
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I i
This is the same situation that exists today because of the inability of the NRC to adopt later editions of the ASME Code in a timely fashion. We recommend that the i
NRC automatically adopt published versions of the ASME Code six months after its l publication unless a direct conflict exists with current regulations. l Item 6 - How will this Rule Change Affect the Range of Code Editions l Applied by Licensee: The supplemental proposed rule will have little effect on l the range of code editions applied by licensees and the adoption of unique plant j specific critena. )
Over 80% oflicensees have currently adopted the 1989 Edition of the ASME Code l as the requirement for existing ISI and IST programs. In the next few years, the remaining licensees are expected adopt the came edition. Baselining the ISI and IST programs to the 1989 edition will bring greater uniformity to the basic set of i requirements that the NRC finds adequate and sufficient. If the NRC staff had i updated 10 CFR 50.55a approximately every 3 years as they have said in previous !
meetings, approximately one third of the licensees would be on one of the editions of !
the ASME Code adopted by the NRC over a ten year period. In contrast, the l elimination of the 120-month update will provide greater consistency than the l l
present regulation.
In the future, the most licenses will be using the same edition of the ASME Code for the plant programs (ISI, IST, IWE or IWL). However, focused ASME Code criteria may be unique for specific topics. This situation exists because of the following reasons:
l i
. Existing regulations permit licensees to use later editions of the ASME Code adopted in 10 CFR 50.55a l
. Current regulations allow licensees to adopt portions or editions or addenda adopted in 10 CFR 50.55a as long as all related requirements are met
. Regulations allow for relief from impractical requirements and allows for
- technically justified alternatives
. The NRC adopts ASME Code Cases and permits licensees to implement these alternative criteria Item 7 - Relationship of Risk-Informed ISI and IST Developments in Relation to ASME Section XI and OM Codes: The elimination of the 120-l month update requirement from 10 CFR 50.55a will not have any impact on licensees adopting the ASME Code Cases or ASME Code criteria related to risk-informed ISI or IST.
The ASME Code has adopted several Code Cases on risk-informed ISI and IST. By definition, ASME Code Cases are alternative Code requirements that licensees may voluntarily adopt for use. It is understood that the Code Cases when incorporated into the text of the ASME Code will be implemented as non mandatory appendices 4
t
l for voluntary use. Currently, the NRC has not adopted the Code Cases in 10 CFR 50.55a nor in the regulatory guide used to adopt Code Cases.
According to the provisions of the supplemental proposed rule, future editions of the
' ASME Code will be adopted for voluntary implementation by licensees. Hence, the conclusion that the elimination of the 120-month update will not have any impact on the licensees adopting risk-informed ISI or IST is valid.
Itern 9 - Application of Portions of the ASME Codes Incorporated by Reference in the Regulations Subsequent to the Baseline Editions:
Whether or not the NRC issues the supplemental proposed rule, licensees are likely to seek relief requests to adopt a portion of the ASME Code rather than implement the entire edition of the ASME Code. We anticipate that licensees will maintain the current frequency of submitting relief requests. This conclusion is based on the following:
. In recent years, the typical Code revision has reflected more realistic criteria by defining new techniques, improved methods, and a better understanding of plant operating experience. These changes reflect an understanding that previous Code criteria posed unnecessary burdens that were not technically justified. The revised Code criteria are typically issued first as a Code Case for voluntary licensee use.
. Traditionally, licensees have selectively adopted these new ASME Code criteria using a relief request that references the Code Case as the technical basis. This is necessary because the NRC process to adopt new editions of the ASME Code or Code Cases takes several years. This process is not timely for licenoes; their needs are measured in months, not years.
The proposed regulatory changes do not correct these situations. Licensees will still need to seek relief requests to implement revised ASME Code criteria on a time'y basis. The regulations should be revised to automatically adopt Code Cases and revisions to the ASME Code within 6 months of their publications. The NRC should take exception to this automatic adoption only when Code revisions are inconsistent with existing regulations.
) The NRC should also consider implementing changes that will permit issuance of generic relief requests to adopt Code revisions for direct use by alllicensees. In addition, the NRC should revise the regulations to permit licensees to selectively use portions of ari ASME Code edition or addenda adopted in the regulations by reference without requiring the licensees to submit a relief request. This is reasonable because the NRC has approved the ASME Code and the licensee will be required to adopt all related provisions of the later criteria being implemented.
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Item 10 - Clarity of Supplemental Rule: The previous items and the enclosure's cover letter provide comments on the supplemental proposed rule larec7ge. The following comments are additional to those previously provided:
e Federal Register, volume 64, page' 22584, paragraph I, states that time limits
..could be imposed on ISI relief requests. The purpose of this time limit would be to ensure that the licensee considers future plant conditions or equipment that might' enable the examination to be conducted. The supplemental proposed rule does not explicitly address this. An unnecessary burden could be placed on licensees should this type oflimitation be placed on all relief requests issued.
This could result in E,000 to 3000 additional relief requests needlessly being submitted to the NRC staff because a random time limit is placed on all relief requests. Such a relief request limitation should be founded on a direct regulatory requirement or it should not be used by the NRC staff to require it to be resubmitted based on time.
- The initial proposed rule 62 FR 63892, found the ASME Code 1995 Edition through the 1996 Addenda to be technically acceptable. This edition and addenda should be adopted in this final rule for voluntary licensee use.
. ~ The final rule should not establish, as the baseline ASME Code, any editions and addendum other than as specified in the supplemental proposed rule or in our comments. Requiring any other baseline Code could result in industry missing an opportunity to identify significant public comments.
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.e Enclosure 2 O
ir 4 - asoucriox ix suno8x os t'c="szzs ro xor cro^re rnein ist AND IST PROGRAMS AND RELATED PROCEDURES ACTUAL COST FOR IST UPDATE AT ONE PLANT IST Program Costs Program development and supervision Contractor hrs 2220 Program engineer / supervision hrs 890 Total hrs 3110 x $80.00/hr 8 248.800 1
IST Program Costs i System Engineering review l Contractor hrs 3279 l System engineer / supervision hrs 80 )
Total hrs 3359 x $80.00/hr 8 268.720 1 IST Imolementation Costs ;
Revision of test procedures l Program engineer hrs 960 Reviewer hrs 300 l Review of data sheets 600 Revision ofIST base Document 200 Total hrs 2060 x $ 80.00/hr $ 164,800 IST Implementation Costs Operations surveillance procedure revisions hrs 1,730 .
Engineering review hrs 1.1E4 Total hrs 2,866 x $ 80.00/hr $ 229,120 IST Total Cost - Example Total program development $ 517,520 Totalimplementation costs $ 393,920 NRC review of relief requests S 50.000 Total cost for IST update at one plant 728bi1Q 1
I.
h (G - OTHER PROGRAMS ESTIMATES 1
. . Inservice Inspection Program Update Range $200,000 to $500,000 per unit Easier characterization of hardware
. IWE/IWL Updates Costs $50,000 to $100,000 per unit estimated No plants updated yet
=> Less prescriptive
=> Less chance of boundary changes
. . Estimated Cost to Update Per Unit IST Program $300K to $950K2 ISI Program $200K to $500K IWE/IWL Program $ 50K to $100K Total Cost Per Unh $550K to $1550K Total Cost to Industrv $55M to $155M 2 Estimates for these programs were provided by severallicensees. These estimates did not include the level of detail discussed on the IST program. The cost ranges provided in this section were based on these licensee inputs and the technicalinsights of the NEI 50.55a Task Force.
- The cost example for the IST program represented the actuallevel of effort for one q licensee's program update. Other licensees provide cost estimation, but these did not include the same level of detail. The cost ranges provided for the IST program updates were based on
. - these licensee inputs and the technical insights of the NEI 50.55a Task Force.
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