464th Meeting - July 15, 1999
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
***
464TH ADVISORY COMMITTEE ON REACTOR
SAFEGUARDS (ACRS)
U.S. Nuclear Regulatory Commission
Two White Flint North
Conference Room 2B3
11545 Rockville Pike
Rockville, Maryland
Thursday, July 15, 1999
The committee met, pursuant to notice, 8:31 a.m.
MEMBERS PRESENT:
DANA POWERS, Chairman, ACRS
ROBERT SEALE, Member, ACRS
GEORGE APOSTOLAKIS, Member, ACRS
MARIO BONACA, Member, ACRS
JOHN BARTON, Member, ACRS
GRAHAM WALLIS, Member, ACRS
ROBERT UHRIG, Member, ACRS
THOMAS KRESS, Member, ACRS
WILLIAM SHACK, Member, ACRS
JACK SIEBER, Member, ACRS. P R O C E E D I N G S
[8:31 a.m.]
DR. POWERS: The meeting will now come to order. This is
the second day of the 464th meeting of the Advisory Committee on Reactor
Safeguards. During today's meeting the committee will consider the
Proposed Final Regulatory Guide for Updating Final Safety Analysis
Reports, Control Room Habitability, Proposed Amendment to 10 CFR 50.55a,
Report of the Reliability and Probabilistic Risk Assessment and
Regulatory Policies and Practices Joint Subcommittee Meeting, Proposed
Plan for the Preparation of the Annual ACRS Report to the Commission,
Proposed ACRS Reports.
This meeting is being conducted in accordance with the
provisions of the Federal Advisory Committee Act. Dr. Richard P. Savio
is the designated federal official for the initial portion of the
meeting.
We have received no written comments or requests for time to
make oral statements from members of the public regarding today's
session.
A transcript of portions of the meeting is being kept, and
it is requested the speakers use one of the microphones, identify
themselves and speak with sufficient clarity and volume so they can be
readily heard.
I open the meeting by asking if members have any comments
they would like to make.
[No response.]
DR. POWERS: Seeing none, let's turn to the first item of
business today, which is the Proposed Final Regulatory Guide for
Updating Final Safety Analysis Reports. John, I think you are the
cognizant member on that.
MR. BARTON: Yes, sir.
DR. POWERS: And I will ask you to take charge of the
meeting.
MR. BARTON: Good morning. The purpose of the meeting this
morning is to review the Proposed Final Regulatory Guide 1.181. The
content of the update is Final Safety Analysis Reports in accordance
with 10 CFR 50.71e and NEI Document 9803, Revision 1.
The committee last reviewed matters related to Updated Final
Safety Analysis Reports in December 1997. At that the time the staff
proposed issuing a Generic Letter. In an SRM the Commission sent down
in June of 1998 they disapproved the proposed Generic Letter, directed
the staff to work with NEI and other stakeholders to finalize an
industry guidance document that the NRC could endorse.
Since then the industry and NRC have been working on such a
document and today we are going to hear from NEI on their proposal,
which is 9803, Rev. 1, and then we will hear from the NRC staff on the
proposed Regulatory Guide to endorse the NEI document.
At this time I will -- oh, the committee action with respect
to this, there will be a letter as a result of this presentation today.
Now, I will turn this over to Russ Bell from NEI, who will lead the
discussion on the 9803 document. Russ.
MR. BELL: Good morning. I have a number of slides to go
through today and we will try and get through those and get to your
questions. I thank the ACRS, it was kind of a joint invitation of the
committee and the staff to come and speak with you this morning about
NEI 9803. The reason it makes sense, I am pleased to say, is because
the NRC's Reg. Guide on the FSAR Update Rule is essentially go endorse
the industry guidance, and that is the culmination of a really
productive interaction between the industry and the NRC to arrive a
mutually acceptable guidance in this area.
FSARs -- FSAR updates is one a triad of issues we call -- we
like to refer to, the other two issues being 50.59 and design bases, and
at NEI, I work on each of those, and each of those is in a various state
of completion. This one is the farthest along. I am happy to say there
is more background material on this than there are things left to do.
The reason these issues are important is because they are somewhat
foundational, they touch on all, nearly all the issues we work on at NEI
and that come before the ACRS. So it is important, I think, for the
committee to hear about these things like the one on the agenda today,
and to understand them.
So, with that, I will get into it. I will tell you I want
to talk about -- I will give you an overview of the guidance itself.
There were some changes that we made to -- there were minor changes
around the edges when we revised the document last month and issued it
to the industry and to the NRC. And I will touch briefly on the status
of implementation.
In the industry we had a workshop last month which was very
well attended, this was one of the main -- this and 50.59 were the main
focuses -- foci of that, of that meeting.
Briefly through the background, which actually goes back
considerably farther on this issue than this slide would indicate. This
issue really started because FSARs started out 30-odd years ago so very
different, each one a work of art in itself, unique. Over the years
they grew, but, again, they each out started out different. They went
from there to being maintained differently by the licensees. One reason
for that is there was no guidance on how to maintain them, on how to
update them. The Update Rule wasn't even issued till 1981 -- I think
the Update Rule itself doesn't go back as far as many of the plants.
And then the FSAR plays, frankly, a different role at different plants.
So these factors, coupled with the sheer side of some of
these documents made it, you know, not too surprising to -- really
probably to anyone that the NRC and the industry identified a number of
discrepancies or weaknesses in their FSARs, led to the lessons learned
reviews, outcomes of the Millstone, Maine Yankee lessons learned, and
increased focus on the SARs by both the NRC and the utilities. But
there was never a safety issue, never a safety issue.
There is still a -- there is certainly a sense that there is
a rule on the books says we need to have a SAR. It really is intended
to be complete and accurate, as the words -- as that phrase has come to
be. And so it was taken seriously that something needed to be done.
This situation was tailor-made for the NRC to grant some enforcement
discretion for licensees to refocus on their SARs and bring them up to
speed, again, there being really no urgent safety issue involved. And
that is exactly what they did. That enforcement discretion continues.
The industry worked -- really expedited work to develop a
guideline last year and we issued it in November, that was Rev. 0. That
document was attached to a Draft Reg. Guide. Public comments came in in
April. And we revised the document as a result of that iteration and
issued it, as I say, in June in a Rev. 1 form, and I think the committee
has that document.
I could include on the background here that -- as I just
mentioned, that the Rev. 1 document was issued, and we did that at our
June workshop. Since then we have followed up and sent copies to every
utility at all our contacts, and copies to NRC with a request to endorse
the document in a final Reg. Guide this time.
We got on that path, the staff flirted with a Draft Generic
Letter, and I think that was last year as well. But, again, our
preference was to stay on the industry guidance track and that is
exactly what we did.
I want to get into the guidance itself, the main purpose
again of which is to provide really the first ever guidance for meeting
the requirements of the FSAR update rule 50.71e, which says basically
this: the SAR needs to be updated to reflect new NRC requirements, and
the effects of changes, evaluations of changes, and new analyses that
might have been performed as a result of safety issues over the years.
It's essentially what the rule says. There's obviously reporting
requirements that go along in it, but this is the meat of the guidance.
But it's not every new requirement, every change, every
evaluation, or every new analysis that needed to be reflected in the
SAR, and that's really where the guidance came in. We in the staff
settled on -- well, we recognized we needed a set of criteria for
determining when something needed to go in the SAR. And we came up
with --
DR. APOSTOLAKIS: Excuse me.
MR. BELL: Sure.
DR. APOSTOLAKIS: So how often do you expect, how frequently
do you expect the FSAR to be updated? Every time there is a change, or
there will be fixed intervals?
MR. BELL: In fact there's two ways to answer that. With
the SARs going to electronic formats, the licensees actually keep them
very nearly real-time. Once a change is made, approved, signed off, and
so forth, it can be reflected in the SAR for the utility's own use. But
now I can answer it from the regulatory-requirement perspective. You
can take up to 24 months in terms of your -- which is generally designed
to match your fuel cycle.
DR. APOSTOLAKIS: So, on another subject, I can tie this
then to the notion of a living PRA, and since you say you can update
this very quickly, maybe the PRA can become alive very quickly too at
regular intervals, right?
MR. BELL: Perhaps.
DR. APOSTOLAKIS: Yes.
MR. BELL: Perhaps.
DR. APOSTOLAKIS: Interesting.
MR. BELL: This is of course a very deterministic --
DR. APOSTOLAKIS: I know.
MR. BELL: View of the plant.
DR. APOSTOLAKIS: But it's a basis, though. It has --
MR. BELL: Yes.
DR. APOSTOLAKIS: All the information that you need. Not
exclusively. There may be more.
MR. BELL: The criteria we -- what we said to ourselves, we
in the staff and with the help of a task force of utility guys, folks,
and we said well, what is it about the SAR that makes it unique? What's
the really important information in there?
It's really -- we turned up that it's -- the SAR contains
the -- presents the design bases, the safety analyses for the plant, and
description to go along with those things provided an adequate
understanding. That's sort of a very practical view of it. It also
comes from -- you can get there from 50.34b, which is the rule on the
format or content of original final safety analysis report. So, you
know, if you want a license here, you've got to give us this
information.
These items, the design basis safety analyses and the
description that goes along with those, are very clearly laid out as
requirements in the original SAR. It makes sense that that's the
critical information that also needs to remain up to date. So we
focused on these areas for -- as our criteria for determining which of
those changes, which of those new requirements, which of those new
analyses need to go in.
The guidance itself breaks down, you know, when you have a
flow chart and there's really just two or three boxes on it. It's
really quite straightforward. It's just that it hadn't been written
down or thought through clearly. We've now done that. In the case of a
new requirement, did it result in a change to your plan? Did it produce
new design basis safety analyses or description that belongs in the SAR?
Now, not every new requirement does that. Take one that
does, the ATWS rule. Really define a new scenario for the plant that
was important enough. The NRC issued a regulation, you know, you shall
be able to respond to this scram situation or transient without scram.
DR. KRESS: Is there any definition of what constitutes a
change? Just replace one minor component, that could be considered not
a change.
MR. BELL: In fact, the definition of change actually is in
the 50.59 world, as you might expect. And so I would probably point you
to that.
DR. KRESS: It doesn't qualify for 50.59, then it's a
change?
MR. BELL: You could have -- 50.59 of course wouldn't come
into play if the change was governed by, you know, some other rule.
DR. KRESS: But you would expect it to be consistent
with it.
MR. BELL: Absolutely. Absolutely.
DR. POWERS: Tom, at the end of a 12-month period you were
supposed to collect together all these 50.59 changes, and they were
supposed to appear in the FSAR.
DR. KRESS: That what I was --
DR. APOSTOLAKIS: So the 50.59 changes do appear in here.
DR. POWERS: Yes, I think they have to show up.
MR. BARTON: Yes.
DR. APOSTOLAKIS: They have to show up.
MR. BARTON: Yes.
DR. POWERS: They have to show up because they are changes
in the facility.
MR. BELL: Remember, we said that not every change, new
requirement, or new analysis would show up in the SAR. In fact -- well,
let me finish this. For instance, the fitness-for-duty rule really
doesn't produce design bases -- so here's a new requirement that would
really screen out of our process -- a licensee may choose to summarize
that type of -- or supplement their SAR with that type of information.
But we don't see that as coming from the regulation, and we don't
capture that as a practice that's necessary for the guidance.
The maintenance rule is another interesting case. As, you
know, prominent and provocative as that rule can be, really, it's how
you maintain your plant, not -- it doesn't go to the core of your design
bases. It's not new safety analyses. And so that too would be an
optional thing in terms of whether a licensee discusses that in their
SAR or not.
The chart on changes isn't much more complicated. Does the
change affect existing SAR information, to get to your question.
Obviously if a change you make causes a SAR to be incorrect, you've got
an inconsistency you're supposed to resolve. But it doesn't just stop
there, because a change could be of such significance that it could
produce new design bases safety analyses and require a description to go
along with it. So we bring you down into this box, and you'd answer
that question.
It's really of significance or, as Joe whispered to me, a
level-of-detail kind of issue. And if it meets those criteria, then you
need to go update the SAR for that change. So it's not every change.
There may be very, you know, there's hundreds of minor changes that
really wouldn't rise to the level of either affecting the SAR
information or modifying the design bases or safety analyses.
Similarly, -- I wish all the issues had flow charts that
were this simple. Similarly, for analyses -- now, this would be, you
know, as a result of Generic Letter or Bulletin perhaps, and you are
asked to perform an analysis to make sure this system will operate as
you think it will. We have -- we, NRC, have identified a new concern.
A lot of that comes out and doesn't really cause you to
cause any changes to the plant. You run your analysis and you determine
that, no, my design -- I hear your concern, but my design is fine as is.
You respond to that Generic Letter or Bulletin, but, really, there is no
impact on the SAR.
The other case certainly may be, and there are examples both
ways, where NRC has identified an issue that perhaps wasn't well handled
in the existing design, it led to a design change and that design change
would get -- if it involved new design bases, safety analyses, et
cetera, would get it incorporated into the SAR.
I have, let's see, a couple of examples, and I apologize for
not bringing a set of slides, but do they have their packages of slides
yet, Mike?
MR. MARKLEY: Yes.
MR. BELL: Okay. In there, -- then I won't be too ashamed
to put this up. In there are some examples, and you can look at these
as we talk or at your convenience later. We talked about the first two,
Generic Letter on testing of safety-related circuits. Here is a case
where a licensee was asked to verify that the circuit design met the
surveillance requirements. They went and did that, found everything was
fine and there was no change to the SAR.
MR. BARTON: Now, if the licensee determines as a result of
that he had to make a design change to the plant, then he would have to
reflect that description in the SAR?
MR. BELL: It is possible. Again, it would be a level of
significance thing. This seems to involve some potential inadequacy of
the surveillance requirement, and that may be a level of detail, the
type of information that would not need -- that isn't now reflected in
the SAR. It doesn't sound like design bases or safety analyses and
wouldn't rise to the level.
Certainly, if they made -- if this circuit design was
described in the SAR or the surveillance requirement that needed to be
changed was described, and they made a change, obviously, you need to
come back and fix that.
DR. KRESS: The shortcut description of your flow diagram
might be --
MR. BELL: Shorter?
DR. KRESS: Yes.
MR. BELL: Great.
DR. KRESS: I will give you a one-liner. If the change
makes your FSAR wrong, then change it.
DR. APOSTOLAKIS: What is wrong?
DR. KRESS: If you read it, you would have a wrong
impression of the plant.
MR. BELL: We would only complicate it somewhat more than
that because there may be new information that comes along. You know,
station blackout, a whole new genre of discussion wasn't even in there
before. So the fact that you added a blackout diesel and change -- it
wouldn't make the SAR wrong necessarily, but it would not be complete
any more, we would say.
DR. KRESS: Wouldn't be complete. That is a little
different.
DR. APOSTOLAKIS: Was there an answer to your question about
what is a change?
MR. BELL: That is one answer, if it affects your SAR.
DR. KRESS: It affects your SAR, then it is a change.
MR. BELL: In this context.
DR. APOSTOLAKIS: It is almost circular.
DR. KRESS: That is a circular.
DR. APOSTOLAKIS: That is a definition of change.
MR. BARTON: There is a definition in the NEI document, 612,
which talks about what kind of changes, what are changes.
DR. APOSTOLAKIS: So it does not define, it just gives
examples?
MR. BARTON: It describes them.
MR. SIEBER: It is my understanding, though, that you are
not limited to some minimum set of things that you can put in the SAR.
MR. BARTON: That's right.
MR. SIEBER: An example would be the mini-flow. It may not
be described in the SAR, the plant may be adequate. When you analyze
it, you can determine that it is adequate. But that analysis becomes
part of the design basis. It really should be reflected in the SAR, at
least from the standpoint of future use as a reference to say let's not
remove this sometime in the future.
MR. BELL: Absolutely.
MR. SIEBER: So the SAR continues to grow partly by
regulation and partly by the licensee's desire to have a complete
description of the plant.
MR. BELL: I think that is a good summary. Obviously,
changes include things that are NRC inspired, like the mini-flow issue,
Bulletin 80.04, but this last one is a change the utility decided was
needed, the high-point vents on the safety injection line. This went to
functionality, operability of the system and the utility determined that
it rose to the level of the type of description that you would need to
supplement your SAR with.
These are the examples that -- well, we presented these at
actually our workshop in the fall of last year, so these are the types
of things that we are putting out in front of the utilities to provide
them guidance. We have supplemented these somewhat with some more
utility-specific experience. We did that in our last workshop. But
similar to these, this is what the utilities are hearing.
And we can come back to that, but I can -- there is a whole,
there is another part of the document and we call it Appendix A. We
wanted to distinguish it from the guidance itself, the guidance that is
there to help you meet 50.71e. Appendix A deals with optional
modifications you may want to make to your SAR.
The other thing utilities are doing now, it is kind of
satisfying, I really think they do not have blinders on, they are not
merely checking the accuracy, if you will, in a pure sense of the SAR.
Does the plant look exactly like I describe it here, or do we operate it
exactly? They are taking this opportunity, and some resources have been
given them from their management because of the tension of this issue,
to make some real improvements. And 9803 I think is important, it gives
them some tools to help them do that. It lets them reformat things. It
lets them remove some dead wood. It lets them simplify some of the
information and this is going on, I think it is all to the good.
Many utilities make to make this -- as I said, the role of
the SAR is different depending on where you go, but many utilities want
to make it more integral to what is going on.
Obviously, if you do a document, you put it on the shelf and
you never go to it except every 24 months, you have kind of designed
yourself a problem. On the other hand, if you use that document more
and more on a daily basis or it becomes a box on your flow chart for
configuration management, then it is much more likely to stay accurate
and up to date.
So these kinds of things are going on, and I think 9803
gives them some tools.
DR. APOSTOLAKIS: Let me ask a naive question. Why do we
have to do all this? Why do we need guidance when to change the FSAR
and so on? Do other countries do this, or is it the unique legal system
we have here?
MR. BELL: I tell you, we never did an international --
DR. APOSTOLAKIS: Isn't it a waste of time to spend
resources on reformatting the FSAR?
MR. BELL: Well, the simple answer is there is a rule on the
books we have to meet. Without guidance, it can be interpreted as any
new requirement, any change, any new analysis needs to go in.
DR. APOSTOLAKIS: But I mean the issue --
MR. BELL: But that was really no one's intent, not ours or
the staff's.
DR. APOSTOLAKIS: The industry has used in another context
the words "good business practice," QA and so on. Would it not be good
business practice to have an updated FSAR without the regulations
requiring it?
MR. BARTON: No, George, I think you found during the
Millstone investigation that that wasn't really going on. People were
-- it was varying degrees of licensees doing various things to FSARs.
Some of them doing a real good job keeping it up to date. Some of them
hadn't updated them for a long time.
DR. APOSTOLAKIS: But the rule existed.
MR. BARTON: Even though the rule existed. The rule existed
but, you know, I don't think it was really looked at. There was not a
focus to the agency. Inspection guys were not really looking at that in
a lot of detail.
DR. APOSTOLAKIS: Isn't it a bit sad, though, that we have
to regulate this kind of thing?
DR. POWERS: Well, I think you raise an interesting
question, George, when you say, what about other countries? We know
that, for instance, in several of the European countries that the
general rule is that the plants be safe and at the state of the art all
the time. Now, in practicality that means that at a frequency of about
ten years, it is different for different countries, but a fairly
exhaustive examination is done and there is not such a thing as a
backfit rule. If the technology has moved on, then they update, and
they were fine. It is a fairly big undertaking in Germany when those
things go on.
I think it would be interesting to explore some of these
alternative approaches to this issue. Now, is it necessary? Let me
point to the experience with the DOE reactors where, indeed, there was a
Safety Analysis Report that was written at the time that the reactors
were prepared and there was some effort to keep it up to date for four
or five years, but then it fell into a forgotten dustbin and we started
adding improved systems on systems on systems, and it quickly became --
when the guy that had it all in his head retired, the whole house of
cards started coming down because you literally had conflicts in systems
and whatnot.
DR. APOSTOLAKIS: That is not good business practice.
DR. POWERS: You are absolutely right.
DR. APOSTOLAKIS: What I am saying is that it is common
sense to have a central document with all this information in it.
DR. POWERS: Well, I think when you chased it down to try to
find out why it was not done at DOE, -- because people at DOE are not
stupid, and they said, well, it makes common sense to keep some
documentation of where all the piping is and things like that in the
plant, -- you found out that there is a finiteness of resources, and
there is no penalty associated with skipping the update one year. And
you can skip the update one year every year, and every year the penalty
associated with it is still in the future, but someday it does
eventually catch up with you. And that is -- I think that is the
problem is that there is no immediate penalty associated with deferring
it one year.
MR. BARTON: Jack, did you have something to say? You look
like you want to jump in here.
MR. SIEBER: Yeah, I guess there is a number of issues.
Number 1, the SAR in most utilities is the primary document that is used
to make changes under 50.59. So that becomes a reference both for the
NRC, all the oversight committees, the safety review boards, the design
engineer, as the basis of design information in the plant. Not
everybody did it and regulation regulate to the worst performer, and
that is unfortunate, but that is the way it is. And so that is why you
end up with regulations like this.
DR. APOSTOLAKIS: Well, how about if you say that if you
want to use 50.59, you have to have an updated FSAR and leave it at
that?
MR. SIEBER: You use it every day.
DR. APOSTOLAKIS: And it will be updated, I can assure you.
It is just that this proliferation --
DR. POWERS: Clever, George. Clever.
DR. APOSTOLAKIS: This proliferation of regulations, I mean
to tell people to update a document that they need to use anyway in
other regulations. Didn't the Vice President advocate simplicity in
documents?
MR. BARTON: Yeah, and they keep passing new laws all the
time, George.
DR. KRESS: Is that that guy from Tennessee you are talking
about? That guy from Tennessee, the one that invented the Internet?
DR. APOSTOLAKIS: From Tennessee, yes. Do you discount the
pronouncement because he is from Tennessee?
MR. SIEBER: It seems to me that before they passed the
Update Rule, it was typical that utilities didn't update.
MR. BARTON: That's right.
DR. UHRIG: That's right, they didn't.
DR. APOSTOLAKIS: So how did they use 50.59 then?
MR. SIEBER: Good question.
MR. BARTON: Don't ask, George. Don't ask.
DR. UHRIG: Well, I can tell you what we did for many years.
We had a finite set of documents we kept up to date, there were like 300
diagrams and drawings were literally up to date, and that was what we
used. It was not the complete FSAR. FSAR was a historical document
until it was required to be brought up to date.
DR. APOSTOLAKIS: I understand that, but still, I am at a
loss understanding why we have to regulate every little --
MR. MARKLEY: George, I think one of the problems you run
into with this is that there is a distribution in the population of the
FSARs. Some of them are three volume sets and some of them are 30
volume sets. And the level of detail in those, I mean if you have a
very scant FSAR, that changes the level of depth you would theoretically
have to go through in doing your 50.59.
DR. APOSTOLAKIS: But this rule doesn't help us with that.
It doesn't tell you to have a uniform set.
MR. MARKLEY: No, no, no. This is --
DR. APOSTOLAKIS: It just tells you make sure that what you
have is up to date.
MR. MARKLEY: Right.
MR. BARTON: And it gives you guidance.
DR. APOSTOLAKIS: So it doesn't apply here.
MR. BARTON: And it gives you guidance as to what you have
to consider in updating, and it gives you options on what you don't have
to put in the SAR.
DR. APOSTOLAKIS: Well, has anybody ever thought that maybe
this is part of the intrusiveness of the regulations that we are trying
to reduce?
MR. BARTON: I don't think so.
DR. APOSTOLAKIS: No. Well, if you guys say it is okay, who
am I to --
DR. KRESS: It doesn't sound like a big deal, George.
MR. BARTON: No, I think this guidance is --
DR. APOSTOLAKIS: Well, we are spending an hour-and-a-half
talking about it.
MR. BARTON: I mean this is good guidance, you get some
uniformity. I think this is good guidance. You get uniformity across
all licensees as to, you know, what is important to keep and what is not
important.
MR. MARKLEY: Right. And it enables them to look past hat
level of detail problem that they have got and wonder how they are going
to deal with it from one site to the next.
DR. APOSTOLAKIS: Well, I am impressed by the unanimity of
the opposition, so --
DR. POWERS: Well, again, George, I think that it doesn't
hurt for us to spend some time thinking about are there -- not in
connection with this particular issue, but, in general, for us to think,
are there alternate paradigms that could be explored here?
DR. APOSTOLAKIS: Yes. Exactly.
DR. POWERS: And it might be something that we want to do
with our -- interrogating our quadripartite partners to understand a
little bit more about their rationale and approaches on this, because it
may well be that in the future an alternate paradigm is more useful to
us.
DR. APOSTOLAKIS: Right.
DR. POWERS: Especially if the uses that we put the FSAR to
in the course of the operating of the plant evolve in the direction of
greater use of risk.
DR. APOSTOLAKIS: And we do have an alternate paradigm in
this country. We never really -- we never required the utilities to
have to upgrade their IPEs and have a good PRA. But in 1.174 --
MR. BARTON: But you are ratcheted.
DR. APOSTOLAKIS: -- we are saying if you come to us using
risk arguments, you had better have a good PRA. So you can do the same
thing with 50.59. Do whatever you like with your FSAR, but if you use
50.59, it had better be good. Then you solve your problem and you don't
need an additional rule.
DR. POWERS: Well, I am not sure that you solve your problem
because then you get trapped into the question of -- what is good? And
that is what these gentlemen are trying to answer is, what is good?
MR. BARTON: Right.
DR. APOSTOLAKIS: We will have to have the ASME issue a
standard. What is a good FSAR?
DR. POWERS: Well, their track record is not good enough
right now for me to jump on that one. I think I will rely on NEI.
DR. APOSTOLAKIS: Anyway, you know, I managed to unite
everybody.
MR. BELL: I appreciate that.
DR. APOSTOLAKIS: Never have so many been against one guy.
MR. BELL: I had a couple of slides that went into a bit
more about some of the guidance that went along with the modifications
that should be made. Don't take it out if it was required to be there.
Make sure you have a disciplined process. And there are some examples,
and you are welcome to peruse that.
But I thought I would move on to -- and this is just the
only slide I have on this subject. Again, the basic guidance we issued
last November held up very nicely through the initial trials, that when
people tried -- different utilities tried to use it, they fed back to
us, gave us some feedback.
In addition, we had the public comment period, some
suggestions from the NRC, and we rolled up all of those into Rev. 1.
And, basically, none of the fundamental guidance changed. The NRC
thought it worthwhile to make very clear that, although this document is
not, you know, a probabilistically based document, there may be some
risk significant information in there that is not otherwise required,
per se, to be there. Well, you just shouldn't remove that type of
information, and so that we included that kind of admonition.
DR. POWERS: George has raised the question of the PRA that
some plants have and maintain. There is a variability, but some of them
pay a lot of attention to the PRA that they use nowadays.
And I guess I'd ask the question, is their information
incorporated in the PRA? They cannot be found in the FSAR with regard
to hardware procedures and the like.
MR. BELL: I would think so, because --
DR. POWERS: I think so too.
MR. BELL: The FSAR was so design-basis-event driven. All
the safety analyses are focused there, and all the previous chapters are
about the systems relied on in the safety analyses. And so in terms of
how to use those systems differently in response to severe accidents, I
would imagine there's --
DR. POWERS: One of the critiques that has come about the
IPEs, and I too make the distinction between the IPEs and the PRA,
because I believe they're two very distinct things nowadays, is that the
IPE submittals sometimes did not reflect the plant as it is. And I
wonder -- not in this, but if I was sitting here looking at Rev. 6 on
this, would we be saying and information used in your PRA if you have
one should be in the FSAR? Is that an evolution that we're making or
should make?
MR. BELL: I don't know. My own reaction is if we go to a
much more risk-informed world, the FSAR would be more of an anchor
around our necks than I think something that could be supplemented and
tweaked and made useful to serve that new approach -- you know, I don't
know.
DR. POWERS: What you're saying I think is, okay, the FSAR
can become an anachronism and some other document becomes the source
book, or the alternate view is the FSAR and its structure and what not
evolves to keep up with the changes. And I don't know what the right
way to go is, but I think we have to think about that. Maybe not today,
but certainly --
DR. APOSTOLAKIS: But if you did this, Dana, would then that
information from the PRA to the FSAR become part of the current
licensing basis when in fact now it may not be? That would be a legal
implication of that. And the industry may not want that.
MR. BELL: And we've always felt it important to leave a
pretty hard line between the FSAR and the IPEs and PRAs, and never the
twain shall
DR. APOSTOLAKIS: Maybe --
DR. KRESS: I think the PRA eventually ought to become part
of the design basis.
DR. APOSTOLAKIS: Sure.
DR. KRESS: Because it spells out the equipment
reliabilities and the -- and I know it's pretty severe, but --
DR. POWERS: Somehow I think we've got to explore some of
these thoughts for the Commission, not for today, but to keep in their
mind for the coming years, as they progress along on this
risk-informed -- I think something has to change, because I think I
agree with you that as design bases that we've used in the past become
more and more anachronistic, the FSAR really could become just a dead
weight hanging off the side of the licensee.
The aspect of the FSAR that says the pipe is connected here
and the wiring goes here, I don't think that ever goes away. But the
chapter 15 becomes something that it's crazy to keep up if you've gone
into a completely risk-informed regulation.
I think we ought to explore this.
MR. BELL: I was certainly talking out of turn, but I think
I agree with you, Dr. Powers, and there are obviously a number of
discussions going on about that brave new world that we're probing. I'm
not sure they've talked about the role of the SAR. I'm not aware that
that --
DR. POWERS: I don't think so either, and that's why I'm --
maybe sometime in the future we can get together and just have a
collegial discussion if you guys have some thoughts on this area.
MR. BELL: Good. In terms -- oh, let's see. This term
"incorporation by reference," what is the SAR, well, if you've
referenced a document in the SAR, is that part of the SAR itself?
Well, the answer, and the lawyers help us on this, no, the
term of art is you need to so-call incorporate it by reference in the
SAR and use those explicit words. Otherwise you've simply provided
additional information that the reader can go to.
What came out and what this document has helped clarify is
people need to be careful. I mean, we've misused that term over the
years. We want you to go incorporate that reference into your SAR.
Well, did you mean you want it to become part of the SAR and subject to
50.71(e) reporting, and update it and change pages and oh, it's subject
to 50.59? Well, no, I didn't mean all that, I just want you to put that
information. Okay, now I understand.
So I think one healthy thing that's come about is a greater
understanding of that term of art. Not everybody liked it, because they
had been using the term a bit loosely, and now they may have to scrub
their SARs for some information that appears to be actually part of the
SAR incorporated but was really never intended to be. So --
DR. POWERS: Yes, but I think we still need to allow people
writing the SARs to cite additional information to clarify what they're
talking about without having to keep that in 50.71.
MR. BELL: Absolutely. The purpose, as someone said, it's a
reference document. And if you force me to take out all the references
to other useful -- it becomes much weaker for that purpose. We again --
as a result of the comment period and the early implementers we amassed
25 questions and answers that we distributed with the revised guidance.
We shared those with the NRC staff informally and got their informal
buy-in that we seemed to be giving, you know, the right answers to those
kinds of questions.
We had the industry workshop in June, as I say. Licensees
are working within the schedule of the enforcement discretion. The
enforcement discretion begins to phase out next April 1 for
risk-significant information in the SAR. So people who are able to
identify that are concentrating there.
MR. SIEBER: Will all licensees be complete in your
estimation by the time enforcement discretion goes away?
MR. BELL: My sense is yes. In fact, many I think will be
ahead of schedule, some completing the whole review by April 1 when it
only begins to phase out. So they've been working on this for some
time, you know, as you know.
But the guidance -- let's remember the guidance isn't even
endorsed yet. So there's a chicken and egg here, but we're able to tell
people that look, the staff and we are of like mind. It's already gone
through the public comment process. You should be using it. So --
DR. KRESS: Can the updated FSAR be strictly an electronic
version, image on a computer or CD?
MR. BELL: In fact, I'll let the staff speak to that. Their
whole ADAMS program, which they've probably spoken to you about, as --
you know, they focus on the SAR, you know, somewhat, and particularly
because of its unique, you know, size, importance, and so forth. But I
think folks will be switching over to electronic submittals.
DR. KRESS: It's a lot easier to update.
MR. BELL: Absolutely.
MR. BIRMINGHAM: I think -- Joe Birmingham.
I think that what we're seeing in ADAMS right now is
preliminarily that yes, we can go to electronic FSAR updates. We're
kind of in the stage of working out the details. There are some
concerns about how, you know, how soon is it transmitted and how valid
is that transmission that we have to resolve. But once those are
resolved, I think we're looking to try to go that way.
MR. BELL: Some of the utilities are making those types of
voluntary modifications to streamline, improve their document, and I
think again using the resources that they've been given to make some
real improvement in their overall update process.
In a configuration management sense, bringing some information
technology to bear to take advantage of the electronic update and
submittal options.
This is just what we've been talking about. Utilities are
focusing on this linkage here. There ought to be like a break in this
line. Remember, this document could be up to 30 months behind this
configuration because they don't need to submit but every 24 months, and
they need to have a cutoff date six months prior to the submittal to
prepare the submittal and so forth, so -- at least that's the way the
rule is written.
While this is the focus of their FSAR reviews, they are
taking a look at this whole process, which smacks of good configuration
management, good business, and looking at that whole process.
So this is my last slide. It's been a very successful, I
think, interaction with the staff. We had common goals. There was no
urgent safety issue, and it allowed for, you know, practical solutions
to be arrived at. The result, I think, is effective guidance is out
there and helping people. It seems to be well received. And the SARs
and the whole process for maintaining them I think are the better for
it.
So I think it's a success story. One of our three issues in
our triad has gone very well. And the other two are coming along, as I
say, at their own pace.
What questions can I answer?
Thanks very much. I think the NRC is going to fill in with
the status of the reg guide, and so forth.
MR. BIRMINGHAM: Yes. I am Joe Birmingham, in the office of
NRR, and I'm just going to present the status of the Reg Guide 1.181.
The staff proposes to endorse NEI 98-03, Rev. 1, without exception. We
have a regulatory position of five parts. One, that NEI 98-03 provides
an acceptable method for complying with 50.71(e). Endorsement will not
extend to the documents that are referenced within NEI 98-03. The
examples in NEI 98-03 are for illustration only. And the existing
commitments to updated FSAR content and format must continue to be met,
unless the licensee chooses to modify the existing commitments. And
five other methods are also acceptable.
We did have 14 public comment letters on the Draft Guide
10-83. Thirteen were from licensees. We had one from NEI. Of these 14
letters, we felt that we had about four substantive comments.
There were some comments received during some public
meetings we held to discuss NEI 98-03. The four substantive comments,
Russ actually talked about -- but one was incorporation by reference.
As the ACRS has already discussed, this needed to be worked out,
licensees need to be able to reference a document without having to
maintain it to 50.71e standards, or those documents that the NRC is
requiring to be maintained at those standards has to be clearly
identified.
The concern, the staff found it acceptable for reference
documents incorporated by reference to be with the staff on file. We
had a concern about the retention of information associated with
risk-significant structures, systems, and components. We were afraid
that these would be removed from the updated FSAR, and we felt that in
the future one, as we go more and more risk-significant, risk-informed
regulation, that this type of information was needed, necessary. NEI
added a statement to Rev. 1 to indicate that this was not the intended
purpose of NEI 98-03 to remove that type of information.
Another comment was on removal of commitments. Staff was
concerned that it could be interpreted in NEI 98-03, Rev. 0 that you
could remove all commitments. NEI did change Rev. 1 to indicate that
those commitments which were needed to meet the required understanding
of safety systems and analyses, that those kind of commitments could not
be removed.
There was quite a bit of discussion on removal of drawings.
We felt -- were concerned that to allow the drawings to be removed and
have simplified schematics would improve the SAR, but we were also
concerned that some of the information in those drawings could be --
that was pertinent could be lost.
NEI addressed this by adding a statement that the drawing
could be removed only if two conditions were met. One, that the drawing
was not required by an existing NRC commitment, and, two, which was
perhaps the one that was the crux of this, the information in the FSAR
provided sufficient understanding of the facility's design bases, safety
analyses, and operations to compensate for that removal.
DR. POWERS: That's the thing that caused me the most pause.
On those occasions when I plow through FSARs on particular issues,
frequently I find redundant drawings, but usually I find one drawing I
can interpret without going back and really researching the text to
understand it. And the second drawing just makes it clear as a bell.
Whereas I'll admit it's redundant, it helps me quickly ascertain what
I'm trying to find.
Now, whether I can find what I'm looking for or not is
probably not a big concern to either the staff or the licensee, and
shouldn't be, but I worry about trying to make the FSAR like a
mathematical proof, maximizing the terseness of it by minimizing the
amount of information flow. You know, it causes me pause. Clearly what
you establish in regulations and regulatory guides is the minimum
necessary, but on the other hand I think it would be unfortunate if it
took Talmudic scholars to understand the FSAR.
MR. BIRMINGHAM: We agree, and that's the purpose of trying
to get these two criteria in there, to make sure that the understanding
is still there. We feel that there are parts of the drawings that can
be deleted fairly readily that aren't really pertinent to the
understanding.
DR. POWERS: There are some of them in there that are
absolutely unintelligible, because they've been shrunk, they've been
copied excessive numbers of times and what not, and all the notes on the
drawings -- you can't read them anyway, why have it there? I mean, the
sketch is far better than the actual drawing. But on the other hand, I
would have relished if in addition to those two criteria you'd said
something like it's worthwhile to remember communication is at least one
of the objectives of the FSAR.
MR. BELL: In fact, the words here are: Drawings should
generally not be removed from the SAR where they are helpful in
understanding the textual description and the design.
DR. POWERS: Very good. That's the kind of thing.
MR. BELL: So we really come at it from exactly your --
DR. POWERS: Good. Good. I like that.
MR. BIRMINGHAM: So the licensees feel the same way?
MR. BELL: Yes. Absolutely. They are not rushing -- look,
they really don't have the resources to, you know, oh, boy, now I can go
in and all kinds of things -- they're not doing that. They'll do that
when it makes sense to do that, when something's been problematic in the
past, but that kind of captures --
DR. POWERS: I think that's where I was going.
MR. BELL: Good. Good.
MR. BIRMINGHAM: Okay. Having reviewed the NEI 98-03 and
Rev. 1, having incorporated the comments, the staff has a schedule for
implementation proposed. We expect to be able to complete the ACRS and
CRGR reviews in the month of July. We hope to submit the final reg
guide for Commission approval in August, next month. We plan, if that
happens, to publish the final reg guide in September.
The licensee implementation for information associated with
risk-significant SSCS was -- we expect that by March 2000, for remaining
information by March of 2001. Somewhat of a risk-informed way of
implementing the NEI 9803 in the new Reg Guide.
Now, that is the staff's position on NEI 9803. If there are
some questions about how we arrived there or --
MR. BARTON: I think this is a fine example of industry and
the staff working together to come to a good document and a good way to
solve the FSAR issue.
MR. BIRMINGHAM: Yes. We think of it as an industry
initiative that met a growing need and something that worked out well
for both sides.
MR. BELL: Thank you, very much.
DR. POWERS: I think you've done a pretty good job on what
your objective is here. I think you guys need to start thinking about
what's the future going to look like here as we go to risk-informed
practices and the PRA assumes greater and greater importance. It's a
funny situation because I think we can anticipate a certain fraction of
the licensees seeing no merit whatsoever to maintaining a PRA to any --
because they just don't use it, or make a minimal use of it, and I think
you see other licensees that are four-square behind this. I mean,
they're charging off there. And I think their needs and the staff's
needs for a reference document tied not to design bases but to the PRA
become greater and greater in the future, and you may have to evolve
this whole concept of the FSAR so it doesn't become what you talk about,
is this document covered with dust that nobody ever uses anymore, and
why maintain it if it's no longer useful?
MR. BELL: A point well taken.
MR. BARTON: Hearing no further comment, thank you very
much, and I'll turn it back to Dr. Powers with a half hour to spare.
DR. POWERS: I think I want to take a little of this time
now to discuss -- we need to send a letter up on this subject.
MR. BARTON: I've already got a draft.
DR. POWERS: And I suspect that the draft you have speaks to
the specifics of the issue here, and I'm wondering, do we want to
explore for the Commission some of the thinking that they need to have
in the future on this.
DR. KRESS: I certainly think that would be of great -- much
more value than just saying we like this update and go forward, which
probably is what the letter says.
MR. BARTON: Basically.
DR. KRESS: Yes. So I think that would be a -- having that
flavor in it also would sure add a lot to the value of the letter, I
think. And this seems to be the right place to do that.
DR. POWERS: It's an opportunity to --
DR. KRESS: It's an opportunity.
DR. POWERS: -- say to the Commission, okay, you can't
forget about these other things as you move forward in other directions,
and it becomes more complicated now because you have a voluntary process
to evolve. I mean, a licensee can stay fixed, can say, I don't like
this new stuff, my plant is running just fine way it is and I'm happy
with it, my people are all trained in this area with business as we've
done it in the past, I don't need to move forward. On the other hand,
you have other licensees that are actually pushing the NRC, they want to
move faster and change more. And somehow, we're going to have to find a
way to accommodate everybody here.
MR. BIRMINGHAM: I think you'll find those licensees whose
licenses are closer to expiration, they're reluctant to make those types
of changes.
DR. POWERS: Sure. Legitimately so. And there's not -- I
can't fault them a bit. In fact, I kind of worry about the ones that
want to change.
MR. BIRMINGHAM: Yes.
DR. POWERS: Just from a cost perspective.
MR. NEWBERRY: Mr. Chairman? Scott Newberry of the staff.
We were here talking about risk-informing Part 50 with you
and the different options, Option 2 and Option 3, of course, and this
issue that you brought up we agree is an issue in the context of those
risk-informed options; that is, what is the role of the design basis in
the FSAR as you would take -- move forward on Option 2, which is the
scope of regulation, you know, what is the -- our notion right now is
that the design basis would stay intact, but you would focus on a
risk-informed scope, but that -- it's more complicated than that, and I
share with you -- you know, we've articulated the issues there. I think
we're going to be -- we're planning on addressing those issues in the
product we come up with in September and October and will be prepared to
talk to the Committee.
DR. POWERS: Fantastic. Fantastic. I mean, that sets the
stage for handling some of more nitty-gritty things, like what documents
do we have. That interface between the design basis, design basis
concepts and the new risk-informed concepts will dictate what we need.
MR. NEWBERRY: I think our thought right now, subject to
considerable discussion and perhaps change, is that the design basis
would remain the same for Option 2 but could be altered on Option 3.
Now, depending on how far you go on Option 2, there's a question there,
we think, and I think we'll be interacting with counsel as well on that.
DR. POWERS: Well, I'm sure you will, and you may well find
out that you need a rule change. It wouldn't be the most stunning thing
in the world. As Professor Apostalokis pointed out, you've got rules
that are on fairly nitty-gritty things here. When you change the whole
context, nitty-gritty rules get changed. I mean, it's an inevitable
result.
Are there any further comments that people would like to
make on this?
I'll take upon myself a task of trying to draft a paragraph
or so for you, John --
MR. BARTON: Okay.
DR. POWERS: -- on this to share with the rest of the
members. I encourage the members to think about what they would like to
include in this, and we'll make a decision on whether to include it in
the letter when we get to the consideration of our reports.
Okay. We can't start the next section of the meeting until
10:15, so we're on break until 10:15.
[Recess.]
DR. POWERS: Let's come back into session. This next
session deals with control room habitability, which has been a topic of
continuing interest to this Committee for 20 years, I guess, as long as
I've been involved with the ACRS, episodically, we have met to discuss
the issue of control room habitability, and we're going to get something
of a tutorial on the subject from a fellow that Dr. Kress and I know
very well, our invited consultant, Lou Kovach. We know him as a
gentleman of insight and perspicacity, an engineer's engineer as I would
call him.
So with that, I'll turn the rest of the meeting over to Dr.
Kress, and you can continue with the introductions.
DR. KRESS: Okay. Thank you, very much, Mr. Chairman.
We have had a longstanding interest in this issue. The
reason is I think there's potential for risk-significant issues here,
and we do plan to follow up this meeting with a Severe Accident
Management Subcommittee meeting in September which we will hear more
from the staff and from NEI.
At this particular meeting, we will also hear from NRR, who
I think are considering or had been considering a generic letter on this
issue. We'll also hear from NEI, who are drafting a guidance document.
We want to assimilate all these viewpoints, and perhaps
we'll have -- I think we're scheduled at the moment to have a letter in
possibly October, but it may get moved up to September, so there would
be no letter yet from this.
Next on the agenda is, we're very fortunate, I think, to
hear from Dr. Kovach, who I consider probably the world's most
knowledgeable individual on this subject, and other subjects too. So
he'll give us a perspective and tutorial, as Dana said, and I guarantee
you he'll be worth listening to.
So with that, I'll turn it over to Lou.
DR. KOVACH: Thank you.
Is it permissible to sit down?
DR. KRESS: Yes.
DR. POWERS: Please. In fact, we hope it's pleasant for the
presenters and it's much more pleasant for us if you're standing there
rather than dictating to us because I know you can swing that pointer
with certain viciousness.
[Laughter.]
DR. KOVACH: Good morning.
First as an introduction, I would like to say that the last
thing I want to do is to get in the middle of some licensing issues
here. I'm going to talk about technical issues that I think are
important to understand for a licensing issue. And this is the second
time that I am in front of the ACRS on control room habitability and my
recollection is that none of you were members at the time when the
previous event took place, which also gives away my age here, this
activity.
But in the last few years, there is renewed interest in
control room habitability relating mainly to determine really what are
the conditions of air flows and air purification in these control rooms,
and a test methodology was selected lately to determine leakage rates in
control rooms, and this is a release of a tracer agent and in monitoring
the tracer agent in the particular control room, and from that, using
the classical equations to determine what the leakage is.
This methodology is very good for spaces which are
relatively close. In most of our control rooms, we have exhaust air
systems, we have intake systems, and we have many different alignments
of the control room, depending on what type of hazard it may face --
normal operations, toxic gas, accident conditions -- and each of these
require different alignment of the various air-cleaning systems.
Additionally, we have air-cleaning systems outside the
control room that are also affecting ingress and egress of air flow from
the control room, and while the leakage tests that were being performed
showed some very interesting results from a maybe even engineering
common sense standpoint, the actual early measurement showed anywhere
from 2 to 55 times higher in leakage than what was originally used in
the design basis evaluations. So some of these control rooms leak like
a sink.
At the same time, some of these control room architect
engineers claimed for these control rooms like 10 cfm maximum. Now, I
don't know how many of you actually tried to make measurements. I'm
willing to give a $10,000 award to anybody who could measure within 10
cfm in this room. It's impossible. Even if you have minimum exhaust
and intakes into the control room, that was totally unrealistic.
Even the newer determinations, and there was a --performed
about two years ago and it was reported, and I'm not going to name
reactors; I'm just going to call them A, B or something. I don't like
to get into the middle of some of this rock-throwing. As they tightened
down the control room in leakage, finding leak paths and sealing it up,
and it is the tolerances are important. In the Reactor A, System A,
they went from 186+/-93 scfm to 122+/-55; in System B, it's 273+/-99,
88+/-62. Another reactor, 341+/-91, 294+/-87, 228+/-88, 162+/-91, and
so on.
So now we are not any more at the mercy of a ASTM procedure
for trace or leak testing; we are at the mercy of how well we can
measure the flows that are going in and out that have to be incorporated
into this measure. And basically, it looks like somewhere ar 80, 90 cfm
plus-minus is the best that we can do. So really trying to go down to a
condition, somebody, an engineering firm or whoever claims 10 cfm in
leakage, it's ludicrous. It's impossible even to measure it, to verify
it, at least as long as you have the air flows coming systems in and
out.
Now, what are the additional problems? I was listening to
one of the reports in performing this sulfur hexafluoride tracer, leak
test, and they carefully said, well, we put people on the doors to the
control room to make sure that there's minimum opening and closing of
the rooms because we wanted to get a good test. Well, what is a good
test? Some of you who may have been or heard about the TMI control
room, we had contamination in the control room. People were pulling
their gas mask up to talk to each other at times. There were more
people going in and out of the control room than any time during normal
operation rather than guarding the door so nobody comes in. So how
realistic is this test? Are they really testing under a condition that
we would have in case of an accident?
MR. BARTON: I think the difference between TMI and the
status of emergency preparedness, the emergency plan where people are
stationed then as compared to now where everybody had to go in the
control room to find out what's going, I think has dramatically changed
to where, in an accident scenario today, you see a big difference with
the door issue itself, because everybody now managing the accident is
outside the control room.
Except for the licensed operators that are trying to respond
to symptom-based procedures. So I think the door room issue is probably
not as realistic today as it was during the TMI accident.
DR. KOVACH: Yes, but it would still depend on the grade of
the accident, whether you abandon the control room and you go offsite or
whether you are still managing it from the control room.
MR. BARTON: In the emergency that gets you above an alert
level.
DR. KOVACH: Yes.
MR. BARTON: You do not go have a lot of access in the
control room. And that's a pretty low threshold.
DR. KOVACH: Yes. So then you go into normal leak paths.
There is a particular plant where they have fire detectors installed in
the control room wall, but these need to be frequently calibrated, so
about half of them are removed at any particular time for calibration.
MR. BARTON: That must be very unusual, because if I had
fire detectors that I had half of them out of service all the time for
calibration, there's something wrong with the design and I think I'd
change out -- there's something wrong with the corrective action system
at that plant that hasn't got to the root cause and solved that, because
that I'm sure is not what was intended in the design. And I think
that's an anomaly and you won't find that across the board in control
rooms.
DR. KOVACH: So you take a measurement with those holes
taped up to make sure that that's not counted in? If we do that, what
we need is a definition that 30 days before an accident you stop
calibrating them. Then it would represent --
MR. BARTON: I'm saying that's not a realistic condition in
most control rooms.
DR. KOVACH: It's not most. I was talking about one
specific one.
MR. BARTON: Then I'd say that they have a particular
problem with their fire-detection equipment. If they have to have half
of them out all the time for calibration, there's something wrong. I
don't think that's a valid data point to say across the board that's an
issue with control room inleakage or outleakage or whatever.
DR. KRESS: Well, if even one of them is out, that's a
pretty good-size hole, isn't it?
DR. KOVACH: Yes. Additionally, we have air cleaning and
air handling systems that are operating in normal operation outside the
control room, and these affect the pressure differentials between the
control room under normal operation and in case of an accident when many
of them would not operate.
So again what is the condition under which we perform this
leak test? We have a very accurate and a very precise leak test method.
The question is how do we and when do we apply this leak-test method
that would be realistic for a condition that would exist under an
accident. Similarly, what is the alignment of these air-cleaning
systems? Do we align it for a toxic gas mode. Do we align it for an
accident mode? Is it in the normal operating mode at the time of
performing the test?
So really the problem is not with the test method itself,
it's a very precise, very accurate method. The question is how
applicable it is to a condition and how many different conditions you
need to determine inleakage to have an idea as to what is happening in
the control room.
There is another issue, and I'll just put it on as a
typical -- well, that's a normal, so let me put on one that's -- air
cleaning system components. Prefilter, HEPA, carbon adsorber, HEPA
filter, fan.
Normally in these systems as a safety component the
consideration is for the HEPA filter and for the carbon adsorber. HEPA
filter is supposed to take care of the particulates, and the carbon
adsorber takes care of the gaseous components. And naturally along
between these two lines normally pressure drop is being measured to make
sure that the HEPA filters are not loaded up.
DR. KRESS: Are the adsorbers activated carbon?
DR. KOVACH: Adsorbers are typically activated carbon,
granular activated carbon.
DR. POWERS: With a teda impregnation?
DR. KOVACH: KI teda coimpregnation. However, the prefilter
is not considered as having a safety function.
DR. WALLIS: Why do you call this an exhaust system?
DR. KOVACH: Well, it just happens to show that there are
exhaust and normal. This would be an intake filter also.
DR. WALLIS: Yes, but it would be an intake. Not concerned
with --
DR. KOVACH: It's just out of a handbook, because it shows
all the components.
The main thing that I want to stress is that the major
buildup of particulate material is in the prefilter. In normal
operation your prefilter is going up in pressure drop because you have
just the normal operational contaminants present. But that's not
considered a safety device, and very often the delta P is not measured
across the entire train except from HEPA filter across a HEPA filter and
across a carbon filter.
So you have a continuous variation in pressure drop across
intake and exhaust filters that are varying depending how dirty your
HEPA filter is. How bad it can be, in two plants now in the last five
years they found a sudden rise of HEPA filter pressure drop, and the
reason was is because the pre-filters built up so much that they were
blown into the HEPA filters, and suddenly they have seen a sudden
pressure rise.
So, again, we are talking about several tenths of an inch of
water gauge in balancing a control room, and we are getting more effect
from that, from an unmonitored component of the air cleaning system that
is cycling up and down.
DR. KRESS: Are those systems included at all in the PRA,
George? You know, if we were going to decide what conditions to run a
tracer test in, you might to run through some sequences in the PRA and
find out the worst condition for most inleakage and run the test under
those conditions. I just -- I don't recall that these are ever modeled
in any of that.
DR. APOSTOLAKIS: In special studies, maybe, but, routinely,
I doubt it. I doubt it. Only if --
DR. KOVACH: I am not aware of anybody going through these
steps and seeing which would be really the most conservative condition
under which you would perform this test.
DR. KRESS: That would be the logical way to do it.
DR. KOVACH: Yes. At the same time that may require you
also to shut down some of your external air cleaning systems that are
air handling systems because they affect the outside pressure. I mean
we are talking about, again, few tenths of an inch of water gauge
differential between the control room and the outside. In fact, even
with an atmospheric high or an atmospheric low, in some cases, they are
effecting the performance of the air cleaning systems.
So if we have the good method to do it, the question is,
when and under what circumstances do we perform this test? If there is
general clatter coming out as to how to do it and what to do with it,
then I think we have to be careful as to under what condition are we
going to go into this extra effort of determining various conditions.
DR. WALLIS: If there is too much build-up on the
pre-filter, it would seem that it is poor design, the big arrows.
MR. SIEBER: Or changed.
DR. WALLIS: Or changed out more often.
DR. KOVACH: Changed out more often. But if they are not
monitoring the pressure drop across them, in some cases, on the total,
you may have a local delta P gauge and they wait until it gets real high
and then it is changed out. Again, the only part that is considered as
a safety system is the HEPA and the absorbers, so the rest are not as
well taken care of, monitored or anything else, but they do effect the
overall delta P of the system, which effects the quantity of air that
you take in or you put back into the controller.
DR. WALLIS: Well, this is one of the problems of
designating things as safety systems and other things as not.
DR. KOVACH: I think if you put in an air cleaning system,
then all the components of it are part of the system, and I can just say
that this is part of a safety system. We have in some of them, we have
electric heaters. Again, don't go by the titles, it just some of them
are --
DR. WALLIS: The inflow nozzle is a safety feature because
if something blows up against it and blocks it, then there is no flow.
DR. KOVACH: Certainly. In some of them we have moisture
separators and electric heaters to maintain relative humidity and those
are just as much a part of a safety system. A moisture separator,
unfortunately, is at times put ahead of a pre-filter and it has higher
efficiency for particulate material than the pre-filter.
DR. POWERS: Sure.
DR. KOVACH: So what gets plugged up? The pre-filter lasts
forever and the moisture separators are all clogged up. We have to try
to make these decisions on a more logical basis than on an arbitrary
basis, that the HEPA filter and an absorber are the major components,
but the system needs to be operating, not just a carbon absorber and the
HEPA filter.
So I am not going to dwell in very great detail as to what
are the other problems relating to what the bounder is. I think there
are numerous conditions that we have to evaluate as to under what we
conditions we do.
It is, in all fairness, and it is almost impossible even to
balance. As an example, under normal operation on a air flow, and then
you switch to a toxic gas mode, and you have to readjust dampers to make
sure that you maintain the appropriate flow. So under which condition
is the most critical to balance the control room, the air flow balancing
or to maintain positive pressure in relation to the outside?
Would there be a reason to perform tests earlier someplace
under the various conditions? Yes, I think I would recommend both to
NEI and NRC, that before they start writing a set of conditions, let's
determine what is the condition under which we want to determine the
actual inleakage.
DR. WALLIS: I have a question about the moisture
separation.
DR. KOVACH: Yes.
DR. WALLIS: If there is a lot of moisture, then this thing
is going to get saturated. Where does the water go?
DR. KOVACH: Well, these are coalescers, basically. There
is a water drain system also that normally goes to rad waste.
DR. WALLIS: If the water also collects particulates, then
you have got to do something with this dirty water.
DR. KOVACH: Yeah, it goes to rad waste.
MR. BARTON: Rad waste liquid systems.
DR. KOVACH: Also, in addition to that water, some of these
systems also have fire prevention systems that spray water on them for
quite a long time, and at times if you look at those quantities of water
balanced against the capacity of the liquid rad waste system, you may
run into some surprises also that they are in fact not.
Now, completely aside from the actual air flow aspects of
it, we have another problem also. Certainly, I endorse the current
source term inside the containment. I have a great deal of difficulty
endorsing that same composition for outside the containment. Iodine is
extremely reactive. Anything that gets out -- so once we are at the
stage that we would get to the control room, it is exposed either to
atmospheric or other reactor building, or other conditions where you can
convert a fair amount of this to organic iodides, which behave very
differently from the iodides or the particulate material.
In crediting, and let me just put back just for a reference
point here, if I have elemental iodine in particulate form, then it will
lay out onto a HEPA filter. But how long? It will still have a vapor
pressure. So just because I assume and credit a HEPA filter with 99.95
percent efficiency in place to remove elemental iodine in particulate
form, that will be a short-term removal and all of that will repartition
over into the absorber unit. Either it is elemental iodine or it is
because already in a larger surface, it helps you to convert to organic
iodides.
So, generally, what we are seeing in these cases, a much
larger fraction of the total iodine will be in organic forms than what
we assume actually as a fraction inside the containment in a case of a
severe or loss of coolant accident.
DR. POWERS: Even inside the containment, I think the new
source term specifies what comes in from the primary piping system, and
then says, okay, figure out what is in there. And that step of figuring
out what is in there, the mix between metallic iodides, I2 and organic
iodide, for just the reasons you say, the high reactivity of the I2 and
even the reactivity of the metal iodides, is a challenge that I don't
think has been sorted out to an level of definitiveness. And we see
from the Canadians -- for a long time, we say, okay, the organic iodide,
we can treat it as methyl iodide. Well, Canadians are coming back and
saying, well, maybe. But there are a lot of other things in there.
They are coming in with propylene iodides and a variety of other things
that they see being reacted largely from the vapors coming off paints.
DR. KOVACH: Yes. You can run in vinyl iodide. I think
vinyl iodide was actually identified by mass spec on some of the TMI
samples that were taken. Unfortunately, at that time people still for
some reason claimed fairly large fractions of HOI, which in the vapor
phase is nearly impossible to have other than for a few microseconds.
But even under normal operations, the measurements that were
made were found in the reactor building, 62 percent organic iodide; rad
waste building, 84 percent; turbine building, 40 percent, and so on. So
we are getting a large percentage conversion even though there is really
no organic iodide in the primary coolant. Once you are coming out,
these are all reactions after release, leaving the primary system.
So it is -- you have to be very careful in trying to come up
with dose calculations for the control room, assuming a certain amount
of air flow in and a certain amount of filtration efficiencies which are
being taken of 99 percent removal of methyl iodide and 99.95 percent of
particulates, because neither the source term is the same at the entry
to the control room, neither of these efficiencies will be maintained.
I think that we have, and for some now years now I keep
hearing that we have very good behavior on nuclear air cleaning systems,
and I would like to revisit that issue because -- let's see what
happened at TMI. Maybe a figure is better.
There were two major air-cleaning systems that were
monitored. The auxiliary building, A and B units in the fuel-handling
building, A and B units. Both the aux building and the fuel-handling
building A and B units are two identical units.
What happened here is because we had very high iodine
loading on the adsorbent batch we couldn't redetermine the efficiency.
So these are two-inch-deep beds, and they were carefully broken out into
half-inch segments. And we counted what was actually in the direction
of the probe from inlet to outlet, and the unit is in microcurie per
gram carbon. All back-calculate to the March 1979. That's when the
accident occurred. The filters were removed actually about a week
later.
You can see the two auxiliary building units show to the end
here if I extrapolate this to the two-inch unit almost identical
behavior, but none of them were up in the 99.99 range. We already had
some coming through. As a matter of fact, if you extrapolate these
curves down to zero, you can pretty well determine how much iodine was
released through these units at TMI. But there is the air-handling unit
from the fuel-handling building, and two very different behaviors, even
though both of them were running.
What happened is they were not balanced, and the dampers
were offset so a large amount of flow was going through this unit. As a
matter of fact, that unit released about between 27 and 30 curies of
iodine at TMI, which is just about matching the total amount of iodine
that was released at TMI, while the other one was actually in fact
efficient to 99.99 percent. Why? Because there was not much -- about
half the air flow was going through here, and three-quarter -- 1-3/4 or
so, the design volume was going through the other.
Now we also took measurements by taking samples before and
after the filter at various times in the accident before these were
removed, and about a week after the accident we had a DF of 1.2, because
the inlet iodine was already going down while there was iodine bleeding
off the other end of the adsorbers. So this assumption that we maintain
99.9-plus percent efficiency for a very long time based a laboratory
test that's performed for one or two hours is not appropriate for those
determinations in a control room. Because what we have is a long-term
operation, and depending on the age and type of the adsorbent, it will
have a different behavior if it's run continuously for a week than if it
is run only for two hours under rather controlled conditions.
Looking at the curves really, except for some front-face
elemental iodine, this indicates the distribution was pretty close to
methyl iodide. There wasn't a major variation at least in there. Or
something that behaves similar to methyl iodide. Because if we had
different iodine species, we would have breaks in the curve, depending
on the efficiency of the removal. We don't have any breaks, except on
the face we have some higher volumes which would be mostly elemental
iodine that's pretty well backed up.
Now in all fairness I also have to tell you that these two
adsorber trains were also present at the time when they were painting
the containment. They got an extension on replacing them because they
were going to change them out at the next refueling time. So again what
we need is a requirement that a certain number of days before the
accident you have to change the filters out, whether you paint in the
containment or not, to make sure that we are in an appropriate condition
for this particular event.
So what I'm seeing is from various groups claiming that we
don't really have to worry as much about the control room, because with
the efficiencies of particulate removal, with the efficiencies of iodine
control, we remove so much of the iodine during the forced ventilation
of the system that the inleakage is not going to be a significant
factor.
Well, the inleakage can be a significant factor, and our
efficiency, if we are basing it on the actual species that we will --
this system will see rather than an arbitrary condition, taking again a
source-term-based reactor accident, source-term-based iodine speciation,
and assume that for the input then it's not going to work. It's going
to be -- the iodine species present are going to be different.
Again, just as a demonstration example as to what we are
seeing in some cases, now this is a little different system, because you
can see when that's going to 50 centimeters rather than 5 centimeters
like we have in the U.S. These are the German systems. And they claim
some assistance from this depth from the behavior of organic materials.
They were looking at the organic materials to build up on
the carbon, convert even elemental iodine to organics on the carbon.
Carbon is a very good catalyst. It's a large-surface-area material. We
pick up iodine on it. It all says adsorbed organics. There's a much
better chance for contact through this system. And you can see when
they start up in operating time in two months on the system you can see
some organic buildup in the bed in the initial part of it. Then you can
see that four months and going up to 14 months the high-volatility
material tends to move through the adsorbent bed, and you actually get a
mass transfer zone moving through, while the higher boilers are much
more strongly adsorbed and they stay on the system.
But if I look at what happens in the first five centimeters,
you can see that really there isn't a lot of difference, and it's very
difficult to interpret in a 5-centimeter-deep system really how much
credibility we can give to these very high efficiencies in a long-term
exposure. These were again two months, four months, 14 months
continuous operations.
DR. POWERS: Was this with a radioactive iodine or with --
DR. KOVACH: Yes. They were running it two ways. They were
running both radioactive iodine tracer, and they also had a sampler, the
same bed depth, that was segmented. So they were taking the segments
out and stripping them.
DR. POWERS: I've always wondered if the self-dosing effect
was significant or not in these beds.
DR. KOVACH: I think it is.
DR. POWERS: I would think it would be.
DR. KOVACH: So the, you know, they have a different design
concept. Basically what they are trying to do is to have a deep enough
bed that even if you have organics, by the adsorption-desorption step,
you delay the iodine long enough that you are significantly
decontaminating it rather than an efficiency of removal. So they
actually are operating iodine delay vents similarly to the way we have
noble gas delay vents on some of the reactors.
Personally I think it makes more sense, but they started
designing these systems after a lot of design data was available. We
wrote regulations first, before we had design data available. So we are
frozen at a certain stage in our engineering designs relating to
air-cleaning systems in nuclear powerplants.
Basically what is -- yes, there are problems. I think if we
want to look at control rooms, we have some things that we have to look
at, and it's almost different in each individual plant. We have some
plants where the emergency diesel exhaust is darn close to the
control-room air intake. I think elimination of something like that
should be a higher priority than directly determining the leakage into
the control room. And really a good walkdown of the overall system is
very important.
But basically what I'm proposing is that we should consider
the conditions under which the control room envelope and the ventilation
systems are tested, and they should be carefully established to yield
realistic data under whatever the most conservative or a range of
conditions before we actually start proposing that this is the method
that you have to use.
The test method should be selected to be commensurate with
the magnitude and accuracy of the needed data. If I run an extremely
precise test but because I can't measure my air flows in and out better
than about plus-minus 90 CFM, there is only a limited effect to go down
to determine inleakages to plus-minus 1 CFM in a test by the test
itself.
The radioiodine removal efficiency credits postulated for
the control room air-cleaning system should be based on realistic
application of the physical chemistry of iodine species and their
potential changes during long-duration operations. What's not useful is
leak-testing performed under unrealistic conditions. I don't know what
you do with it. You have a number, and how do you apply it? Assuming
laboratory radioiodine test conditions is representative for long-term
operational efficiency. Again, a two-hour test is not going to tell you
how a system behaves in a week or a month or whatever duration you want.
In case of an accident, it will most likely be longer than a couple
hours' operation, and hopefully less than months. We are talking about
maybe weeks at most, or a week.
Assuming in-containment iodine speciation for control room
air intake or air inleakage locations, I think that if we are going to
evaluate directly the dose to the workers, we have to assume not the
iodine distribution that exists in the containment, but what actually
would be the condition at the control room intakes or where the
inleakage can take place, and make sure that we are using realistic
credits in assuming the calculations.
I'm not saying anything here that's new. I don't claim that
I'm the discoverer of this. I'm just trying to recite things that in my
opinion are significant before there is a generic letter written, and
I'm not sure if September or October is a realistic time based on where
we are with it now, at least on my knowledge. We have not run to my
knowledge any control room air inleakage tests under these conditions
where we would actually determine that what is the most conservative or
what is the most realistic for an accident condition, how to line up the
system for that type of a test.
So what I'm pleading for is to consider under what
conditions to run the tests and how relevant it is from a dose
standpoint again should be evaluated at what is a realistic dose that we
want to prevent and not just an idealistic condition.
And with that, if you have any questions or anything else,
I'll be happy to answer anything. There are some additional examples
given in the paper. I'm not going to recite them.
DR. POWERS: I guess what comes immediately to mind is
that -- two things -- is that I think we do want to see some more
attention to this in the probabilistic assessment, and you think about
it, what is it that you need to consider in setting up probabilistic
models for these things? Variabilities in the leakage rate?
Variabilities in the speciation? Variabilities in the efficiencies of
the --
DR. KOVACH: Yes.
DR. POWERS: And then you have some protracted period of
time, so it changes in time. Are you going to be able to do this in PRA
space, George?
DR. APOSTOLAKIS: I don't know.
DR. KOVACH: With some data I think yes. With no data it
will be very difficult to come up with even a PRA.
DR. APOSTOLAKIS: We need expert opinion.
DR. POWERS: It's always good to get expert opinion. When
in doubt, go to expert opinion.
MR. SIEBER: What about shift changes?
DR. POWERS: Ooh, shift changes.
MR. SIEBER: Yes, sure. People only stay there 8 to 12
hours, and then somebody else gets the next shift.
DR. KOVACH: I think that, you know, some initial conditions
can be established. They may not be the same for all plants. I mean,
we don't have identical air-handling systems and identical control room
sizes and control room envelopes.
DR. POWERS: I am aware of some studies that -- anecdotal
accounts of studies that went on in Great Britain about HEPA filters
with self-dosing of iodine on the surface, and, you know, they
deliberately put radioactive iodine on the paper for the paper HEPA
filters and looked at the retention. And the answer was retention was
extraordinarily high in the first 10 minutes.
DR. KOVACH: Sure.
DR. POWERS: And it went to zero, because you turned the
iodine into an organic iodide and it went right through the paper. Are
HEPAs typically paper filters, or are they --
DR. KOVACH: No, they are typically glass now, but we have
more organics than the old -- the paper was phased out because of the
fire hazard.
DR. POWERS: Right.
DR. KOVACH: Now they are mostly glass fiber, but they also
have water-repellant organic coatings and binders in them, so the
propensity for reaction is, if anything, maybe worse.
Again, they are really -- HEPA filters are for true
particulates that have no vapor pressure or no reaction on the HEPA
filter itself. If you don't have those conditions, you can't assume the
efficiency from the available test data as to what it's going to be.
DR. KRESS: Are there no test data on the conversion of
iodine species to organic on HEPA filters? Do we need some more
research, is what I'm asking.
DR. KOVACH: That aspect of it is -- there may be some in
the literature from which you could at least get a starting point. Some
people actually looked at -- but even isotope exchange in beds with
elemental iodine --
DR. KRESS: Yes.
DR. KOVACH: You know, where particulate's going through.
DR. KRESS: Yes.
DR. KOVACH: If you go to a particulate, you can run through
the same processes, except your kinetics goes to hell because your
diffusion -- it will be a direct relation to your diffusion --
DR. KRESS: Yes.
DR. KOVACH: Coefficient. So even a submicron particulate
has a very different -- much lower diffusion coefficient than methyl
iodide.
DR. KRESS: Sure.
DR. KOVACH: The other thing that happens is the short-term
test gives you another sort of a misleading condition that methyl iodide
removal is by isotope exchange. You put actually stable iodine on the
adsorbent bed and you let methyl iodide come in. The methyl iodine
group is not so strongly held.
DR. KRESS: So they --
DR. KOVACH: As long as you have statistically an excess of
stable iodine on the adsorbent, you get an isotope exchange.
The higher organic molecules are really removed by physical
adsorption for a limited time. So you also have a high efficiency for a
short time, because it's a big molecule. On methyl iodide you don't.
If you don't have isotope exchange that methyl iodide zips through,
because it's highly volatile. But if I go to ethyl iodide or propyl
iodide, I have a half-hour, hour retention. But again, what happens
after 10 hours, 8 hours, or whatever is the actual duration that we are
looking at.
The other thing, you have to realize that we are talking
about in some of these control rooms air intake, air inleakage, and then
we have recirc systems. Now if I bring in some of this iodine, even
though I may have a shift change now from the intake standpoint, what I
put on the recirc unit may be just recircing through there and I can
have this distribution that I showed you, a very flat distribution,
after a while, on the iodine on that recirc system, and a very low
defendant on the recirc unit. So we have to make sure that at each step
we understand what's happening.
DR. KRESS: Would chemical thermal dynamics calculations be
useful here?
DR. KOVACH: I think so. Also, I mean, this is, as you
know, there is a lot of experimental data being generated by the French,
Canadians looking at the reactivity of iodine under various conditions,
and it can be both good and bad. You can have electrical cabling,
insulation paints that actually remove iodine. The question is that
most of the people are looking at iodine removal in a short term and not
the possible reentrainment of the organic iodine species after the
reaction takes place.
DR. POWERS: Yes. Assuredly what the Canadians are saying
is that within the containment itself you get two classes of organic
iodides. You get those -- essentially methyl iodide or maybe it's ethyl
iodide, or multiple iodides. The other one is you get these
high-molecular-weight iodines which is better for retention than even
metal iodide.
DR. KOVACH: Yes.
DR. POWERS: Back in the sixties I believe that there was
some work done at Battelle on trying to develop an optimal paint for
iodine retention. I don't know where that went. The idea there was to
of course trap it.
DR. KOVACH: Use a type of paint that actually --
unfortunately I think at that time most of it was still looking at
elemental iodine, and there's very little work was done on the full
speciation. And there's a tremendous amount of good data out there that
I think can be looked at to get an initial start, at least to lay out an
experiment at a plant as to what you want to do.
DR. POWERS: Another thing that's always intriguing is that
you have a lot of these zinc-based paints, typically as primers, and
when they're covered over with another kind of paint, nothing happens,
but if you have the primer bare, that is a tremendous absorber of
elemental iodine. I don't think you'd get anywhere with methyl iodide.
I don't think anything absorbs methyl iodide well. And, for instance,
in AP600 we gave no credit for their zinc-based paints at all on iodine
absorption. But it is assuredly true that the primer -- not the actual
paint, but the primer -- is the great absorber of --
DR. KRESS: Suck it up and hold it. It stays there, too.
DR. POWERS: It essentially turns it into zinc -- hydroxy
iodide.
DR. KRESS: It's pretty stable stuff.
Well, if there are no more questions, well, thank you.
DR. KOVACH: Thank you for your time.
DR. KRESS: Thank you, Dr. Kovach, and at this time we are
scheduled to hear an NRC staff presentation from NRR talking about
some -- continuing on issues related to control room integrity. So I'll
turn the floor over to our NRR rep right now.
MR. HAYES: Thank you very much.
DR. APOSTOLAKIS: Is there a reason why this has started in
the Probabilistic Safety Assessment Branch?
MR. HAYES: Pardon?
DR. APOSTOLAKIS: Are you doing PSA on this?
MR. HAYES: On this issue?
DR. APOSTOLAKIS: Yeah.
MR. HAYES: No, I'm not. I'm in the Probabilistic Safety
Assessment Branch. That sums it.
DR. APOSTOLAKIS: Yeah, that's why I'm asking. Why is this
issue within that branch?
MR. HAYES: Okay, this issue is within this branch because
the accident analysis component of NRR was just reassigned to the
Probabilistic Safety Assessment Branch. Formerly, it was in the
Radiological Assessment Branch, okay. It was actually Radiological
Assessment and Emergency Preparedness. You must understand that the
issue of control room habitability encompasses a number of different
review areas. It involves the Plant Systems Branch, which has the
responsibility for the ventilation system itself. It involves the
Materials and Chemical Engineering Branch, which is involved with toxic
gas analysis. And it also involves the human factors area, which is now
in a different component. They have been merged with about two other
branches and the Radiation Protection Implant Health Physics person.
So, if you will, I am making this presentation because the
section that I am in is sort of the focal point for control room
habitability, but I can assure you that the reviews and the assessments
that we do are quite integrated. When these issues come in, there's
continual discussion with the various branches to make sure that we try
as much as possible to look at this as an integrative fashion. Okay.
As Dr. Powers indicated, control room habitability has been
an issue --
DR. APOSTOLAKIS: Would you focus it a little bit?
MR. HAYES: Sure.
DR. APOSTOLAKIS: Yeah. Thank you.
MR. HAYES: Is that better?
DR. APOSTOLAKIS: Thank you very much, Greg.
MR. HAYES: Dr. Powers indicated that control habitability
has been an issue with this committee for approximately 20 years. It
started out in 1980, and, at that time, quite frankly NRR was rather
slow in responsiveness to the committee in terms of identifying and
understanding the concerns which this committee had. But eventually, in
1983, generic issue 83, control room habitability, was established, and
a control room habitability working group was formed.
Now, as a part of this control room habitability working
group, it was determined that there needed to be an assessment of the
actual control room habitability at three plants. So sort of a
mini-survey was performed of those three plants.
The result of that survey was that a more detailed
evaluation was required of the existing control rooms. And that
resulted in a 12-plant survey, which started in the fall of 1985 and
concluded in January of 1987. Now, one of the chief areas of
concern--and there is a number of them that this committee had--was the
question of how did licensees implement TMI Action Item 3D34 in their
plant modes of operation. In other words, is -- was the as-built, as
operated system similar to what was described in a TMI Action Item 3D34?
So, members of the staff and a contractor went out to these
12 plants to determine whether the as-built as-operated systems
reflected TMI Action Item 3D34.
Now, this was rather a straightforward evaluation. The
staff and their contractor evaluated normal and emergency operating
procedures. They walked down the systems. They reviewed the updated
FSARs. They reviewed the safety evaluation which was issued in
conjunction with TMI Action Item 3D34, and they even made flow
measurements, as much as possible, at these 12 plants. And what these
flow measurements were, they were an attempt to determine where the
licensees were getting the flow that they had anticipated. In other
words, if they had assumed a pressurization flow of a thousand CFM, were
they actually getting that? If that had assumed a recirculation flow of
4,000 or 5,000, were they actually getting it, or were they getting some
other number? In other words, the flow wasn't coming in, you know,
where they anticipated.
They also -- we also looked at the technical specifications.
Did the technical specifications mirror the way the system was operated?
Did it mirror some of the assumptions which went into the accident
analysis? For example, if they assumed 95 percent as the charcoal
absorber efficiency, was an appropriate laboratory test performed to
demonstrate the 95 percent?
Now, I should point out that in no time in this evaluation
of the survey of the 12 plants was there ever an assessment as to
whether there is an adequate toxic gas or radiological assessment. In
other words, we did not go back and recalculate doses or toxic gas
concentrations.
Now, on June 22nd, 1987, we provided to you all the
conclusions as a result of this 12-plant survey. And I guess you might
say that I feel somewhat like the Austin Powers of control room
habitability.
DR. POWERS: Do you think you've been shagged?
MR. HAYES: You know, because here we are again, you know.
And I'd like to summarize the results of those findings back in 1987.
With respect to the as-built and as-operated system and
comparing that to 3D34, we found that the as-built and as-operated were
different than the 3D34 evaluations.
And one of the major findings we had was that it appeared
that the flow rates and inleakage was much different. As Dr. Kovach
indicated, many of these licensees had, in essence, assumed that they
had a perfectly zero inleakage control room, because the tent CFM is not
due to inleakage; it's due to ingress and egress, okay. When we found
that there was communication, we found that the flow rates, like
pressurization flows didn't match, and it was sufficient at a number of
these plants so that there was some question as to the capability of
these plants to meet GDC 19.
We also had issues with respect to the technical
specifications. We felt that they were inadequate and, in some cases,
inaccurate for some of these plants. For example, one of the probably
the deficiencies we with respect to technical specifications on control
room habitability is that nowhere do we address the integrity of the
envelope. We address the capability of the system to filter. We
address the system capability to isolate. But nowhere do we take into
account this boundary, and that's one of the most important, if not the
most important, thing in the evaluations.
Some of the inaccuracies we saw--we saw, for example, that
licensees may have assumed 95 percent absorber efficiency, and they were
testing to 90. We saw flow inaccuracies. For example, maybe they
assumed 300 CFM of pressurization flow, and in actuality they were
seeing a thousand. Okay.
And then finally, the last conclusion was with respect to
the importance of ventilation systems. You may recall back in the
1980s, there was a comedian named Rodney Dangerfield, and his famous
line was he couldn't get any respect. And that is somewhat the way we
found the ventilation systems at that particular point in time is that
it seemed to be that ventilation systems really didn't have ownership.
You saw engineers who were recycled through those particular job
descriptions, but no one was ever assigned on a permanent basis. You
didn't have a system engineer that, if you will, stayed with that system
for a long time. You know, I remember one visit we had at a plant in
doing that 12-plant survey when we were asking for some information, and
they asked this one fellow: they said, well, didn't you have that? And
he said, yeah, I had that system at one time. He said, but then I got
promote to rad waste.
[Laughter.]
And so that sort of gives you a flavor of the way that
ventilation systems have been, you know, presumed in the past in terms
of their importance.
DR. SEALE: A card carrying ASHREA member gets no respect.
MR. HAYES: That's right. That's right.
Now, here we are, if we fast forward ourselves to the 15th
of July 1999, and the question is well, what has changed, you know, or
what are the conditions today? And we can be safely said that if you
want to look at the conditions of control room habitability, you can
just about look at the slide which was given back in 1987.
Now, the one exception I think that there is is that there
has been an increased interest in the importance of ventilation systems
at the grass roots level. There is an organization called NHUG, which
stands for Nuclear HVAC Utilities Group. They have been very
instrumental in bringing to the front ventilation system problems.
You're also seeing in terms of these utilities much more a
system engineer approach, and these people are starting to stay with the
systems for some significant period of time. So that has been a very
good improvement.
However, if you look at the problems with respect to the
adequacy of the tech specs with respect to inleakage, you will find
these same problems exists, and, in fact, what we have seen is an
enhancement of the conclusions which we were given in 1987.
And to demonstrate this, and I think if you want to pull one
thing from this meeting and presentation from the staff this morning,
it's this next issue, and this is dealing with the issue of inleakage.
And then we'll talk about unfiltered inleakage.
The next two slides deal with tracer gas testing of control
room envelopes. Okay, this is a graphical presentation of it. The red
is an indication of the measurement of unfiltered inleakge in CFM.
This, in the green, is the values which were assumed in their accident
analysis. Okay. That gives you an order of magnitude.
DR. POWERS: A plant that certainly sees the two big spikes
you've got there must be just shocked because verification of your
assumptions is a critical part of any aspect. We just heard about the
FSARs, verification of the assumptions. There is a required activity.
How do they react to that? I mean, I -- shoot themselves?
MR. HAYES: Well, if you look at this data, this data, 13
control rooms have been tested out of roughly 72 that exist--21 reactors
out of about a hundred and some.
So that, if you will, this sampling represents 20 percent
approximately of the entire industry, okay. None of these plants, which
were tested and did the tracer tests, met their licensing basis. None
of them. Not one to date. And I think when I say that, I want to point
something out to you that I think is very important. Do not label these
people who have done these tests bad guys. On the other hand, label
them the good guys.
DR. POWERS: They tested.
MR. HAYES: Yes, because they've had the guts to go out and
test this. Because I can assure you, nobody in the industry really
wants to go out and do the tests, because they're very familiar with
this data.
DR. POWERS: Yeah, I can believe this.
DR. WALLIS: Would you tell me about the assumptions. Were
the assumptions made by engineers or were they were something that was
specified by the NRC?
MR. HAYES: The -- there was guidance given in the Standard
Review Plans, but the guidance says, hey, licensees, you are to
determine and tell us what your inleakage is. In other words, what I
found when we did this survey is like, for example, if you took a
particular architect engineer, and you went to, say, a mid-70's plant,
and you went to, say, a mid-80's design, it didn't seem like the
architect engineer ever went back and verified that the system that they
had done in 1970 worked as they had intended, so they maintained the
design.
And, you know, and I just don't think -- you know, no one is
raised from infancy -- you know, you don't see your sons and daughters
saying, hey, I want to be a ventilation engineer. I think it's
something that people sort of get pushed into, and so I don't think that
they were really very well appraised of this potential -- these
potential problems.
DR. WALLIS: Yeah, but if they all estimated so low, is this
because there's something generically wrong about the way they're taught
or that the literature in the field or something. What is it?
MR. HAYES: I think it's both. I think it's both.
DR. WALLIS: And they all make naive assumptions. You'd
assume some of them might assume in the wrong direction or is it
management tries to push them to making assumptions that look good on
paper. What is it? Or, it's all of the above?
MR. SIEBER: Well, I think there's another factor is that as
far as inleakage is concerned, it's door seals, which wear out as you
open and close doors. Sheet metal that's not fit together well. Holes
that are --
DR. POWERS: The architect engineer is going to have built
this building and said that there's a certain inleakage on it. But he's
going to have a design construction --
MR. SIEBER: The construction would then produce it.
DR. POWERS: But somewhere in this plant, there is going to
be a specification for control room that says, this is the kind of
inleakage we want.
MR. SIEBER: That's right.
DR. POWERS: Okay. I would bet you that these guys made
their estimates of the inleakage by going to that specification and
saying, it's this. We'll bet on that, because the guy wanted to meet
the spec.
And it's just what Jack says. The first thing was
construction probably couldn't meet that, and didn't, and had no way of
checking it. And second thing is that, as time goes on, all the seals
and what not, which everybody has forgotten where they are, because
they're all over the place, have gone away, and, as Dr. Kovach's
discussed, you're taking things in and out of these things. And you run
off and calibrate this, knock a new hole for a conduit, and things like
that, and it just gets forgotten in this stuff.
I'm willing to bet that's how the evolution progresses.
MR. SIEBER: That's exactly right.
DR. KOVACH: In some cases, modifications were made also.
MR. SIEBER: Right.
DR. KOVACH: From that time to the original time. And you
have a lot of other penetrations that were not sealed because they --
DR. SEALE: There are lot of the equivalent of parking lot
dents.
DR. KOVACH: Yes.
DR. SEALE: On these control rooms.
DR. POWERS: Getting wide -- these shopping carts ready to
--
DR. SEALE: Yeah, exactly. Yeah.
MR. HAYES: Go ahead, Mark Reinhart.
MR. REINHART: This is Mark Reinhart of the Probabilistic
Safety Assessment Branch, and I head the dose assessment team under my
section. I wanted to ask Jack, is it worthy to comment back on your
chart the difference between some of the large spikes and the smaller
spikes if I understand this correctly is that the plants that did
sealing before the test got the lowest spikes.
MR. HAYES: Oh, sure. Let me show you a couple what I
consider good examples. If you see this plant C. Plant C had a design
basis of 260. When they did their first test, it was 4,000 plus. Okay.
This values here are subsequent tests. You know.
DR. WALLIS: It looks like 518,242.
MR. HAYES: Oh, I'm sorry. It's really 518 and 242.
[Laughter.]
DR. POWERS: Yeah, well, what happened was the plant manager
saw the results, and he went right through the roof.
DR. APOSTOLAKIS: By the way, this is a good place where the
use of a semicolon would be valid.
[Laughter.]
This is for my colleagues who hate to use those in letters.
Semicolon would be good here.
DR. POWERS: Or even a space.
MR. HAYES: But this particular facility has a -- is owned
by a utility that has another reactor. As soon as they found that they
had this inleakage associated with this plant, the ventilation engineers
said, hey, get some sealers to this reactor and start sealing. And
that's why, as Dr. Kovach, mentioned the lowest factor that we have in
terms of the measured versus the analysis is a factor of 1.5
approximately, and that's because these people started sealing first.
The same way with this value right here, 440, versus 120.
They also sealed first. And finally, the last example here, this plant
number H, or letter H rather, which had an assumption of 10 and came up
with 71, that was one of the plants we did at the -- during the 12-plant
control room habitability survey. And we made measurements in there,
and I can tell you for sure that the leakage wasn't 71 CFM. And when
the person who did the tracer test went into some of these various
areas, he sort of compared it to going to Luray Caverns, where you had
stalactites and that hanging down, because they had so much sealant
material.
And so I think it's fair -- it's fair to say that there is
solutions to this issue of control room habitability.
DR. APOSTOLAKIS: Yes.
MR. HAYES: And, and -- because this plant here was not a
new plant that did this ceiling. And, in fact, to go, if you will, from
this level down to this level and the vintage of that plant, I think
it's a tremendous, tremendous step, you know. Yes, sir.
MR. SIEBER: I think another problem, and this points out
the importance of updating the FSAR is that when a designer puts a
penetration in the control room, and looks at seals, he thinks they're
firestops, unless he reads the FSAR and the design basis. And so what
he places in there, even as a temporary mod, allows leakage. And so
those are the kinds of things that generate these problems.
DR. BONACA: But also, this shows that even in the cases
where they were so good at putting insulation, they never, except in one
case, met their analysis inleakage.
MR. HAYES: That's -- that's correct. You know, in no cases
did they ever met the original analysis.
DR. BONACA: So those are, you know, impossible to achieve
almost, as --
MR. HAYES: Well, I think, you know, to assume that you have
significantly low values of inleakage is -- may be a stretch on many
designs.
DR. BONACA: That's right.
MR. HAYES: Because one of the -- you know, we have found as
a result of a lot of this work that it depends upon whether you're
ventilation equipment goes outside the envelope, because if it goes
outside the envelope, then the air handling units, you know, the duct
work, are very susceptible to inleakage and bringing contamination.
Plus, if you have ductwork which traverses the envelope that may have
nothing to do with the control room -- for example, you may have aux
building, turbine building ventilation systems that go through the
envelope. Those can be a source of inleakage.
MR. SIEBER: Yes, that's right.
MR. HAYES: You know, like, like, some of those lower
values, like here, you know, this is very good, and this is a recent
test, and it's because in essence all the equipment is within the
envelope, you know.
DR. KOVACH: Yep, I'd still like to caution that in almost
all of those values, you can put in about a plus minus 8 to CFM. And
don't assume these measured values to be the worst because they were
still, you know, outside -- air handling systems were still operating
and this is not the most conservative condition under which these were
measured.
DR. KRESS: May I put plus and minus 80 on that 70 one?
DR. KOVACH: Yes.
DR. WALLIS: I guess I can say that inleakage and outleakage
are the same thing. Same number, simply by conservation of math.
MR. HAYES: Well, you don't blow the -- if you don't blow it
up or you don't implode it, you know.
DR. WALLIS: I just wondered, though, if you measure it some
consistency in the measurement of that? What did you measure in or out
or both and take the average or what?
MR. HAYES: Okay. I myself did not perform these tests.
These were performed by the licensees' contractor.
DR. WALLIS: It would be interesting to see if there are two
numbers vastly different depending on how you measure.
DR. POWERS: Well, I think the -- I think we in the material
we had in preparation for this, there was a section that fairly
exhaustively discard the test procedures and that they did, and it
differs depending on the type of system you have, and the amount of
leakage you anticipate. And I think the -- the interesting conclusion
was that sometimes if you think you're going to get 10, and you're going
to get 4,000, they system doesn't work very well.
MR. HAYES: For example, this plant right here which was
done was just done within the last couple months. You know, the
individual who did the plant told me for sure the he didn't believe that
the number was going to be 35. He did anticipate that it was going to
be a couple hundred, and it was on the order of a thousand.
DR. WALLIS: Well, this leakage, though, it depends on
what's happening. I mean, it's driven by something. Sure. If there
are pressure differences through a building because of something like
the wind outside, it makes a difference. If this room is hotter than
another room, and there's circulation-driven stuff, you can't just
measure a leakage and say this is leakage. It depends on what's going
on.
MR. HAYES: Okay, most of these leakages, if you will, are
mechanically induced by either the air handling units which are
operating --
DR. WALLIS: Under some sort of special conditions. If the
conditions change to an accident, leakage will change.
MR. HAYES: Okay, the -- they would if they changed, but
the, if you will, the conditions under which they are measured are with
the emergency control room ventilation system operating.
Now, I agree with you and Dr. Kovach that the important
thing is to find your limiting condition, because it is influenced by
adjacent ventilation system areas.
DR. WALLIS: Right.
MR. HAYES: And so, if you will, it depends upon whether you
have a loss of off-site power or you don't have a loss of off-site
power, whether you're running one train or two trains.
Now, you know, I don't know in all these cases whether that
myriad of ventilation of cases were analyzed. But you're right: they
have to be investigated to find which is most limiting for your
particular situation. And I would also maintain that, if you will,
ventilation systems are dynamic. And what's true today might not be
true next week, next month, you know. And so this is a changing
situation.
DR. BONACA: Did plant A have walls around the control room?
I mean, 4,300 CFM --
DR. POWERS: Walls? It was a tent.
DR. BONACA: It's an enormous flow rate.
MR. HAYES: It is enormous. It is enormous.
Okay, so to summarize a little bit with respect to these
conclusions on these tracer gas is that you recognize now that
approximately 20 percent of the control rooms, 20 percent of the
reactors have been tracer tested. None have met their design basis, and
some we're sure did not meet GDC 19. Okay. There's a -- the variation
between the measured and the assumed in their accident analysis is a
factor of 1.5 to actually 55. Some did seal prior to their testing, and
it improved their condition. I think it can be determined that the
analysis level integrity does not exist. And then finally
statistically, there is no confidence of envelope integrity.
Okay. Now, the question is, okay, where do we go from this.
Okay. In addition to having the tracer gas test results, we have had a
significant amount of issues involving control room habitability that
have been, if you will, inundating the staff. We've had issues
involving licensees' regional and resident inspectors finding and
identifying the design, operating, and integrity flaws, you know. I
think probably it's true that many people hoped the issue of control
room habitability would go away, but it hasn't. You know, we
continually find things. Licensees find things. Resident inspectors
find things. Regional people find things. We have 50.59 evaluations
where there's questions raised as to the adequacy of those reviews in
terms of the changes licensees have made. We have unreviewed safety
questions. We're continually, you know, looking at control room
habitability issues. Okay.
We go to the point where, if you will, you know, we said,
hey, stop. Things have to get better. We have to come up with some
approach.
And so in July of last year, NRC, NEI, and NHUG held a joint
workshop on control room habitability, where the staff outlined their
concerns and the issues that they're dealing with. We had some of the
people who had done tracer tests made presentations, and then we also
had NEI spokespersons make discussions with respect to the various
aspects of control room habitability. Out of that workshop was a
control room habitability task force formed from NEI. The staff has met
with that task force on three different occasions, okay--in September,
April, and then June of this year. And what the staff is looking
towards is NEI is putting together a guidance document on control room
habitability. And Mr. Cozens from NEI, he will be discussing that
particular document. But the staff is basically waiting to see that
document before we take our next step, because the directive to the
staff from the executive team of NRR was to work with the industry to
try to resolve this problem.
DR. WALLIS: Can you put this in some perspective, and is
there a problem of habitability with these leakage rates?
MR. HAYES: Well, I think that --
DR. WALLIS: Are the operators at risk in some way that they
--
DR. UHRIG: Not during normal --
DR. POWERS: Under accident conditions under a design basis
there.
MR. HAYES: Yeah, under normal operation, as the gentleman
said, there is none, but --
DR. WALLIS: Under normal, that's right.
MR. HAYES: But if you would have a toxic gas or if you
would have a smoke event, or if you had a radiological situation, the
operator could be impaired. You know, I don't -- I think it's fair to
say that I don't think any of us believe that at these integrity levels,
that an operator is going to be killed from a radiological accident.
However, I think it's also fair to say that we think it's
unacceptable for the operator to try to perform their function with
self-contained breathing apparatus on in the event of a radiological
event, and in the case of a toxic gas challenge, well, we all ought to
have serious concern for those facilities that have, you know, possibly
inleakage rates as great as that.
DR. WALLIS: Well, the conclusion seems to be from your
studies that all them leak like sieves except when patched up for a
test. That -- that -- and yet nothing concrete gets done about it yet.
They're making studies.
DR. SEALE: Have you detected any graded concern -- there
are few plants which live in environments where there is an increased
toxic fumigation from an adjacent facility.
MR. HAYES: Right. Waterford is a good example.
DR. SEALE: Yes. Have you detected any heightened
sensitivity from plants like that?
MR. HAYES: Not any more for them versus, say, people who
don't have it.
DR. SEALE: Okay. No difference from them and Palo Verde?
MR. HAYES: That's correct. Not that I have been exposed
to. Now, there may be, but I haven't been exposed to it.
DR. SEALE: Okay.
DR. WALLIS: I guess I'm trying to figure out how much of a
-- how much of a problem this really is. If it is a problem, why it's
taken so long? Maybe why it's taken so long is -- it doesn't help, but
just to note that it seems to have taken an awful long time. You go
back to 1980 -- to still have control rooms, if this is an important
problem, leaking sort of 10, 100 times as much as they're supposed to on
paper. If it's an important problem, it seems it rather strange to me.
MR. HAYES: Well --
DR. WALLIS: What's going to happen down the road? I mean,
is the purpose of bringing them back to the design basis or something?
Or there is no design basis, because it's not in some kind of
regulation, I guess.
MR. HAYES: Well, the design basis is in their accident
analysis and their licensing assumptions.
DR. WALLIS: Well, you could close them down if this were a
problem design.
DR. POWERS: But that's all -- the general design criteria
and applicable to this isn't --
MR. HAYES: Okay, yeah, the general design criteria says 5
REM whole body or its equivalent, okay. And so, if you will, the design
criteria is not safe. You know, 100 CFM of unfiltered inleakage or a
1,000 that -- so, for example, if they can get by with 4,000, you know,
and still meet the design criteria from a dose standpoint, you know that
has to be considered to be acceptable.
DR. WALLIS: But has that been considered? Has someone made
this connection?
DR. KOVACH: I think NEI is working on that aspect of it.
DR. WALLIS: They're working on it. I mean, God, I'm sort
of puzzled --
DR. KRESS: Well, but those calculation involves a source
term --
DR. WALLIS: Yeah.
DR. KRESS: And a transfer through the atmosphere. You have
to a have a transfer to the atmosphere --
DR. WALLIS: But you have to answer the question --
DR. KRESS: Close in --
DR. WALLIS: You have to answer the question are these
operators during an accident? And to say that someone's working on it,
doesn't give any answer.
DR. BONACA: Well, one thing I've noticed is the point that,
you know, in part, there is I think a complacency in the --
DR. WALLIS: Yeah, incredible.
DR. KRESS: Which is tied to two issues. One is that's true
that this things are not, you know. And the other one is source harm is
so conservative that it creates all kind of -- and so you have -- you
have a certain attitude on the part of radiological engineers that they
see both sides of the coin, and that's too bad, because it means that we
have no understanding of where this issue is. Okay. What I'm trying to
say is now that we are going towards a more realistic source term
treatment, this becomes more important than ever before, because I think
there are going to be more realistic assumptions of source term.
Well, I'm not so sure because previous assumptions just
assumed it was all metal iodine, and that may be a better assumption in
this case.
DR. BONACA: Okay.
DR. KRESS: Going to the new source served.
MR. HAYES: But I caution you with respect of the new source
term. The new source term is only good for field damage accidents. You
still have accidents, like steam generator tube ruptures -- you know,
the main steam line breaks, and you know in part of your evaluation.
And I think the steam generator tube ruptures is one that you really
need to look at as a real, real, potential accident, which has nothing
to do with the source term of NUREG 1465; it's a coolant source term.
And so your chemical form in those considerations are much, much
different.
DR. BONACA: So there is urgency that this issue get
addressed?
MR. HAYES: Well, you know, I think it's an issue which, you
know, we should deal with it and put it to bed. You know, it's sort of
like having a car where you have a starter problem, you know. And you
can't run your car because the starter is always acting up, you know.
You should get the starter fixed and put it to bed.
DR. WALLIS: But you know that. That seems to be in all
diffused. It would seem that if the control rooms are left and not
source sealed up for the test, they're going to degenerate again until
the leakage is in the order of thousands of CFM. That's -- that would
seem to be unacceptable, unless this -- some other mitigating
circumstance somewhere.
MR. HAYES: Okay. My impression from the sealing work that
has been done to date, you know, prior to these tests, is not -- I don't
think it's a situation where you're just going to degrade, say, from
like this value of 260, which was on there, to, you know, which had
4,000 and went down to, like, 242. I don't think you're going to see
that type of degradation.
Unfortunately, we don't have a whole lot of data in terms of
subsequent test. You know, I think that's something that the staff
believes. When we had our workshop, we thought that one of the
potential solutions to this issue was periodic surveillance of the
control room envelope that demonstrates the integrity, say, on a
refueling cycle basis.
DR. KOVACH: But, one of the -- maybe easier things to
perform for continued surveillance is how many CFM do you need to
maintain a certain pressure in the control room?
DR. WALLIS: That's a measure of the pressure.
DR. KOVACH: Measure, measure the intake flow to maintain a
certain positive pressure.
DR. WALLIS: That's right.
DR. KOVACH: That will give you what your outleakage is if
it's deteriorating or not. You don't necessarily have to go back to
tracer test.
DR. WALLIS: You can do that very quickly.
DR. KOVACH: I can do that quickly, and that's why I said
that we have to have a commensurate test for the relevance of the
system.
MR. HAYES: Okay, let me point out something about that
proposal, though. That proposal presumes that, in essence, you have a
steel box, with the only penetration being that particular ventilation
system. Because the people who did the test at that plant C, see, would
tell you that they had no problem achieving a positive pressure.
DR. WALLIS: No, no, no, no. It doesn't -- it has leaks in
it, so you figure how much you have to pressurize it, and to start the
flow rate. That gives you a measure of the leakage.
DR. POWERS: Yes.
DR. WALLIS: What comes in has got to go out. It's not just
pressurizing the box.
DR. KOVACH: That's correct.
MR. HAYES: But you have to be able to measure the path
that's coming in and out and with the duct work that traverses. In some
of that, you don't see those pathways.
DR. WALLIS: Put a fan in the door and measure the pressure
in the room that it creates. That's all you have --
DR. KOVACH: I mean, these have positive, you know,
ventilation system that feed air into them. What you'd have to do is to
very carefully monitor that and see what -- how much you have put in to
maintain the pressure, because the arrow in that test is exactly the
same arrow that you will see in the tracer test also, because you'll
have to adjust it with the fresh air coming in, because you are looking
at a dilution of a tracer.
DR. WALLIS: I'm not sure it's a linear system.
DR. KOVACH: It is.
DR. WALLIS: If you have something like a curtain, and
there's a wind, the curtain moves.
DR. KOVACH: Yes.
DR. WALLIS: This is an exaggerated case, but if you have
something like a curtain, it doesn't take much pressure to move
something which is venting flow, which is like a curtain.
MR. SIEBER: Maybe I could add that the control room
envelope is often very complicated. They contain a number of rooms that
are separate from one another. And the adjacent rooms may have all
different pressures depending on the ventilation there. You may have
penetrations that leak in, and others that leak out at the same time
while the system's in pressurized operation.
MR. HAYES: Yes.
MR. SIEBER: So it is really not a simple problem.
MR. HAYES: You are correct. Very much so. For example, I
think the -- if you look on your slide, the B plant that was -- has I
think around 100,000 cubic feet in their volume. It's like goes five
stories.
MR. SIEBER: That's right.
MR. HAYES: You know, and it's very different.
MR. SIEBER: And inleakage and outleakage are often
different?
MR. HAYES: Yes.
MR. SIEBER: Mainly because of the door seals, you know,
they're like diodes. Do they leak out better than they leak in,
strangely enough?
DR. WALLIS: I'm trying to put it in perspective, and there
is some other situations where if the licensee were off by sort of two
percent in something, he will be shut down. Here, he's off by 2,000
percent and isn't shut down. What's the justification for tolerating
this?
MR. HAYES: I think probably that the licensee has utilized
Generic Letter 91-18, you know, which allows them to assess it on a
realistic basis, you know. And they have the opportunity to bringing it
back within the design specifications or make a determination that they
can change it and change this design. And they -- they assess it based
upon their impression of the safety significance of the particular
element. And I think it's fair to say that in some cases, control room
habitability is down on the importance level.
DR. WALLIS: So there is some sort of a paper escape clause
that says, although things are lousy, they can continue that way because
we've written some paper. I'm just being naive, but that's what seems
to have happened.
DR. POWERS: I don't know that you're being naive. I think
you're just being puzzled.
DR. WALLIS: I am not perplexed yet.
DR. POWERS: I'm always perplexed.
DR. KOVACH: I think it's worth mentioning, though, Jack,
that some of them manage to bring it down to the levels that you
indicate by excluding certain parts that prior to the test were
considered to be part of the envelope. And as long as they consider
those also, there was no way to bring it down, and they actually
narrowed the control room envelope. And certain areas that were prior
to the test were considered to be part of the envelope became excluded
from it because they were hopeless.
DR. WALLIS: I'm trying to just figure out if the ACRS has
to take some position on this. And what do they do it, between saying
everything is fine and dandy or this is completely intolerable.
Somewhere in this spectrum is the right view of things, and I don't
quite know where it is yet.
DR. KRESS: Because you don't have a risk analysis. It
tells you the importance.
DR. WALLIS: And if I don't know where it is, I've got to be
conservative and say it's intolerable.
DR. POWERS: Well, I think you're going to get a chance to
pursue this further in your --
DR. KRESS: Yeah, in our subcommittee meetings --
DR. POWERS: Subcommittee meetings -- so maybe want to move
on in this?
DR. KRESS: Yeah, I think now is a good time to move on to
the NEI presentation. We need to --
DR. SEALE: I have a feeling that this problem has been
subjected to a rather interesting kind of management attention, namely,
without an accident, it's a mess to fix. And it won't stay fixed -- the
dents in the parking lot problem.
DR. WALLIS: Is this a generic problem?
DR. SEALE: Yeah.
DR. WALLIS: Management attention?
DR. SEALE: In this -- I think it's generally what's
happened. And with an accident, this is the least of your worries, at
least until the lawyer shows up.
DR. POWERS: Well, I think you -- I mean, if you think in,
say, design basis accident space, where you require -- you're certainly
hoping that you have operators --
DR. SEALE: Yeah.
DR. POWERS: Essentially capable of doing their job for an
infinite amount of time, but certainly for 30 days. You know, there is
these questions that -- of habitability clearly are very important --
DR. SEALE: Yeah.
DR. POWERS: And the questions that Dr. Kovach raised about
how do you assess these filtration systems for my two-hour test to 7
days, 30 days plus become very real.
DR. SEALE: There's whistling in the dark going on to answer
your question.
DR. POWERS: And if you move to severe accident space, I
think the attack on the control room becomes a good deal more severe
than it is under design basis space and maybe -- on the other hand maybe
the demands on having operators present and capable drop off pretty
dramatically, too, because there is not much they can do once you get
into a severe accident.
DR. WALLIS: How do you find leakage? You don't go around
with a candle.
DR. KOVACH: Certainly, there's precedence for it.
DR. WALLIS: Worked once?
DR. KOVACH: You actually generate a tracer and use the
outside tracer detector in areas --
DR. WALLIS: You go around and sniff for it?
DR. KOVACH: You sniff for it, and then you can shroud off
-- in many cases, you can see it. You don't need to run a tracer test
for 90 percent of the latter, just find the holes. In fact, you can
hear the whistling in some cases.
DR. WALLIS: I was just wondering if you would -- the
keyhole.
MR. HAYES: Mark?
MR. REINHART: This is Mark Reinhart again. I'd just like
to add, there are a number of facets to this, this issue, and the staff
really does want to see it resolved as a package, all the facets, so
that we do have a proper control room habitability. And I think that's
what we're looking for right now. We're hoping this NEI initiative gets
the industry started in the right direction, so we're going to be
looking to see what happens there. I think Mr. Cozens will probably
update us on that, but we're looking for something this month as their
initial proposal.
DR. WALLIS: I dare say I was very surprised. Here's a
problem which affects public safety, or at least some safety of people.
Here is an agency in charge of that waiting for this could be to give
them something, tell them what to do. It seems to me extraordinary.
Again, I am being my naive self, and this is my reaction.
DR. KRESS: Well, with that comment, I would like to turn
the floor over to Cozens' NEI to give us some presentation.
MR. COZENS: Good afternoon. I'm Curt Cozens from NEI. I
am the senior project manager responsible for this issue at NEI, and we
have a summary here of where we stand today, and how we got to where we
are, and I'd like to share that with you.
Just as the punch line I think was mentioned earlier that
the staff is waiting for our guidance document. That is true. We've
discussed it with them, but we have not actually provided it to them as
of yet. We're still having to work on some of the details. It's a
fairly substantial document--about an inch thick. And we're looking for
guidance that will both educate the industry, because there's always
that issue of bringing everybody to a common baseline, as well as the
effort to give some structure to provide a consistent set of guidance
that licensees can, indeed, follow.
So having said that, which is a little bit of a stealing the
thunder on my presentation, let me just do a little review of where
we've been on this thing.
We actually did not get involved in this until last year,
1998. Formerly, we probably kicked off our activities of understanding
this issue on a more generic basis in July of '98.
DR. WALLIS: So, mate, those were emerging concerns for a
problem which has realistically been here all along.
MR. COZENS: These are issues that we have been aware of.
We had been -- the GSI was at 83, had been put to bed, and those were
the reactions that were responding to. Subsequent to some additional
test issues that have come out since then, new information has become
available. It's not always readily cognizant of the significance to
individual plants, and that's one of the things we've been developing in
this process as we've gone further and further into it.
As a result of the workshop, which did, indeed, define the
issues of concern to the NRC staff; it redefined it to the industry,
taking Jack's slide. It looks like, indeed, these were some of the same
concerns that had existed previously, and we revisited them and have
worked on understanding better what these really mean to the industry.
As a result of this workshop, NEI did, indeed, form a task
force to deal with this and to - with the goal of providing guidance
back to the industry, and I'll get more into that in a bit.
Back in September of last year, we had formulated some of
our thoughts on how to approach this issue, some of the concerns. As
you can imagine in an issue of this nature, there is a lot of wrangling
that goes on with 100 odd plus plants, various utilities, individuals
with different perceptions and needs, and we have to bring them together
in a single position. That's an interesting challenge that, indeed, we
needed to wrestle with and are continue to wrestle with.
DR. POWERS: Well, I guess the question comes up when they
see results of a sampling that says 100 percent of the sampled control
rooms failed to meet what was assumed in the FSAR for the inleakage and
not by small margins. Did somebody actually say that now that's good
for everybody else, but my control room's okay?
MR. COZENS: There was some interesting discussions on that,
but I think we'd have to conclude that that's an issue at hand.
DR. WALLIS: It seems interesting. The response to all this
is to discuss it?
MR. COZENS: No, what we're doing here -- we could come in
and everybody could manage it in 104 different manners. That's not a
good use of resources. We're trying to provide some consistent guidance
and some logic behind it. And any time you're dealing with this type of
issue, you must realize that there will be differing of opinions.
They're not always right, but at some point you need to bring them
together and provide a logic that is somewhat irrefutable, because not
everybody has all this information at hand.
MR. SIEBER: Curt? The small bullet under the third item,
issues of compliance, concern, but low safety significance.
MR. COZENS: Yeah, I think one of the things that Jack's
slide, which I thought was good -- it showed that there was quite a
variation in measured in unfiltered inleakage. This is what we're
talking about, which is really a focus of the radiological issues more
than the toxic gas, because you may not have unfiltered inleakage, you
just may have inleakage because you were isolated, not necessarily
pressurized for the toxic gas. There may be more experts in this room
that can clarify that more than I can, but issues of compliance.
Compliance is what did you assume in your analysis, and what
do you actually have there?
That is the different number than you might -- the maximum
number you might be able to tolerate and meet the requirements.
MR. SIEBER: Well --
MR. COZENS: So we don't have -- in many cases, these
numbers were, to be quite frank, cookbook, the 10 CFM. That was a
number that was widely used back when these designs were being made,
rightly or wrongly, apparently it actually looks like it's probably not
a good assumption. And it was readily accepted in the days that those
were made, and so being that that had been an example of reasonable
number to use as an assumption, it was used by a large number of people.
It wasn't challenged by staff or industry. Wrongly, rightly, that's the
way things were at that point in time is a poor assumption.
DR. WALLIS: Ten CFM, excuse me, led to some sort of
radiation -- REM calculation or something?
MR. COZENS: Yeah, it did and all it would have demonstrated
that you were lower than some other value.
DR. WALLIS: Well, but then, what was the margin to
acceptability?
MR. COZENS: That's one of the things that's many people are
going to have to probably look at as they examine this situation.
DR. WALLIS: Well, crudely speaking I say if I got 10 CFM, I
have ten to the minus five millirem or something. I've got a thousand
times as many CFM, I just multiply it by a thousand.
MR. COZENS: They're -- we're probably -- I don't have a
hard number to provide. That will be a very pleasant --
DR. WALLIS: Isn't that an order of magnitude calculation
that's not unreasonable?
MR. COZENS: Probably.
DR. WALLIS: And does that exceed some acceptable dose rate?
MR. COZENS: Not necessarily.
DR. WALLIS: Does it or does it not. I mean, as a
calculation, it can be done very simply by -- without discussing
anything -- just taking the numbers on Jack's slide and saying, is there
a problem here or not.
MR. COZENS: The -- what I'm saying is that once they used
an assumption that gave them an acceptable answer, they didn't establish
the margins.
DR. WALLIS: They did -- if the allowable number is 10, and
then calculated 1, then is something goes up by a factor of 10, they're
up to the limit. Is it not as simple as that?
MR. COZENS: If that was the number. The point is, and what
I'm saying here I don't know what each plant had, so I am unable to
answer your question. I can say --
DR. WALLIS: But the NRC or someone could have said, do this
calculation. It takes five minutes, and let us know the answer if
you're outside what was originally -- what -- whatever the regulations
say you should have for a dosage to operate, is then we'll shut you down
or something. I don't under this waiting for some --
MR. COZENS: Well, if you let me continue with this
presentation --
DR. WALLIS: I'm sorry. Maybe you should go on.
DR. KRESS: Well, the question I might have asked about that
is how is this determination about low safety significance made?
MR. COZENS: We have done an analysis of margins on the
various parameters that are input into this analysis, and have concluded
that we're on the order of 50 to 100 factor of excessive margin in
assumptions that are put into the analysis.
That is no -- that is a rough order estimate. And that's
something that we've shared with the staff in June.
And they have yet to have a chance to totally review it, so
I don't want to go beyond the fact that's what -- when we did our
analysis, that's what we came up with.
But the point is, it's clear there's a lot of margin in
these analyses, and that's something that will be included. That's not
to discount the concept of compliance. That's just a technical
understanding of what the this thing is
And so based upon that, that plus the value in the GDC is
believed to be extremely conservative, that just because one would
exceed the GDC criteria, we don't believe is a ready indication that the
operator would, one, be unable to perform his duty, nor would it result
in an immediate health issue for the operator.
DR. BONACA: Although I can tell you that I have seen cases
where the calculations have been redone entirely, and for normal
accident analysis, they come very, very close to the limits for control
room habitability. So I am saying that I don't think there is the
margin that you seem to indicate there is.
MR. COZENS: This margin is within the way that the analysis
is structured, which will be detailed more in our presentation, probably
in September.
But we had concluded, based upon our evaluations under
basically the guise of Generic Letter 91-18, for the individual
licensees, when they did their studies, that they were able to continue
to operate and, indeed, I believe did in all cases. But the point being
that there is a difference between what is used as an assumption and as
a licensing basis, versus what the maximum number would be, and that is
something that needs to be studied further.
And then we basically have taken our path the guidance to
the industry for resolving this issue, something they would be able to
adopt.
Over a period of time in the September to October timeframe
of last year we, in writing, laid out to the staff where we were going
with this issue. We received some feedback from staff urging us to take
extra emphasis on the unfiltered inleakage issue, which we have, and we
responded back to them.
We have subsequently developed some early drafts of the
guidance document that we are continuing to work, taking into
consideration some of the comments that we did receive from the staff,
from our presentation material, and also some additional work that we
have been doing.
We met with the staff in June of this year to provide them a
review of the margins analysis that we have done. Again, we got some
additional feedback on that which we are continuing to pursue.
Our objectives are very simple. We are interested in
assuring adequate protection of the control room operator. This is of
very high importance to us. We do indeed need tight control rooms for
that. How you manage that is the subject of our guidance. Given what
we see this as, the relative safety significance, what is the effective
response process? That is one of the things that we have had to wrestle
with, there are many competing demands when you get into providing
generic guidance to an industry.
DR. WALLIS: Excuse me. These margins analysis, did you
submit documents where you calculated the dose and so on? You indicated
there was a 50 to 100 factor margin. Do you have -- is that written
down somewhere?
MR. COZENS: Not in this presentation.
DR. WALLIS: Could we see if it is written down somewhere?
MR. COZENS: It will be provided at the September meeting,
yes.
DR. WALLIS: In September?
DR. KRESS: We are having a subcommittee meeting in
September.
DR. WALLIS: So it is all put off, right? We haven't see
anything quantitative about this issue.
MR. COZENS: Staff has that information.
DR. WALLIS: Staff has it. Can they give it to us?
MR. HAYES: We have had a discussion on it, but we don't
have anything in terms of -- we haven't seen the discussion of it.
DR. WALLIS: We are back to discussion again.
MR. COZENS: Pardon?
DR. KRESS: We hope to get some hard information in the
September subcommittee. That is why it was put off till September
actually, to have time to get this information together.
DR. WALLIS: Well, maybe I will have to ask my colleague,
Dr. Bonaca, to give me his figures where he says they actually come
pretty close to a margin.
MR. COZENS: We are studying the assumptions that are put
into the analysis, not the actual analysis, and have dissected it and
which does demonstrate a fairly significant margin.
DR. POWERS: I assume we can translate that and the
objective is to find a paper way out of this problem.
MR. COZENS: No. I will emphasize what the purpose of that
is simply. To say that you have margins does not eliminate to have
compliance with the regulations. It is a technical understanding of
what is the consequences of this. It is useful in doing an operability
determination, but it would not eliminate the need to be in compliance.
DR. WALLIS: Are there any other regulations like this?
MR. COZENS: I am not certain I understand your question.
DR. WALLIS: Where you can say we don't meet the licensing
basis, but there is a huge margin, so we don't need to worry. Are there
are other regulations like that?
MR. COZENS: The licensing basis frequently establishes a
number far lower than the regulatory requirement. That is what we have
here. The assumptions that were used for unfiltered inleakage, which is
just a -- I would have to check carefully with our licensing folks.
That in itself is not the regulation, it is a number that was used in
the design.
DR. WALLIS: So we are back to margins and what they mean.
MR. COZENS: But that is not the solution to this problem,
as I just said. The solution to this problem will require compliance to
assure that they in compliance.
DR. KRESS: Well, we just heard that there is a lot of the
plants assume 10 CFM.
MR. COZENS: Yes.
DR. KRESS: And we also heard indications that that is
impossible.
MR. COZENS: Yes.
DR. KRESS: So, I mean you are going to change the licensing
basis, is that the way you get into compliance?
MR. COZENS: The plants that have done the testing, -- and,
Jack, maybe you could confirm this, did they change their licensing
basis?
MR. HAYES: Those that didn't restore them to the original
level. Like some of those plants, like I think it was C, maybe E or F,
they had the values at 260, they went below their original licensing
basis, so they restored it. Other ones have not, they have used some
higher value and come up with a new analysis.
DR. KRESS: They still meet the GDC criteria.
MR. COZENS: That's correct.
MR. HAYES: Yeah, they still meet the GDC. Yeah.
Probably with some form of a margin on top of that even.
Those are very plant-specific situations that need to be analyzed by the
plants. We are trying to provide the generic structure on how to
approach it so they can walk into this using good, appropriate resources
balanced against other needs in the plants.
DR. WALLIS: I am kind of interested to see what would
happen with a 50.59, where you were trying to prove your change
inleakage was minimal. It would be a really interesting exercise to
see.
DR. POWERS: If your inleakage is 4,300 cubic feet per
minute, to make a small change in taking out a fire detection system,
leave a hole in there, I suspect it is a 50.59.
DR. WALLIS: Well, there is a connection. I am sorry we are
-- the reason I am doing this, because it impacts on so many other
things we have discussed in this committee. In all our discussion of
50.59, there was this reluctance to give up margin, and this slowly
takes small bites out of it and so on. Here it seems as if there is a
willingness to give up the whole margin, in fact, not even quite know if
you are doing it or not.
You had better go on.
MR. COZENS: The approach that we have taken in this report,
which will be provided, recognizes the significant variation in plant
design and licensing criteria. Plants are very different. Each plant
has its own unique physical configuration, frequently different
hardware, very often different licensing requirements that impact them,
very often different technical assumptions that were made that have to
be walked through, validated, and generated.
The unfiltered inleakage which is one of the questions that
arise was only one of the issues that was raised by the NRC staff. We
are looking at all of the issues that were identified by the staff.
We are looking at trying to provide guidance that will
indeed provide a balanced approach, one that demonstrates that the
operational staff is indeed protected, that is in compliance, but also
is using an optimization of the resources that the licensee has. These
are all things that each licensee needs to balance to be an effective
producer of electricity. And that's just one of the -- how we're
approaching this thing.
The document which is NEI 99-03 develops guidance that
licensees can use. It has a very strong educational role for licensees.
As I said, a lot of staff rotation has occurred on this. Different
States, and I'll be quite frank, believe in the significance of this.
We need to bring it to a common point.
DR. WALLIS: Is this close to be a finished document?
MR. COZENS: Yes.
DR. WALLIS: Or is it just an outline?
MR. COZENS: No. It's about 100 pages right now. We're
doing the polishing on it right now.
DR. WALLIS: How much more is left to be done?
MR. COZENS: I'll address the schedule in a second.
DR. KRESS: When you do a design basis calculation here to
determine the dose, do you just input into that calculation the
unfiltered leakage rate?
MR. COZENS: You might be better off asking that specific
question of somebody -- maybe the gentleman next to you, Dr. Kovach.
DR. KRESS: That's the reason I asked, because Kovach said
that may be a real problem.
DR. KOVACH: It's a combination of they take credit for the
forced ventilation for the system plus that it's assumed that what is
the inleakage. And there are questions whether the assumptions put into
the forced ventilation efficiencies are realistic or not. Those are the
99.9-pluses. Because how much inleakage you can tolerate depends
greatly on what is the efficiency of your --
DR. KRESS: What you're saying is there's two parallel
paths.
DR. KOVACH: That's correct.
DR. KRESS: And one of them has a filter.
DR. KOVACH: Yes. The other is not.
DR. KRESS: And so since there's 99 percent, it doesn't
enter into the dose.
DR. KOVACH: If you in fact get a 99 percent.
DR. KRESS: Yes. Because that's what they use.
DR. KOVACH: Yes.
DR. KRESS: It doesn't enter into this calculation.
DR. KOVACH: Yes.
DR. KRESS: So that looks like -- is that being addressed in
the NEI document at all?
MR. COZENS: We primarily are focusing on the --
DR. KRESS: Unfiltered.
MR. COZENS: Assumptions that had been taken in the initial
analysis and giving them guidance on how to make more appropriate
assumptions.
DR. KOVACH: But the mix that will give you the dose is a
factor of both.
DR. KRESS: Yes.
DR. WALLIS: I don't think you should give guidance on
assumptions. You should give guidance on reality.
MR. COZENS: As in many engineering features in a plant,
there's thousands of assumptions made that keep these plants operating.
DR. WALLIS: That's one of the problems. You have to know
how close these are to reality. You have to know something about the
uncertainties. When you use a number you've got to have some awareness
of -- you can't just say it's an assumption. You've got to qualify it
and quantify the nature of that assumption.
MR. COZENS: It has to be based on something. We agree.
DR. POWERS: Dr. Kress, I'll call attention to the timing
here, recognition that we will be doing a subcommittee --
DR. KRESS: Yes, I think we need to move on.
DR. WALLIS: I'm sorry I'm taking too long. I suppose it's
because I'm surprised.
DR. KRESS: We'll get a chance to talk about this some more.
You're welcome to come to the subcommittee meeting.
DR. WALLIS: I was afraid you might say that.
MR. COZENS: Let me hit on the near-term activities. As I
said earlier, we will be giving the staff a copy of the draft document
for formal commenting prior to the NHUG meeting, which will take place
about the time of the August ACRS meeting, or is there -- August 12, 13
I believe is when the NHUG meeting is. We'll be also in a parallel path
providing that to the NHUG members, and we'll be soliciting feedback
both from the staff and from the NHUG members.
Once we take that input, make whatever refinements are
justified based upon the comments we receive, we will be making
adjustments to the document, and we hope to get that final document out
for industry use late September, early October time frame.
I have outlined here the basic sections of the 99-03
document, and we'll be happy to go through those in detail if you wish,
but in light of the time I don't know if you want me to continue on that
or not. It's pretty self-evident.
DR. KRESS: Yes, looking at the slides, I think we could
postpone that part to the subcommittee meeting later when there's --
DR. SEALE: That's a good idea.
DR. KRESS: When we can get into really detailed questions
on it.
MR. COZENS: Yes. We'll have more expertise with this that
would probably be better equipped on a few of the questions. Okay?
DR. KRESS: Okay.
DR. WALLIS: Do you know ahead of time, is this document
going to say there is a problem or there is not a problem?
MR. COZENS: We are giving guidance for plants to make that
decision.
DR. SHACK: Look at slide 8.
DR. SEALE: Yes, that's -- 8 did it.
DR. POWERS: I just can't help but note that those of us
that run chemical facilities -- and I guess, Dr. Kovach, you know more
about this than I do -- seem to be in the world of where -- we live in a
world of ratcheting protection on our workers with ever finer and finer
demands being placed on us to assure their protection against chemical
hazards, and ever greater and greater scrutiny from both State and
Federal officials on our ability to protect our workers. This seems to
be a very relaxed environment relative to that.
Fair statement, sir?
DR. KOVACH: Reasonable.
DR. POWERS: Reasonable.
MR. SIEBER: Could I ask one final question of Mr. Hayes?
Does the NRC staff believe that this issue is one of low
safety significance as the NEI slide indicates the industry believes?
MR. REINHART: I think that we've not concluded that. The
bottom line is is it's an issue to the operator, and if the operator
doesn't function, is he available to take actions for the plant, and to
what extent would this impair his abilities not only radiologically but
toxic gas, smoke? So those are concerns we have.
MR. SIEBER: Is that safety-significant? Your concerned?
MR. REINHART: It's significant. I don't know that we have
an answer as to how significant.
DR. WALLIS: Just naively, I would think 4,000 cubic feet of
smoke would be one humongous hazard in a control room.
MR. REINHART: I think smoke and toxic gas definitely.
MR. SIEBER: About half the plants clean their condensers
with gaseous chlorine, and that's usually within a couple hundred yards
of the control room air intake, and I've seen a couple cylinders go.
That's -- they're five-ton. And that's bad news.
DR. KRESS: Yes, but leakage is not 4,000. It's going to be
like 400. Yes.
DR. POWERS: Well, good.
DR. KRESS: Okay. And with that we'll --
DR. POWERS: I'm going to recess until one o'clock.
DR. SEALE: Till when?
DR. POWERS: One o'clock.
DR. SEALE: Okay.
[Whereupon, at 12:12 p.m., the meeting was recessed, to
reconvene at 1:00 p.m., this same day.]. A F T E R N O O N S E S S I O N
DR. POWERS: Let's come back session now. The subject for
this afternoon is the proposed amendment to 10 CFR Part 50.55a. And Dr.
Shack, I believe you're the cognizant member on this and I'll turn the
meeting to you.
Incidently, in the course of this presentation, I will be
transferring control of the meeting over to the member-at-large, to --
so -- and disappear, unfortunately, for some other purposes. So, Dr.
Kress, you will -- might as well assume the gavel right now.
DR. KRESS: Okay.
DR. SHACK: Again, 50.55a is the portion of the code,
essentially where you endorse the ASME code for -- incorporate by
reference the ASME code. Mr. Scarbrough will be discussing that today.
There's a number -- it's been a while since this has been updated, so
there's a list -- he's responding to, I guess, public comment that
ranges about an inch-and-a-half on various aspects of it. In many ways,
or at least in my mind, one of the most important things is to
incorporate the necessity for performance demonstration of ultrasonic
inspections and that was one of the contentious items in the thing,
since it was an expedited schedule for the implementation of the
performance demonstration.
Again, you can say in the old ASME code, the requirements
for Inservice Inspection were prescripted. They told you what to do.
It didn't matter when you did it whether you found the crack or not, you
know, you followed the rules. The performance demonstration says that
you actually have to demonstrate that your technique, whatever it is
that you use, will find cracks. And so, I believe that's an important
one. But, there's a number of other changes and in looking at Mr.
Scarbrough's view graphs, I think he's going to do a heroic attempt to
try to summarize all the changes and all the public comments that were
received. Again, another large part of the public comment is the fact
that the NRC endorses the code with some limitations and modifications.
And, again, the consensus people always have a little problem when their
work is not adopted completely.
But, I understand Dr. Sheron wants to give us an
introduction to this.
DR. SHERON: I'm Brian Sheron. I'm an associate director of
Project License and Technical Assessment. I had asked if I might have a
couple of minutes of your time to talk about one of the issues and I
discussed this with Dr. Powers some time ago. I thought it might be a
good idea just to kind of least put a perspective and a question on the
table, because it will come up again, and that has to do with the
necessity of when we update 50.55a, whether it's necessary to require
licensees to update to the latest endorsed edition of the code or
whether there is a position, in which we only require them to update to
those aspects of the code that provide a substantial increase in safety,
namely -- or a backfit, you might say. In other words, we pass some
sort of a backfit test.
When we looked at the ASME code, the '95 edition, the only
piece of it that would pass a substantial increase in safety test or a
backfit test, cost benefit, was Appendix 8. The industry had proposed
-- and this goes back aways to about 1994, '95, Entergy came in before
they were required to do their 10-year ISI update, and proposed to be
able to cherry pick, you might say, from the next edition of the code.
They argued that imposing a new edition on the code in total constituted
a real burden for them, or at least some licensees, in the sense that
every time they would -- you would change something, a lot of times it
involved having to change manuals in the plant for doing the Inservice
Inspection and testing; you would have to retrain some of the
technicians. But, the extent of the change was not such that it may
really enhance safety. It was just perhaps a better way to do
something, but not something that would provide any quantifiable
increase in safety.
We did not agree with the ability to cherry pick. We
struggled with the issue for some time. Finally, when we were getting
to the final throes of endorsing 50.55a, NRR decided that we could not
basically demonstrate that there was any measurable safety enhancement,
i.e., from the 50.5109 standpoint, and so we said that we would endorse
it as a voluntary code, namely that the industry could use it. We had
no objection to them using it, but they were not required to. The only
piece they were required to implement was Appendix 8.
That, obviously, generated a lot of debate. I believe the
ACRS issued a letter on that. The Commission finally decided that we
would endorse, as a requirement, the '95 edition, with the '96 addenda
of the code, and that we would come back to them this fall, presumably,
with the recommendation on the question of voluntary versus mandatory
updating.
I just wanted to bring that out, that the approach we're
taking, it may have been misperceived that we were not going to allow
anyone to update to a later edition of the code. The only thing we were
saying is we were certainly allowing -- and some utilities may find
benefit in updating to a newer edition of the code, for whatever reason.
A lot of it is plant -- plant specific. Of the utilities, for example,
a plant that may be shutting down in two or three years, it may not be
worth their while to spend the kind of money it takes to update, just to
operate for a few more years. So, we felt that in order to be able to
rationalize when someone had to update versus when it could be
voluntary, we should apply some sort of a safety test, which fits in
with some of the NRR goals of no unnecessary burden.
I do want to point out that we raised this issue with ASME,
I know I raised it personally several years ago, and have asked the
ASME, it would be very, very beneficial if, when they issue an edition
of the code, they could distinguish between what is -- should be a
voluntary or an acceptable way to update versus what is mandatory. If
that was in the code, itself, in other words, if they did the screening,
that would make our life a lot easier.
I don't believe they do that now. We asked them, you know,
perhaps to do some sort of a qualitative risk assessment or the like of
what the benefits are. That's not being done. We have -- I feel that
the NRC has an obligation, that we should not automatically impose a new
edition of the code on the industry, without being able to quantify what
the safety benefit is compared to what the burden is.
DR. POWERS: As you know, Brian, when we talked about this,
I thought the suggestion -- this point of view that you had, had broader
significance in this particular issue, in thinking about further -- how
does that interface with the public law, concerning the use of consensus
standards? And I noticed in a lot of the public comments that same
issue came up. Have you thought about that at all?
DR. SHERON: Yeah. People are interpreting that in many
different ways, usually to their own benefit.
DR. POWERS: Of course.
DR. SHERON: You know, people that are advocates of
mandatory updating will cite the public law and claim that, you know, we
are required to use the code. The public law basically says --
DR. SHACK: Well, you're currently required to use it and it
will take a rule change not to update.
DR. SHERON: Right; yeah. But what I'm saying is that the
public law says that we will use consensus codes and standards, okay, as
long as they are not contrary, okay, basically to the agency's mission
and the like. And to me, I interpret that to mean that we have our own
regulations, including cost benefit, you know, backfit rule and so
forth. And to the extent that we endorse the ASME code, I feel it's
consistent with the public law. But, we're endorsing it as voluntary to
use. It's acceptable to use, okay. We're not -- we're not telling
people they can't use it. But, we're not forcing them, that you must
use that edition of the code and only that edition.
We ran into this a little bit on IEEE 603. I don't know if
you remember that. It replaced IEEE 279, which was actually withdrawn
by IEEE, I think, back in the '80s; and, yet, our regulations still
endorsed it. We thought it was going to be a real simple thing, because
603 was the new version, okay. We went out with a direct final rule to
change our regulation to replace 279 with 603, and we ran into a buzz
saw from the industry, because they argued that it had -- it went beyond
the scope of 279, because it did include digital. They claimed that
they had to, you know, do a -- I can't remember the exact words, but you
had to go to the system level -- I'm sorry, down the component level, I
believe it was. But, anyway, we immediately had to drop off the direct
final rulemaking approach.
We thought we fixed the problem by backing off and saying
that they only had to do the assessments down to the system approach.
That still ran into a buzz storm of -- you know, of objection from the
industry. And we wound up, basically, endorsing it as a voluntary -- as
a code that could be voluntarily used. But, we could not justify -- we
could not pass a cost benefit test that says, you know, we can impose
this. So, we're running into that kind of a problem, is that as these
codes are updated, it's very difficult to be able to sit there and say
this is a substantial increase in safety, okay.
We need to address the issue. We asked the Commission if we
could have more time to address the issue, to dialogue more with the
committee. I don't want to dialogue now. I am not asking for that. I
want to get off here and let Tom get up here. But, I did want to place
the issue, you know, kind of on the table, let you think about it,
because we will be back, okay, probably with a recommendation in this
area. And I know the Commission, and I've spoken to some of the
Commissioners, they are not very comfortable when the ACRS and the staff
are at odds, okay. So, we would like to reach some sort of a consensus
with the committee on how we can address this concern.
And this is a concern with the industry. Most of the
industry comments that we've received, if I'm correct, basically agreed
with the NRC's position, that we should not automatically mandate the
next edition of the code. So, I'm kind of struggling myself, because
ASME is supposedly -- the code is an industry code, and, yet, I get
letters from the industry that say don't impose it, and the ASME says
you must impose it, okay. So, we're kind of struggling there and I've
kind of asked NEI if they could work with ASME and solve what these
differences are. It would be a lot easier for us if both sides came in
and said this is the right way to do it.
DR. POWERS: There is a second stage in your position, as we
discussed it, and that was we don't impose, if there should be something
in an update that a rule of tremendous significance, the staff could
always mandate that. And in thinking about that, I said, well, does the
staff have the capability to -- clearly the staff has a very clear
capability and will establish capability to look at particular issues
and say this is safety significant and it satisfies the backfit rule and
I can impose it, and do that assessment. But, these industry standard
codes, they have lots of little things in them and especially now a
days, it's lots of little things. You're not getting --
DR. SHERON: A lot of them are just relaxations.
DR. POWERS: A lot of them are relaxations.
DR. SHERON: Right.
DR. POWERS: And -- but on the other hand, lots of them
bring new technologies that allow lower worker dose and things like
that. The staff have the capability to look at lots of little things
and combine them all together and then say, now, does that satisfy the
backfit rule.
DR. SHERON: Not very easily, no. But, you know, that's one
of the issues that we have to struggle with, okay, is that, yeah, you
could say, you know, how do I add up a whole bunch of little good things
and a whole bunch of relaxations, you know, and try and say where does
that come out and is that something that I can, you know, force the
licensees to adopt or the like. I just don't know. I don't know how to
answer that. I think research tried that, at one point, and they kind
of threw their hands up and they said they really can't. Because, a lot
of times, I know they've changed things in one part of the code and it
affects another part, and you can't -- so, that's why we eliminated this
any option called cherry picking, okay.
The other thing I did want to point out is that from a
safety standpoint, you can have a plant that reached its 120-month
update, say, last year, I guess, okay, and they would update to the 1989
edition of the code. Well, with the exception of Appendix 8, they're
going to run another eight or ten years, before they have to go to the
'95 edition, okay. So, it's very hard for me to argue and say, there is
enough of a safety benefit that I can impose this.
What I'm saying is one plant has to update today; another
plant doesn't have to update until 10 years from now, okay. Why is
that? If this is so good, why don't I make everybody update at that
time? Why can I allow these 10-year periods to go between plants?
That's a difficult thing. I mean, I realize it's just the nature of the
beast, but it's something that, you know, is hard to answer.
Anyway --
DR. POWERS: How many other states -- how many other plants
are located in states, where the state makes them update like within six
months? States aren't liberal as you are.
DR. SHERON: I'm going to have to turn to any you guys, if
you know, because I don't.
MR. SCARBROUGH: Tom Scarbrough. That's another question
we've indicated from trying to get information from the states in that
area, but we don't have an answer for you right now
DR. POWERS: They don't -- theirs is not -- the states that
do it are not nearly as good -- I mean, they say do it.
DR. SHERON: But, I think that's only for the non-nuclear
part. They don't have the --
DR. POWERS: Yeah.
DR. SHERON: -- jurisdiction.
DR. POWERS: Yes, where they have jurisdiction.
DR. SHERON: Yeah. So, anyway, unless there's any further
questions, I just kind of wanted to, you know, lay out the issue and let
you know we'll be back. If you can think about it and, you know, we'd
like to reach some sort of a consensus, so we can go back to the
Commission and -- I'm trying to urge NEI and ASME to see if they can
reach some sort of consensus, too, because they seem to be miles apart
on this, and it makes our life much more difficult.
DR. POWERS: The ASME sounds like it's in survival mode
here.
MR. SCARBROUGH: Good afternoon. I'm Tom Scarbrough. We're
going to give you -- attempt to go through the significant changes and
response to public comments that we received on the proposed rule change
that we sent out. And I want to give you a little bit of background, to
back up a little bit, and sort of tell you how we got to the point where
we are today.
As a little introduction, as you know, the regulation --
DR. POWERS: I can't help but think you've been looking at
codes and standards too long. You try to produce view graphs that read
like the ASME code.
[Laughter.]
MR. SCARBROUGH: Yes, I've been accused of that by others,
as well. I apologize.
DR. POWERS: But, you're not going to change, right?
MR. SCARBROUGH: I've told people the same thing. It's too
late; I'm too old.
In terms of the regulations in 50.55a, they require power
plant owners to construct, inspect, and test specific components in
accordance with the ASME Boiler and Pressure Vessel Code, with certain
limitations and modifications. Back on December 3rd of '97, the NRC
published a proposed rule to update the regulations, to incorporate by
reference the '95 edition with a '96 addenda on the ASME Boiler and
Pressure Vessel Code and the new ASME code for Operation Maintenance of
nuclear power plants, the OM code, with certain limitations and
modifications. We, also, had provisions in there for endorsement of
specific code cases and other portions of the code, to try to advance
the technology aspects.
We went through those comments. We revised the rule. We
took out several proposed limitations or conditions that, based on
public comments, appeared to be well founded. So, we reviewed those or
modified other aspects to make it more clear.
Then on April 27th of this year, we published the proposed
rule supplement, which focused on the 10-year update requirement and the
proposed elimination of that requirement. And then on June 24th, we
received a staff requirements memorandum from the Commission, which
directed us to proceed with completing the December '97 proposed rule
expeditiously and to address elimination of the 10-year update issue in
a separate rulemaking. So, we have two separate tracks now that we're
working on.
DR. POWERS: In your separation of tracks, is the 120-month
update track going to accumulate lots of baggage along with it, or is it
going to be -- remain pristine?
MR. SCARBROUGH: We're going to try to just keep it on a
10-year update issue, so that we don't bring other things into it. I
think one thing we have talked about is in the next rulemaking or so, to
try to go through 50.55a and sort of scrub it and make it more readable,
which would be a nice idea. And so -- but, we're trying not to do that
in these, just because we're trying to focus just on the issues we're
trying to deal with. But, that's something we've talked about.
DR. SEALE: No new areas of confusion.
MR. SCARBROUGH: We're going to try to do that, right; try
to stay away from new areas of confusion.
I won't talk about the third slide there, the elimination of
the 10-year update. Brian has already given you kind of background on
that. Let me just go right into what the current regulatory
requirements contain and to give you a little bit of feeling from where
we are today.
50.55a presently requires that power plant owners construct
class one, two, and three components to the 1989 edition of Section 3 of
the ASME Boiler and Pressure Vessel Code; inspect class one, two, and
three components to the 1989 edition of Section 11 of the Boiler and
Pressure Vessel Code; inspect MC and CC containments, metal and concrete
containment components to the '92 edition, with the '92 addenda of
Section 11; and then test class one, two, and three pumps and valves to
the 1989 edition of Section 11 of the Boiler and Pressure Vessel Code.
And then, as we talked about, there's a requirement that they update
every 120 months to meet the edition and addenda of the code,
incorporated by reference and, in effect, 12 months prior to the start
of the new 10-year interval. So, there's sort of a one-year grace
period up there, to allow people to get ready for the new change.
We talked a lot about trying to give you some highlights of
what the major changes are, so that maybe it's easy as possible to work
your way through this. The highlights of the rule -- for example, we
update 50.55a to reference the 1995 edition, with the '96 addenda of
Section 3 and 11 of the Boiler and Pressure Vessel Code; and then, also,
endorse the 1995 edition, '96 addenda of the OM code, so that brings up
to that year. We have one expedited schedule, as a backfit to require
Appendix 8, regarding performance demonstration for ultrasonic
examination systems, to be implemented as contained in the '96 addenda
of the Boiler and Pressure Vessel Code, Section 11; or, in response to
the industry's performance administration initiative, they can implement
Appendix 8 as described by the PDI. So, there's two paths that they
could use to expedite. Also, there's a relaxation on the schedule, too.
We, also, provide certain limitations on portions, as always
we do. For example, the use of the ASME standard NQA-1 on quality
assurance, seismic design of piping issues and MOV stroke-time testing.
And, also, we permit several code cases to be implemented. So, that's
--
DR. POWERS: If I wanted to use the code cases, but I
currently had a plant that was in compliance with the '89 edition, could
I use these code cases?
MR. SCARBROUGH: Yes. They have to have -- they're subject
to NRC Commission approval. There's a portion in there. But, this
endorses them, so there won't be any extensive review.
DR. POWERS: I understand, to upgrade to the '95 -- to use
the '95 code cases?
MR. SCARBROUGH: No, no. You have to make sure that if
there's any cross references, straighten those out. But, no, you do not
need to update.
Okay. One of the things I did when I inherited this project
was -- we wanted to go through and try to decide what was changing.
What does the current regulation say and what's the final rule going to
say. What's the main changes? Because, in the interim, there's a
proposed rule, and it had a number of changes in it, proposals in it,
and some of those are no longer there and they've been taken out. But,
I didn't want to dwell on those, because you all don't have the benefit
of a pre-proposed rule meeting, so that really wouldn't seem very
important to you. So, we tried to focus on where the regulations are
now and where they will be if the rule is issued as currently drafted.
So, in terms of paragraph (b) of 50.55a, we just change --
we have to add a reference to the OM code and the address changes; so
just administrative there.
In (b)(1), we talk about Section 3. We're going from the
'89 edition and the '88 addenda, up to the '95 edition and '96 addenda.
There were no limitations in the current regulations on Section 3. And
we're going to -- we're proposing to add five, in terms -- in the
endorsement of the '95 edition of Section 3. And those five have to do
with materials -- and we'll talk more about these specific slides on
these -- materials, well dimensions, seismic design, QA, and inspection
independence. So, those are all -- that's all the limitations
associated with the '95 edition.
DR. POWERS: The staff does not participate in the
development of these rules?
MR. SCARBROUGH: Yes.
DR. POWERS: Oh, standard code --
MR. SCARBROUGH: Right.
DR. POWERS: -- sorry, the ASME standard?
MR. SCARBROUGH: Absolutely.
DR. POWERS: Why do so many limitations show up?
MR. SCARBROUGH: Well, I wouldn't consider so many, in terms
of because it is from '89 all the way up to the '96 addenda. So,
there's a lot of time in there and there's a lot of changes. For
example -- I'll just give you an example for the materials, number one
there. There was significant numbers of printing errors in the '92
edition and what this does is it alerts licensees to that and indicates
they should use a different addenda for that. And that's a type of
thing that came up. It wasn't able to be corrected in the '92 edition,
so this was alerted -- an alert was made in here. Because, what this
does is it's really endorsing all of those editions and addenda, up
through the '95 edition. So, there's a lot of editions and addenda to
look at there. So, you know, there are some, but I wouldn't consider a
significant amount from -- from -- considering how long it's been since
we endorsed one of the codes.
MR. TERAO: Yes. But, I would also like to point out that
the ASME -- that the staff representative on ASME committee, there's
only one person. So, we only have one vote, of course. So, any changes
to the ASME code, the NRC staff representatives may not approve of it,
but that does not stop it from going through.
DR. WALLIS: Now, the naive public might assume that NRC
would be stricter than the ASME, that would require more and not here to
require less.
MR. SCARBROUGH: I would say that when we do look through,
if there's something that concerns us, in terms of some type of
relaxation, you know, I'm sure you would see that. But, there is a
pretty good collegial process, in terms of trying to come up with the
best possible code, before it's issued. I know on the code committees
I'm on, we go round and round, trying to come up with a good consensus
opinion. But, sometimes, it just isn't possible. Sometimes, we just
get to a point where we have to agree to disagree.
DR. BONACA: I have a question. Why does the ASME keep the
editions of the ASME codes, if we seem to believe that we can stay with
the 1995 edition and not go further?
MR. TERAO: Well, first of all, let me answer that. That is
not the ASME's position that we should stay with a specific edition and
addenda; that's the NRC staff's position. And, of course, the ASME is
in the business to develop the codes and standards, and they get the --
it's a voluntary consensus. They get representatives from the industry,
as well as the NRC staff, to participate on those codes and committees.
So, it is -- it's to reflect the latest state of the art or techniques
that are available for either design or inspection or testing.
DR. POWERS: Does ASME decide on when it's going to do a new
edition, based on the calendar or based on the technology?
MR. TERAO: Yes, it's based on calendar. It is now at the
point where they issue an addenda every three years -- I mean, an
edition every three years and an addenda every year.
DR. SHERON: Excuse me, this is Brian Sheron. Mario, could
I just -- I want to just respond to your question. We certainly -- we
don't -- while we say, you know, that -- let me start again. We're not
advocating that we just stop everything at the '95 edition or the '89
edition, okay. We certainly encourage the code to develop new editions,
okay, with improvements in it and the like. We have no objection. And
as I said, we would -- you now, we're trying to actively endorse, on a
timely manner, these new editions, as they come out, because we
recognize that there is some improvements in them, okay.
But, from the standpoint of saying can we justify closing it
on a licensee, as a requirement, you must do this, okay, we feel that we
need to have some sort of a measure, okay, on when we should do that and
when it should be just voluntary. As I said, we tried to use -- we
figured the backfit rule, which is what we use for everything else, you
know, was an appropriate tool, okay. But, we are not saying that the
code development should come to a screeching halt, by no means, okay.
We certainly encourage it and we would encourage licensees to adopt the
latest edition of the code and to use it.
DR. POWERS: We understand -- somebody wrote this rule in
the past that says 120 months, update to the latest edition. Do we
understand why they wrote that rule?
DR. SHERON: I believe, at the time, it was first
promulgated -- the code, at least Section 3 and 11, were in their
infancy stages and there was an anticipation that there were going to be
a lot of changes made, a lot of improvements, which is the case. And,
therefore, the provision was built in to automatically update.
What we're seeing is that the code has reached a level of
maturity and we don't see any quantum leaps in safety, you might say, or
benefits. And that's why we're saying, at this point, we think that
further updating -- requirements for updating would only be voluntary,
okay. But the reason was, is that we saw, at the time, that the
technology was rapidly changing, okay. So, it was written into the
rule, the provision, to allow us to -- you know, to allow the industry
to use that.
DR. POWERS: You saw the early stages of where the rapid
change -- new sections being added, new systems being covered. Now,
you're see a plateauing off and we're wheedling it. Is this an
asymatope approach or is this just a hiatus? The 2003, I see a quantum
change in the whole technology for doing that.
DR. SHERON: And if that's the case, we would probably be
able to justify a safety -- you know, a large safety benefit. I would
also point that the deregulation of the industry may be, to some extent,
driving a large part of this. Remember in the past, when a licensee had
to update their programs, it was because it was an NRC requirement and
that meant they could pass that cost right on to the rate payers, no
questions asked. So, what do they care, okay. Now, that's not the
case. Everything they do, they are challenging us, basically, if
there's a NRC requirement, okay.
DR. POWERS: I've noticed.
DR. SHERON: Right. It's no longer a matter of I can just
pass this cost down to a rate payer, okay. You know, everything now
that costs them money comes right off -- you know, right out of their
margin. So, we have become much more sensitive, now, at NRC, okay, on
what we impose on the industry, because we recognize that we no longer
can just sit there and say do this and do that, recognizing that they
can pass it on to the rate payers. So, it's a whole new -- whole new
world out there, you might say, which is driving a lot of this.
DR. WALLIS: Are there other regulated industries and other
industries that use the ASME code? There must be, because it will not
test for nuclear units. And if they adopt and nuclear somehow is
laggardly in adopting it, that doesn't -- perhaps not too good for
nuclear. How does this compare with other industry?
DR. KRESS: Other regulated industry.
DR. WALLIS: Other regulated -- well, other regulated and
non-regulated. But, are other regulated industries encouraged
voluntarily to adopt the ASME codes or what?
MR. SCARBROUGH: I couldn't answer that.
DR. WALLIS: The NRC seems to often operate in a vacuum, as
if, you know, they make its own decisions, based on its own criteria.
But, an outside worlds is going to make comparisons.
DR. POWERS: If I build a pressure vessel and locate it on a
government reservation, I have to get it as a code vessel. And I'd get
it code stamped against the current edition of the code. Now, I have no
experience doing this with either Section 11 or Section 3. I have with
the sections. And I have that stamped for all time, until that vessel
falls apart. I have a requirement to do period testing on it, but
against that standard against which I got here. I don't ever have to go
look at another code. So, effectively, in the non-clear area, at least
in the area I have an experience with, I never had to update.
Now, if I --
DR. SHACK: But, you only update your inspection and your
ISI and IST. I mean, your construction standard remains the same.
DR. POWERS: But, I don't change my testing standard. I
test against whatever -- what was enforced at the time I built that
vessel.
DR. WALLIS: Is this common practice, do you think?
DR. POWERS: The commonality, I'm not sure of, but I know
what I do.
DR. BONACA: Generally -- oftentimes, changes in the
industry drive changes in standards, because you have additional needs.
So, we are now thinking of license renewal for these plants. There is
aging issues and so on and so forth. Are we expecting to see
contributions from the ASME in modifying inspection programs and things
of that kind, which relate to aging mechanisms? And in that case, have
we thought about that, in saying that we know enough about it and there
isn't sufficient movement now of the ASME editions from one to the next,
that deserve to be considered?
MR. SCARBROUGH: Yes, that's one of the issues that we need
to deal with, as we go through the public comments, and resolve them
regarding 10-year update issues; is what do we do about the life
extension, the plant can go on for a long period of time.
DR. BONACA: Okay.
MR. SCARBROUGH: Let me go on and tell you what we've done
with this rule. For Section 11, we've gone from the '89 edition of --
up t the '95 edition. There were 10 limitations -- there are 10
limitations in the current regulations, regarding Section 11 and the
earlier editions. And for this rule, there would be 12 limitations.
There's three new limitations and one limitation has been deleted,
having to do with containment isolation valves, IST. There's three
modifications that are associated with the Appendix 8 issue, and there's
one voluntary provision to allow use some code cases.
Basically, the changes are where you have some sliding of
the numbering system. So, it's a little awkward, in terms of how the
regulations are numbered. But, basically, provision six had to do with
the metal link or concrete containments; eight was the OM reference,
which were standards back in those days and now it's their own codes.
We had to update that. We deleted the containment isolation, so now
everything slid up numbering-wise. The concrete containments went up
from nine to eight in the list. Similarly for metal containments, they
went from provision ten to nine. So, there was renumbering that took
place with -- which basically, there's no change in the content. It was
just that we renumbered them.
And then we have the new limitations. Once again, we have
the QA, and that has to do with NQA1. There was some class one piping.
There's a limitation associated with some provisions in the code,
regarding exemption of certain welds. We had one division, which was in
there, twelve, and we deleted it. So rather than trying to renumber
things, once again, we just make it reserve and then we'll clean it up
in the next revision of the regulations.
Class three piping in provision 13 is a permissible for code
cases -- excuse me, code cases, for class three piping. Fourteen,
fifteen, and sixteen, and we'll talk more about these, basically, those
are the modifications associated with appendix 8 endorsement, the
expedited implementation. And then 17 is a limitation associated with
the reconciliation of quality requirements and has to do with the
purchasing replacement items.
Okay, these are the changes for Section 11. For the OM
code, this is a brand new code, so we have a new section, paragraph
(b)(3). And there's one limitation on that code. There's one
modification. There's three voluntary provisions. Once again, we have
the quality assurance, NQA1. Then, there will be stroke-time testing.
Then, we have three voluntary provisions, which allows first a code case
OM one to be used, as an alternative to stroke-time testing for MOVs; a
provision for the use of Appendix 2 on check valves for condition
monitoring programs, to replace the current code requirements for
monitoring and testing check valves. And then finally, snubbers, the
use of snubbers allows the use of Subsection ISTD, which provides some
guidance on snubbers, which can be used to meet the Section 11
requirements for ISI, for snubbers.
So, those are -- that's the meat of the changes. Now, there
were some changes back in the F -- paragraphs F and G, which has to do
with implementation schedules, to reflect these updates and the Appendix
8 expedited limitation schedule. But mostly, that was minor, in that
sense. So, there were some changes back there, but these were the
principle changes, in terms of technical.
Okay. I was going to go through a little bit on the
details. And we have some of the folks here, who are the technical
experts in these areas. So, if you have a question about a particular
aspect or particular limitations, just let me know and we'll call on
those individuals to give us some details.
In terms of the construction, Section 3, the rule permits
the use of the 1989 addenda, all the way up through the '96 addenda for
the boiler and pressure vessel code, and with five limitations. We
talked about the '92 addenda that was on materials, because of the
printing errors. There was like 160 errors in the tables in that -- in
the 1992 addition. So, there's a cross reference there that says,
rather than using the '92 edition, use the '92 addenda, which corrects
most of those errors.
There's a limitation regarding the 1989 edition for weld leg
dimensions, because there were conflicts in later addenda. It was a
1989 addenda and later allowed weld dimensions, in some cases, to be
smaller than the pipe thickness. And the staff had concerns about that
and that was the limitation that was placed on that, to go back and use
the '89 edition. There was a limitation on the -- providing the use of
specific articles for seismic design, because of weaknesses and the
technical bases. There's quite a bit of testing that was gong --
occurred to evaluate those -- that information and those articles, and
it was decided that those specific articles were not supported. So,
there's a limitation, in terms of that.
Regarding acceptability of ASME NQA1, what the rules says is
that when you apply the reference to ASME standard NQA1, as part of your
code program, you need to also use the QA provisions of Section 3,
because Section 3 QA provisions are adequate. But, there's a cross
reference in the code to NQA1, and NQA1 has some weaknesses, in terms of
operational details and there's some procurement auditing concerns in
that areas. So, there's a cross reference to make sure that you cover
all the aspects of QA programs; so if there's a cross reference, use
your QA provisions.
And, finally, there's a prohibition for inspection personnel
from reporting directly to the immediate supervisors responsible for the
work inspected, to ensure their independence. So, that's something that
-- that was felt to be it needed to be a limitation. So, those are the
basic limitations on Section 3. So, there was a large number of addenda
and additions that were looked at and that's what came out to be the
limitations.
For ISI, Inservice Inspection, the rule referenced the '95
edition with the '93 addendum of Section 11, with three limitations.
The NQA1, once again, that pops up again. So, now it references back to
the QA provisions of Appendix B. There was a concern, regarding
unacceptable code cases that exempt certain welds from examination in
the 1989 edition -- or later addenda, excuse me. And there's a cross
reference back to the 1989 edition for those class weld piping items.
So, that was a limitation placed on the later addenda and sends them
back to the '89 edition. And then, finally, there's a limitation on --
regarding the use of the owner's QA program. We're replacing the --
purchasing replacement items, to make sure there's full coverage there,
in terms of the QA program. So, that was the limitation associated with
the one, two, and three -- class one, two, and three components.
Okay, now, for Appendix 8, there is an expedition of the
implementation of the performance administration for ultrasonic systems.
There was a concern regarding the quality of the current methods for
qualifying personnel in performing that -- those ultrasonic
examinations. There was a proposal to provide for that expedited
implementation within about a six month or so period, and response to
public comments has been stretched out to be folded in over a three-year
period. So, there was some response there.
Also, since the proposed rule was issued in '97, there's
been a lot of interaction between the NRC staff and the industry's
performance administration initiative, which has been working to
coordinate the use of ultrasonic examination systems and the
qualification of personnel and such. And as a result, there's been
agreement that the licensees can either use Appendix 8, as referenced in
the '96 addenda of Section 1, or they could use Appendix 8, as
implemented by PDI. So, that provision is in there.
Unfortunately, it makes it a little wordy, because there
wasn't a document that the rule could reference directly and just say go
out and use PDI document such and such. There wasn't a good way to do
that. So, as a result, there are several pages of description of what
the PDI initiative is and what the requirements are. So, that's one
reason why that rule is a little wordy in that area. But, basically,
the bottom line is I should use Appendix 8, as in the code, or Appendix
8, as implemented by PDI.
Now, there were three modifications associated with that.
And the first one was the personnel qualification for eight hours of
recent hands-on training, and that's been adjusted to match the PDI. In
the initial proposal that went out for public comment, that was a
different requirement, a much more extensive requirement. But after
some discussions and interactions with PDI, it was decided to follow the
PDI approach, to give that eight hours of recent hands-on training.
The second limitation is basically having to do with the
description of the PDI program and what are the requirements for cracks
and fabrication flaws. And finally, there are some additional
provisions on single sided examinations, in terms of comparison to
two-sided examinations. So, there were some provisions there that was
felt to be needed. So, those are the modifications on the expedited
implementation of Appendix 8.
DR. SHACK: What would the code have permitted for the
implementation? You know, is it longer than the three-year period?
MR. SCARBROUGH: With the code, it would have been the next
10-year update.
DR. SHACK: Oh.
MR. SCARBROUGH: Okay. So then we have some voluntary
permissibles, whatever you want to call them, in terms of certain things
that are allowed. And the final rule allows licensees to meet
Subsection IWE on metal containment components or IWL on concrete
containment components of Section 11, by using either the '92 edition --
'92 addenda, or the '95 edition, '96 addenda. Previously -- currently
in the code right now -- in the regulations right now is a reference to
the '92 edition. And what this adds in the '95 edition. So, now, they
have an option to use either one.
The rule, also, allows licensees to use two-code cases,
N-513 and N-523-1, related to the temporary acceptance of flaws in class
three piping, which might be detected during operation. It gives them a
chance to evaluate those flaws and possibly operation until the next
outage to deal with those. And there's a couple of limitations on the
use of the 513 code, having to do with safety factors and scope. But,
mostly, for the most part, it's a pretty straightforward endorsement of
those two code cases.
Okay. So, that's all for ISI.
DR. SHACK: What do they do for class three piping before
the code cases, that was a case-by-case basis?
MR. SCARBROUGH: The class three piping person.
MR. STROSNIDER: This is Jack Strosnider, director of
Division of Engineering. We've been spending about half a man year
every year -- or half an FTE, as we call it, looking at plant specific
temporary repairs, as we call them. And there was some guidance that
was put out in a generic letter, with what constituted -- you know, ways
for analyzing and justifying those sort of temporary conditions. So,
this basically would codify that approach and will get us out of the
loop. Licensees will be able to do it on their own.
MR. SCARBROUGH: Okay. For Inservice testing, IST, the
final rule will incorporate by reference to '95 edition, with '96
addenda of the ASME OM code, for class one, two, and three pumps and
valves. And that's the first time we've endorsed in the regulations OM
code. And that's good that we're doing that, because all the
responsibility is now transferred from the Boiler and Pressure Vessel
Code into the OM code, and all the work now is processing through the
OMB code committee. So, this is a good thing to do, to make sure we
have the proper reference in the regulations.
There's one clarification, one limitation, one modification.
In paragraph (f) of 50.55a, we clarify that the IC program is -- the
scope is narrow than -- narrow than implied for earlier license plants.
There was a concern that the earlier license plants were being unfairly
penalized for more recently constructed plants, and the wording has gone
around and around a little bit, in terms of trying to make sure that
really -- the purpose really was achieved, in terms of not penalizing
those earlier plants. But, we think we've got the words down now. We
got some good comments from the public on that and we think we've got
that taken care of now.
There's a limitation regarding the -- limitation of the
code, regarding NQA1, in terms of quality assurance provisions, once
again, because of weaknesses in NQA1. There's a modification regarding
the supplementing of MOV stroke-time testing with design based
capability programs, and that's been -- that's been approved, in terms
of the language. The language that went out for the post rule was a
little cumbersome and we think we've straightened that language out a
little bit and make it more directly related to the design based
capability programs the licensees developed. And the rule deletes the
current modification in the regulations on inservice testing of
containment isolation valves. So, we feel that's adequately covered by
Appendix J, and it doesn't need to be repeated through 50.55a. So,
that's been taken out.
The final rule permits licensees to use the ASME code case
OM one, which is alternative rules for stroke-time testing, providing
for diagnostics and exercising diagnostics on a much longer interval and
then exercising every outage. We have two modifications -- one
modification, one clarification. But, one modification has to do with
the evaluation of test data over the first five years. The code case
allows licensees to go 10 years on their diagnostic testing. And what
we've asked the utilities to do, implement this, is to evaluate the
first five years, before they go long distances out. And then the
clarification had to do with the evaluation.
There's a provision in OM one, which says that licensee
should evaluate the potential risk involved in extending quarterly
exercise and quarterly stroke-time testing out to every outage basis.
And what the clarification says, to amplify that consideration of risk
for that provision, we say -- what we think that means is to consider
the potential increase in core damage frequency and risk, in extending
those exercise intervals from quarter to every outage, those higher risk
MOVs.
We, also, permit in the rule Appendix 2, check out condition
monitoring in lieu of the exercising requirements in Subsection IST of
the OM code. And we have three modifications: one involving
bidirectional testing, make sure that taken care of in the Commission
monitoring program; two, that the initial interval is -- not exceeds two
cycles or three years, with extension not to exceed one cycle per
extension of ten years. So, anyway -- so what that basically says is --
it's a step-wise approach. You work your way up by stepping up on your
intervals. You don't go out very quickly all at one time. You walk
your way out, the step by step approach. And, also, that if you
discontinue the program, you have to go back and pick up the whole --
pick up your ISTC requirements again for checkoffs. So, we have that
modification in there.
DR. SHACK: You had some additional testing requirements by
general letter from MOV, right? Does this subsume all that now?
MR. SCARBROUGH: That folds in the weaknesses. This will
resolve the weaknesses in the code that we saw back when generic letter
89-10 was first developed. It now says, in addition to stroke-time
testing, you have to have a program, which confirms, on a regular basis,
your design base capability.
DR. POWERS: Okay. So, this, in fact, obviates the need for
the generic letter. That's really be incorporated into this?
MR. SCARBROUGH: Right, right. This is moving us right into
the modification onto the code, itself.
And then the last permissible there is the use of subsection
ISD of the OMC code. So, there's some testing provisions in IST's CD,
which is very helpful for leaving your ISI, in terms of inspection
requirements, of section 11. It allows you to apply that information
back to meeting those section 11 requirements.
So, that, in summary, is -- extended the changes. It's just
hard to walk through, because there are so many areas that were -- that
we're dealing with: section three, section 11, and OMM. But,
basically, there are not a lot of changes to the -- this massive amount
of code that's been updated. We end up with 65 different public
commenters, with over 560 comments. And Wally Morris, in the Office of
Research, worked through this for a long period of time, pulled them all
together, and allowed them to be responded to by each of the core
groups. And this is a list of the various commenters that sent in
comments on the rule change, NEI, ASME, Epry, a number of utilities and
individuals. We, had a pretty broad cross section of comments.
What I want to do is kind of give you a flavor for the
comments, because the comments package, itself, is 260 pages, in terms
of the comments and responses. So, it's so extensive, it's -- it just
takes a long time just to read it. But, we tried to focus on what were
the major comments that were received and how we dealt with them. The
first comment was received is a general comment that NRC should update
the regulations more frequently and we agree. And we're trying to
achieve that.
A second comment that we received was -- had to do with a
proposed limitation on the use of engineering judgment. There was
language in the forward of the code that concerned the staff and there
was a proposed limitation regarding the use of engineering judgment, in
the proposed rule that went out in '97. Well, in response to public
comments and the description of the public comments and the resolution
of those comments, it was decided that that specific limitation was not
needed. So that was taken -- that's been taken out.
DR. WALLIS: What does engineering judgment mean?
MR. SCARBROUGH: Well, there was some language in the
forward, which said that these -- this -- I'm paraphrasing, that the
provisions of the code could be adjusted or accounted -- revised, in
accordance with your engineering judgment. It was written a little
general and there was some concern that that might be taken a little too
far; that the code is the code and there are these requirements. And so
with the description that -- of course, any time you apply anything in
the power plant, you're going to be using your own judgment, no matter
whether it's motor operated valves or check valves or ISI or whatever.
And so, in response to that, there was a discussion in -- we
put in the statement consideration, and it's more detailed in the --
detailed in the response of the comments of -- that, yes, of course, you
need to use engineering judgment, but just don't go too far, in terms of
making adjustments to the code, in terms of when you're implying that,
that you need to make sure that you follow the code.
DR. WALLIS: You used the ACRS meeting, when all other
explanations fail.
[Laughter.]
DR. WALLIS: I'm really wary of it appearing -- you
appearing to endorse it. It can cover a multitude of sins.
MR. SCARBROUGH: And that's why there's a lot of discussion.
I think the public comments goes on for 20 pages of just our response to
that issue and there is some more discussion in the SOC, itself. So, it
was decided that there was a significant amount of explanation of what
the NRC expected, that we are comfortable with it.
MR. HERMANN: Yeah, I was just going -- Bob Hermann, staff.
We've put some inspection guidance out, in terms of the appropriate way
to use -- or looking at engineering judgment, in terms of using it as
how to apply things, rather than engineering judgment to come up with
let's say what we would call new requirements, in lieu of those that
might get there by interpretation.
MR. SCARBROUGH: So that was one area that we responded to
public comments. There was a -- regarding IST program scope, there was
concern that our attempt to clarify the IC program scope just went the
other way, and expanded it. And when we read it, we could see how
people could read it that way. So, that was revised, to make sure that
were not penalizing those earlier license plants, because that was the
goal. So that -- I think that's been achieved.
There was comments that this proposed schedule for
implementation of Appendix 8 was too aggressive and also there was
comments that we should try to adopt the PDI program. And we've
accomplished that, we think, by allowing a phased in approach over a
three-year period for Appendix 8, and also allows an alternative for the
PDI program. So, we think we've been responsive to those comments, as
well.
There were comments that we received on the training
requirements that were in the proposed rule regarding the qualification
of non-destructive examination personnel through Appendix 8 and that
those requirements were excessive, and there was quite a bit, it was
like a 40 hour timeframe annually.
The NRC staff went back, looked at that, agreed with those
comments and decided that the PDI position of eight hours of actual
recent hands-on training was probably more helpful in terms of making
sure licensees were able to deal with having qualified non-destructive
examination personnel, so we made a change in that area.
There was a proposed requirement for HPSI Class 1 piping
examination. There is a sort of missing portion of the code which --
where Class 2 piping is dealt with, but Class 1 piping wasn't for HPSI,
and there was a proposed requirement for expedited implementation for --
in terms of the HPSI piping examination. However, there has been some
industry initiatives in that area to deal with question and resolve it,
so the staff is planning to defer regulatory action in that area and
allow that industry initiative to address the issue.
There was a proposed limitation also in the rule on Class 2
piping or Class 2 components which were subject to examination contained
in ISI plans and such. In response to public comments, it was decided
that there were suitable controls in place through the ISI program plan
that we didn't to call that out in the regs themselves, so that was
deleted.
DR. SHACK: One of the things you didn't mention, and I
haven't looked at it myself, is the portion of the code that deals with
steam generator tube repairs, sleeving repairs. In the past you have
approved each of those sort of on a case by case basis, right, somebody
devises a repair and you analyze that.
MR. SCARBROUGH: Right.
DR. SHACK: You will now be able to do that by the code
without an independent NRC analysis?
MR. HERMANN: This is Bob Hermann of the staff. I am on the
Repairs and Replacement Committee. There have been several rules that
have been written by the code recently in terms of steam generator
repairs, some sleeving, some for sleeving, some for mechanical plugging,
some for welded plugging. Those rules generally have gone in place.
They probably address some of the issues that are related to
implementing those repairs, but in some cases there have been things
that have been beyond that.
The sleeving case I think you have had discussed over here
before, the electrosleeving, and, certainly, things like severe
accidents were not part of the code action. So there have been issues
outside of those that have gone through the code.
I think the rules are there to put a good repair in place,
but there may be other regulatory questions that may be beyond the
things that went into the code.
DR. SHACK: But would they now be able to implement the
repair technique without an independent NRC evaluation?
MR. HERMANN: I don't think so, and I think it is probably
because of the tech specs. The tech specs basically -- I think
basically only talk about plugging as an acceptable action for repairing
steam generator tubes. So, although there is rules in the code for how
to do it, you may have a conflict between what is in the code and what
is in the tech specs, and the tech specs take precedence.
DR. SHACK: The specs win.
MR. SCARBROUGH: Mostly it is just a discussion of caution
in the SOC about being careful in terms of following, they estimate --
stating that requirements were generally acceptable, but just to keep
them in perspective.
Of course we didn't respond to every public comment in terms
of changing the proposed rule into the final form. We had a comment
that the rule represents a backfit and the discussions of the 120 month
update. And the staff, through its position, has had a historical
position that the 120 month update is not a backfit. However, we are
evaluating the need for continued periodic updating and the accelerated
implementation of Appendix 8 was justified as a compliance backfit under
51.09.
There was a number of comments in terms of the need for
clarification or revision of the rule and we responded to that. We did
clarify several aspects and revise several aspects. For example, we
deleted a proposed modification on the length of time between
construction and docket dates deleted. The ASME commented that there
was some work in that area for a code revision and it was decided that
was probably the better avenue to deal with that issue rather than
through the rule itself, so that was taken out.
We have prepared a detailed backfit analysis as one of the
attachments to the package. In terms -- in the first, the section 3 is
voluntary for licensees to update between the '89 addenda and the '96
addenda. It was determined that a backfit analysis was not required for
the ten-year update issue. And the position -- the staff's position on
that has been based on three basic points.
One is that section 3 is voluntary. It's updated only for
new construction codes, new construction. Two, utilities understand
that the update requirement is part of their license when their license
is granted. That's part of the requirement. So that historically has
been understood by licensees. And, third, that the ASME code is a
national consensus standard, and that the revision process includes a
general examination of costs and benefits. So those were the three
prongs that the staff has based its view on on the ten-year update
issue.
DR. SHACK: Yes, it is curious that, you know, as Brian
mentioned, there seems to be an industry position against the update,
but of course, I mean, the ASME code, you know, there's no ASME coders,
you know, this is all done by industry people basically, you know,
except for the lone NRC representative. There's not even a Union of
Concerned Scientists representative, you know. So there's an industry
on the one hand that is producing these changes, and someone else is
objecting to the changes.
MR. SCARBROUGH: There's a significant difference of opinion
from individual people who work in that field, you know, the utilities
themselves. It's quite a broad spectrum of views on what to do on that
particular issue of the ten-year update which we're going to have to try
to muddle through in the next project that we're working on.
MR. WESSMAN: If I may interrupt for a minute, Tom, this is
Dick Wessman from the staff, sometimes the word "industry" can be
treated, you know, far more broadly or perhaps more narrowly, and I
think it's important to recognize that the consensus committees on the
code have a very broad balance of interest. And when we say industry
and NRC, yes, there's one NRC. Industry may be utilities, it is
consultants, it is vendors and suppliers, it is State insurance
representatives. So there is quite a broad perspective of industry
that's part of that overall consensus process. And that's one of the
values of that process.
MR. HERMANN: But I think it's probably fair to mention, if
you started counting heads on section 11, what Bill said is absolutely
right, if you counted the beans, the majority votes would be people that
are, quote, utility reps.
MR. SCARBROUGH: Okay. And then on the -- it was determined
that the administrative change go from the O&M standards, the O&M code,
was not a backfit. For the Appendix 8, expedited implementation, that
was determined to be necessary to bring licensees into compliance with
GDC 14 of Appendix 8 of Part 50, and then criteria 2 and 16 of Appendix
B under the QA program. And so there was a justification for that
specifically in the rule package itself too.
DR. SHACK: What does GDC 14, Appendix A say?
MR. SCARBROUGH: That says that licensees have to have a
reliable means for testing -- several other things -- but testing to
limit abnormal leakage and the possibility for abnormal leakage or gross
failure. And so there's concern there that testing wasn't adequate.
Okay. Well, in conclusion, the final rule incorporates the
'95 edition with the '96 addenda of the boiler and pressure vessel
codes, sections 3 and 11, and ASME O&M code. It endorses most of the
provisions. I think, you know, there are some -- volume-wise you can
see some changes there. But for the most part, five or so for section
3, three new ones for section 11, and really only two provisions for O&M
codes. Other things in there are permissibles or voluntary aspects to
endorsing code cases and such.
It does require expedited implementation of Appendix 8, as
described in the code itself, or through PDIs. So we think we've given
some options there to allow licensees to implement what's best for them.
It's been decided that the rule does not substantially
change the character of the codes and does not represent a Government
unique standard as defined by the National Technology Transfer
Advancement Act of 1995.
And, finally, we think the rule provides improvement in
construction and service inspection and service testing of nuclear
powerplant components.
Where we are with the package -- and I do appreciate ACRS
listening to us and letting us brief you on a package you don't have in
your hands yet -- the draft that we sent to you is very, very similar to
what's currently in the package. We've tweaked it a little bit in terms
of trying to take out some of the rule language that wasn't changed so
you don't have so much to read in the back in terms of the actual rule.
We put a little asterisk in there. But for the most part, it's
basically the same as what you have.
Currently we have received OGC concurrence on the package.
We should be receiving CIO information office concurrence here in the
next day or two. I just talked to them today. The financial office is
looking at it. They've checked with our financial people, and that
should be coming through pretty soon. The administrative office is
looking at it for how the words should fit into the Federal Register,
making sure that our current method of saying things is consistent with
how they like to say things in the Federal Register. So they're working
on that. And the Office of Research, I've talked to some of their
people, and they haven't seen anything in it that causes them major
concerns.
So currently we hope with -- the packages have been updated
to reflect OGC comments and our own internal NRR folks who deal with
rule changes. As soon as I get these other -- whatever comments these
other offices have and their concurrence, we'll finalize it, so we hope
to have the package ready to go early next week, and to have it signed
out and sent over to you -- and it is, you know, that thick -- sometime
next week. So that's the plan right now. But basically that's the
rule, and we'll be happy to answer any specific questions you have, and
we have some folks here that can answer questions, if you have any more.
DR. SHACK: What's been your track record in the past? I
mean, how often have you actually managed to update, incorporate
reference -- are you behind your historical record or, you know, you're
on track?
MR. TERAO: If I can answer that, Bill, I did some research
in looking at the Federal Registers going back to 1971, when 50.55a was
first put into the regulations, and it's interesting, because from about
1971 to about 1986, we issued updates of 50.55a endorsing or
incorporating by reference the next edition addenda about every year,
sometimes twice a year.
But around 1986 is when the packages got a lot more
complicated. And some of the things that happened around that time is
when we split paragraph G into F and G. So there were a lot more
administrative type of issues that came up as well as dealing with CRGR
and I think more obstacles for the staff to overcome. And in those
days, say before, from '71 to eighties, there are no public comments.
Zero. So it was very easy to -- or relatively easy to get a package
out. And today we have over 500 comments.
So of course the last rule change was in 1992, and that was
when we endorsed IWE, IWL for containment inspection. But before that,
of course, the 1989 rule came out. I think that was 1992 or 1994.
So it's been quite a while since our last update. And this
package has gone through literally three full revisions since it was
first proposed for issuance back in the 1994 time frame. So what you
see here is not just a development of a package from when it was
initially prepared about six years ago. This is about the third
reincarnation, a complete new package.
So yes, it's gotten a lot more complicated. We're hoping
that in the future it won't be quite as complicated as this one, but
we're hoping to of course get the rulemaking out a lot quicker in the
future.
DR. BONACA: I had another question regarding the ASME
position. If I remember, they have written, they are on record, right,
with the NRC that they do not agree with this?
MR. SCARBROUGH: Not with this package.
DR. BONACA: No, I'm talking about with this change, rule.
MR. SCARBROUGH: Well, they disagree with the ten-year
update.
DR. BONACA: Right.
MR. SCARBROUGH: But this does not change that at all. This
maintains that as always.
MR. DUDLEY: There is a discussion between the staff and
ASME -- I guess -- yes, between the staff and ASME on what is it, 1994
addendum to the code.
MR. TERAO: Oh, you're right, there are some disagreements
between ASME code and NRC on some of the positions, of course, or
limitations that the NRC staff has imposed on the use of some of the
addenda such as the seismic design, and that's a major issue. I
think -- I'm not sure if the NRC staff has briefed the ACRS --
DR. SHACK: No. I mean, that's been an ongoing
discussion --
MR. TERAO: Right.
DR. SHACK: For several years now. We've had subcommittee
meetings on that. I mean, that obviously is a major sort of technical
difference between the code and the staff.
MR. TERAO: But aside from that, I think the overall package
as far as the NRC staff going forward and endorsing the 1995 edition of
the ASME codes up to and including the 1996 addenda, there's no
disagreement there.
DR. BONACA: No, I was talking about not requiring the
ten-year update.
MR. SCARBROUGH: They've sent a letter in on that.
DR. BONACA: They disagree.
MR. SCARBROUGH: Yes, they disagree. Right.
DR. BONACA: That's what I was referring to.
What's your opinion on that letter, thoughts?
MR. SCARBROUGH: I haven't started looking at it because I
really wanted to focus on getting this package out, you know, on its
way, and what we are doing right now with all those comments, we have
like 26 or so comment letters. All the comments are being collated and
categorized. And over the next few weeks, we'll be reading them
carefully and working up responses to them. So that's the plan right
now. But we really haven't got to the point now where we could say, you
know, what our position would be on those.
DR. BONACA: Because I think you've made a business case
for, you know, eliminating the requirement, but I think the letter from
the ASME makes some technical case that would be valuable for us to look
at.
DR. SHACK: Well, I mean, we will be seeing the 120-month
update again.
MR. SCARBROUGH: Absolutely. We're on your calendar for
September.
MR. HERMANN: This is Bob Hermann of staff. I think Brian
made it clear that that's a separate issue from where we stand right
now. It just might be worth mentioning there was a public stakeholders'
meeting where everybody's opinions to update or not update got taken in
as part of the stakeholders' meeting, and I'm sure that as part of the
package that comes in here, you'll hear a summary of what came out of
the stakeholders' meeting.
DR. BONACA: Okay. Thank you.
DR. SHACK: Are there any more questions? Curt, are you
going to say something about the code? Gerry?
[No response.]
DR. KRESS: Well, we thank the staff for this very
interesting discussion and at this time --
MR. EISENBERG: Tom. Dr. Kress.
DR. KRESS: Yes.
MR. EISENBERG: I would like to --
DR. KRESS: Okay. Okay.
MR. EISENBERG: I wasn't planning to say anything. I am
Gerry Eisenberg from ASME, and I just wanted to make the statement that
we are quite pleased that this rule is going forward in its present
state, despite any differences we might have had with the particular
limitations. But over on the overall, it is a big step forward. It has
been nine years in the making.
DR. KRESS: Thank you. And we think that is it. Thank you
very much. We look forward to hearing the discussion on the 120 days.
At this time on the agenda we are schedule to have a report
from the chairman of the subcommittee meeting that we had Tuesday. The
chairman of that subcommittee is not here, that was George Apostolakis.
The co-chairman of the Joint Subcommittee is here, that is me, and I
guess that would leave me to provide a summary of this report.
Now, the interesting thing about this is this was a Joint
Subcommittee of the PRA and Reliability and the Regulatory Policies and
Practices. It turns out that everybody on the committee was there at
the Joint Subcommittee meeting except Bill Shack. So the question is,
do I need to make a summary of a Tuesday subcommittee meeting for the
benefit of Bill Shack or not? Or can you just read --
DR. SHACK: Did I miss the airplane? I have the minutes, I
will read them.
DR. KRESS: You just read the minutes. I think that would
be appropriate because I really can't, you know, since George is not
here, we could probably use this time for -- well, that is another
problem. We could move on to the next item.
MR. BARTON: Which is the break.
DR. KRESS: Well, --
DR. WALLIS: Well, I have a question for you, Mr. Chairman.
It says representatives of the NRC staff will provide their views. Are
there any NRC staff waiting in the wings we will cut off if we leave
this item?
DR. KRESS: Oh, that is a good question.
MR. BARTON: I don't think so.
DR. KRESS: No?
DR. WALLIS: Well, you see, they are not expected to be here
till 2:30.
MR. BARTON: They are not here to get their wings cut.
MR. REED: This is Tim Reed from NRR, and the only comment I
would like to make with regard to our briefing for the ACRS Subcommittee
is we certainly appreciated the ACRS's input and I think we understand
that we need to better articulate our objectives and what we are doing
risk-informing Part 50 and to have been criteria defined, and we heard
that loud and clear.
DR. KRESS: I think that was the major message.
MR. REED: Yes.
DR. KRESS: So, we appreciate that. We certainly appreciate
having this early kind of discussion with the staff on things like that.
It was very beneficial to us.
DR. WALLIS: Now we have your statement on the public
record, we can hold you to it.
MR. REED: I knew you were going to hold us to it anyway.
DR. KRESS: Well, I think I will declare a break at this
time and let's make it for 20 minutes and be back at a quarter till
3:00, and at that time we will move on to the next item on the agenda,
which was Graham Wallis'. And we will start that way 15 minutes early.
I think that is within the uncertainties of the schedule.
DR. WALLIS: If we start it without our esteemed chairman,
we might make some progress.
[Laughter.]
DR. UHRIG: Do you want that off the record?
DR. POWERS: Well, the feeling was that our esteemed
chairman would be back by then. If he is not, we can discuss whether to
start without him or not. I am perfectly willing to start without him.
DR. SHACK: Well, we might want to go to John's letter since
he is about to turn into a pumpkin.
DR. KRESS: We might go through the letters first. So we
will --
DR. SEALE: Yes, I would point out that the next thing on
the agenda after that is a break for the preparation of reports and we
might just want to --
DR. KRESS: We might to do that now.
DR. WALLIS: Let's do that now.
DR. SEALE: We will do that now and do John's letter.
DR. KRESS: Why don't we break until 3:00 then.
DR. SEALE: All right. And then let's do John's letter.
DR. KRESS: And then let's come back and do John's letter at
that time.
DR. SEALE: Yes.
DR. WALLIS: Maybe we can avoid some of this later full
writing.
DR. KRESS: That's a very good thought. Will that help John
if we break now?
MR. BARTON: Yes, because I have got two letters I have got
to at least read through first reading before I leave. So let's break.
DR. KRESS: Would you rather break for 10 minutes and then
do your letter?
MR. BARTON: How about breaking until a quarter of?
DR. KRESS: Let's do that. And then we will do your letter.
All right. So I declare a recess until a quarter of.
[Whereupon, at 2:28 p.m., the open portion of the meeting
was recessed, to reconvene at 8:30 a.m., Friday, July 16, 1999.]
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