ML20057A500
| ML20057A500 | |
| Person / Time | |
|---|---|
| Issue date: | 09/10/1993 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1975, NUDOCS 9309140307 | |
| Download: ML20057A500 (130) | |
Text
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FFICIAL TRANSCRIPT OF PROCEEDINGS
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Agency:
Nuclear Regulatory Commission l
Advisory Committee on Reactor Safeguards l
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401st ACas Meeting l
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Docket No.
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LOCATION:
Bethesda, Maryland i
I ec DATE:
Friday, September 10, 1993 PAGES:
147 - 252 1
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PUBLIC NOTICE BY THE k
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l
I DATE:
September 10, 1993 O
The contents of this transcript of the procecdings c
of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards, (date)
Sepenwher 10, 1993
, as Reported herein, are a record of the discussions recorded at the meeting held on the above i
date.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION l
3 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
6 401st ACRS MEETING l
7 i
8 l
l 9
l l
l 10 11 Nuclear Regulatory Commission 12 Conference Room P-110 1
13 7920 Norfolk Avenue 14 Bethesda, Maryland 15 l
16 Friday, September 10, 1993 17 l
18 The Committee met, pursuant to notice, at 8:30 19 a.m.,
E. WILKINS, Chairman, presiding.
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PARTICIPANTS:
2 E. WILKINS, ACRS CHAIRMAN 3
J.
CARROLL, ACRS VICE-CHAIRMAN 4
C.
MICHELSON, ACRS MEMBER 5
C.
WYLIE, ACRS MEMBER 6
H.
LEWIS, ACRS MEMBER 7
I.
CATTON, ACRS MEMBER 8
T.
KRESS, ACRS MEMBER 9
W.
LINDBLAD, ACRS MEMBER 10 P. DAVIS, ACRS MEMBER 11 R.
SEALE, ACRS MEMBER 12 W.
SHACK, ACRS MEMBER 13 J.
LARKINS, EXECUTIVE DIRECTOR OF THE ACRS 14 G. GRIMES, NRC/NRR
- O 15 O.
CHOPRA, NRC/NRR 16 G.
ZECH, NRC/NRR 17 F.
ROSA, NRC/NRR 18 R.
CORREIA, NRC/NRR 19 N.
CAMPBELL, NRC/NRR 20 E. WEISS, NRC/NRR 21 W.
HALL, NUFA' RC 22 A.
SERKIZ, NRC/RES 23 A. HISER, NRC/RES 24 L.
SHAO, NRC/RES 25 C. SERPAN, NRC/RES O
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PARTICIPANTS [ continued]:
2 A. TABOADA, NRC/RES t
3 K. WICHMAN, NRC/NRR 4
5 6
7 8
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1.
10 1'
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12 13 14 i
15 l
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21 22 23 1
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24 25 4
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PROCEEDINGS l
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[8': 3 0 - a. m. ]
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MR. WILKINS:
The meeting will now come to order.
i 4
This is the second day of the 401st meeting of the Advisory 5
Committee on Reactor Safeguards.
During today's meeting, 6
the committee will discuss and/or hear reports on the 1
7 following:
8
- 1) Proposed generic letter on removal of certain 9
technical specification requirements for emergency diesel 1
i l
10 generators; 2) Proposed rulemaking on the fracture toughness 11 requirements and thermal annealing for reactor pressure l
12 vessels; 3) Reconciliation of ACRS comments and 13 recommendations; 4) Report of the Planning and Procedures i
i 14 Subcommittee; 5) Preparation of ACRS reports.
I I
15 Portions of today's meeting may be closed to 1
16 discuss organizational and personnel matters that relate i
17 solely to the internal personnel rules and practices.of this 18 Advisory Committee and matters the release of'which'would 19 represent a clearly unwarranted invasion of personal 20 privacy.
21 This meeting is being conducted in accordance with 22 the provisions of the Federal Advisory Committee Act.
23 Mr. Doug Coe is the designated Federal official 24 for the initial portion of the meeting.
25 We have received no written statements or requests 1
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151-1 for time to make oral statements from members of-the public 2
regarding today's sessions.
A transcript of portions of-the 1
3 meeting is being kept and it is requested that each speaker
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use one of the microphones, identify.himself or herself and f
5 speak with sufficient clarity and volume so that he or she l
6 can be readily heard.
I 7
I have one or two miscellaneous comments.
8 I think you are all aware that the Research Office 9
is holding a workshop on digital computers on Monday and
]
10 Tuesday.
Just as a matter of general interest, how many of
)
l 11 you are planning to attend that?
)
12
[Show of hands.]
13 ME. WILKINS:
All right.
I see four hands.
I am I
14 on the program first thing Monday morning.
I have a class 15 in Atlanta at 3:00 which I will meet and I have to decide 16 whether I turn arcund and come back for Tuesday..
If there 17 are four of you there, I think it really isn't necessary for 18 me to subject my body to that strain.
19 MR. LEWIS:
It is necessary.
How can we operate 20 without leadership?
21 MR. WILKINS:
The answer is very simple.
I will 22 delegate the leadership.
23
[ Laughter.)
24 MR. WILKINS:
Standard MIT, Sloan School of' 1
25 Business response, if I may say so.
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1 As a matter of fact, let me just go ahead and do j
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2 it.
Bill, you are a member of the Planning and Procedures 3
SubcDmmittee, and so Bill will be --
4 MR. LINDBLAD:
So I have to go to all the f
5 sessions, you are saying?
l 6
MR., WILKINS:
Well, in particular the panel i
7 discussion on Tuesday afternoon, which is sort of the wrap-l 8
up, the wrap-up session.
It is physically possible.
l
}
9 schedule-wise.
Airline schedule-wise, it's possible for me j
i 10 to get back for that, but I would prefer.not to fly all the j
l 11 way back here for two hours and then go back home again that' 12 night.
13 In addition, in connection with that workshop, 14 Doug Coe advises me that members can obtain copies of the.
O I
l 15 software standards.
That is IEC-880 -- I don't know the
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t 16 title of these things, but this particular one and the next 17 one have been referred to several times -- and IEEE/ ANSI l
18 7432. If any of you would like to take a look at those i
19 things, you can get copies from Doug.
20 MR. MICHELSON:
Do you mean you have. copies now?
i 21 MR. COE:
Yes, up in my office.
22 MR. LEWIS:
Yes.
I would like to review it.
23 MR. WILKINS:
Okay.
t 24 You have received a copy of the program for the 25 European meeting.
Among other things, the question that was ANN RILEY & ASSOCIATES, LTD.
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raised yesterday about how long you should talk and how long l
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2 you should allow for discussion is explicitly answered on 3
the first page of this:
20 minutes and 20 minutes.
I f
4 assume that the chairman of each session will enforce the j
i 5
40-minute total even though he may not enforce the 20/20 6
split.
7 Do we have any additional information on that?
l i'
B MR. LARKINS:
It is my understanding there is some 9
flexibility in that, but roughly they would like to keep to i'
10 that schedule.
11 MR. WILKINS:
Yes.
The program doesn't give the 12 specific minute and hour at which each presentation is to
]
i 13 start and doesn't indicate how long the coffee break is, J
14 things of that sort.
So the chairman of the session will O
l 15 have some flexibility, but not an awful lot.
16 MR. CARROLL:
The only difficulty is I don't see 17 session chairman.
18 MR. WILKINS:
And there is no evidence of who the 19 session chairmen are.
If I were to hazard a guess --
20 MR. LEWIS:
If one does arithmetic, Ernest, one 21 finds there are three and a half hours allowed for four 40-22 minute talkF, plus a Coffee break.
23 MR. WILKINS:
Yes.
1 24 MR. LEWIS:
With a calculator you can determine 25 the length of the coffee break.
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MR. WILKINS:
Except that there is some slack.
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am absolutely certain that these characters have built some l
3 slack into the program.
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4 MR. LEWIS:
I am well aware of that, and I am l
-i 5
putting the slack into the coffee break.
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MR. WILKINS:
The coffee break.
Fair enough.
I i
l 7
Is there anything else any of the rest of you j
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8 would like to say before we get started this morning?
I 9
[No response.]
l 10 MR. WILKINS:
All right.
Then we will proceed to J
l 11 Agenda Item 10, proposed generic letter on removal of j
12 certain technical specification requirements for emergency 13 diesel generators, and J.
Carroll is,the cognizant 14 subcommittee chairman.
O 15 MR. CARROLL:
Okay.
Well, this is a continuation 16 of the saga of the diesel generator trigger values, I guess, 17 that we have been involved with these many years.
18 The background information on this is in Tab 10 19 and when we last left the subject, the staff had put the 20 famous footnote in the Reg Guide in an attempt to make clear 21 that trigger values really didn't ensure particular levels 22 of diesel generator start reliability.
23 Now we come to an initiative that I guess started 24 with the Commission, didn't it, where we are going to change 25 the present tech spec testing requirements and move these ANN RILEY & ASSOCIATES, LTD.
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over into the maintenance rule, and you will hear how they l
2 propose to do that.
3 I guess I must say that in reading this generic 4
letter, I came away quite confused as to exactly what this 5
was doing and how it was doing it.
So, I hope I will be 6
enlightened.
But I didn't find it very clearly written.
7 I am not sure how NUMARC and licensees are going 8
to find it.
I guess it has gone out for public comment at l
9 this point in time.
I would also point out that I 10 understand it has been through its CRGR review.
l i
11 So, with those introductory remarks, I will turn l
l 12 it over to the staff.
Chris, are you going to lead off?
l t
13 MR. GRIMES:
Good morning.
My name is Chris.
I 14 Grimes.
I am Chief of the Technical Specifications Branch.
j O
15 I hope that today that we can convince you that the saga of l
16 trigger values has died a final death, and that the action 17 that the staff is proposing to take is consistent, actually, f
i 18 with the initiatives the staff developed as a part of i
19 options to try and resolve generic safety issue, B-56, i
t 20 diesel reliability.
l i
21 The presentation is going to be made by Om Chopra 22 of the Electrical Engineering Branch.
We also have. Gary 23 Zech, the Chief of Performance and Quality Evaluation i
24 Branch, and Rich Correia of his staff here today to respond 25 to questions concerning the staff's expectations and intent JJM RILEY & ASSOCIATES, LTD.
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regarding implementation of the guidance for the maintenance
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rule.
3 The only other comment that I would like to make j
4 by way of introduction is that the action that the staff is i
5 proposing in the generic letter, which was reviewed by the l
6 CRGR and has been issued for public comment, is fairly l
7 simple.
8 Our intent is to allow licensees.to voluntarily l
9 remove those accelerated testing provisions from their f
i i
10 technical specifications by early implementation of a l
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11 maintenance program that will specifically address diesel t
12 reliability.
l l
1 13 With that introductory remark, I would like to 14 turn over the presentation.
r 15 MR. CARROLL:
As long as you got that far, let me l
?
16 ask the key question in my mind.
Does that mean that i
l 17 licensees would be committing to the accelerated testing l
18 problem diesel kind of thing in Appendix D?
19 MR. GRIMES:
Let me have Om do his presentation.
I i
l 20 MR. CARROLL:
All right.
I 21 MR. GRIMES:
Hold that thought.
After he has l
l 22 explained what our objectives are, if you still don't l
23 understand, then we will try to explain it more clearly.
l 24 MR. CARROLL:
The answer.to the question is really
+
25 yes or no.
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MR. LEWIS:
That's right.
In fact, we are less 1
2 interested in your objectives than what you are doing.
l 3
MR. CARROLL:
While he is getting ready, Chris, l
4 when is the public comment period over?
5 MR. GRIMES:
September 30th, I'm told.
6
[ Slide.]
7 MR. CHOPRA:
Good morning.
My name is Om Chopra.
8 I am an Electrical Engineer from the Electrical Engineering 9
Branch, Division of Engineering, NRR.
I am going to give 10 you a presentation on diesel generators.
i 11
[ Slide.]
12 MR. CHOPRA:
The tcpic of my presentation is
{
13
" Removal of Accelerated Testing and Specia) Reporting 14 Requirements of Diesel Gelieratois from the Plant Technical 15 Specification "
16 This is a line-item improvement in technical 17 specifications.
18 MR. CARROLL:
What does that term-of-art mean, 19 "line-item improvement"?
i 20 MR. GRIMES:
The Commission policy statement on i
21 Technical Specification Improvements allows a provision that 22 as we develop changes in staff positions that are'part of 23 the improved standard tech specs, that rather than complete j
24 conversion to the new standard technical specifications, r
25 licensees could adopt parts, which are termed "line-item ANN RILEY & ASSOCIATES, LTD.
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improvemente."
2 Mhen a licensee successfully achieves a license 3
amendment that adopts a part, the staff then prepares a 4
generic letter and offers up that part to other licensees l
5 who we would expect would also be interested in that change.
6 MR. CARROLL:
Okay.
Now, the scope of tnis, in
[
7 terms of testing, at least, is the removal of the l
l 8
accelerated testing requirements.
If you hit some present j
t 9
trigger in the tech specs -- or we going to get to that --
i 10 you then get into a mode where you have to successfully l
11 start-testeo seven consecutive times; is that what we are I
12 talkinc about here?
i 13 MR. GPIMES:
Yes, sir.
14 MR. CHCPRA:
I have prepared a slide to address l
15 that, if you are inte? rested to know what the current j
l I
16 accelerated testing requirements are.
I 17 MR. CARROLL:
Well, I am just trying to focus at t
18 the moment on what we are dealing with here, and what is 19 left over.
In other words, one of the Committee's concerns 20 is that we seem to testing diesels in some plant's annual l
21 frequency 10 times what we are doing in other plants, at 22 least according to the data that we have received from 23 NUMARC.
Now, how much of that is dealt with by this generic 24 letter?
25 MR. GRIMES:
This proposed action would allow ANN RILEY & ASSOCIATES, LTD.
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1 licensees who have technical specification requirements that l
2 accelerate the testing frequency for diesels to remove the I
i 3
tech spec requirements that say when you hit certain values 4
ci diesel failures, that you have to increase the frequency i
i I
5 of testing.
6 Right now, the requirements and technical l
7 specifications for diesel testing vary from plant-to-plant.
8 Older plants don't have any accelerated testing provisioca.
i l
9 The newer plants have some more stringent accelerated i
f 10 testing previsiens.
i l
11 So, there is a variety of practices demanded by i
l 12 technical specifications and there are a variety of I
i 13 practices that differ from utility-to-utility.
This is a i
14 proposal that licensees could voluntarily adopt.
So, there l
O..
15 may be some licensees who elect not tc early implementation 16 of the uaintenance rule, and continue to leave accelerated 17 testing requirements in their technical specifications.
18 MR. CARROLL:
What I am getting at is, for 19 example, some tech specs have a requirement that if one 20 diesel becomes inoperable you have to start test all diesels l
21 every eight hours, something like that.
This does not-deal 22 with that particular issue, does it?
23 MR. GRIMES:
No, sir.
l 1
24 MR. CHOPRA:
I can address that if you want to j
25 know.
Yes, we did have that requirement if one of the ANN RILEY & ASSOCIATES, LTD.
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1 diesels is inoperable since the remaining diesels have to be 2
tested, and the requirement was every eight hours.
But.
3 since we issued a generic letter 84-15, the licensees have 4
come in for a tech spec change to remove that requirements.
5 So the current requirement is if one of the diesels is 6
inoperable, that you test the other diesels within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 7
and that it is it.
Just once.
8 MR. CARROLL:
Just once.
So that part of the 9
testing requirements have been dealt with.
Are there other 10 things?
11 MR. CHOPRA:
It has been implemented.
12 MR. CARROLL:
Are there other things contributing i
1 1
13 to 150 starts per year in some plants that you have plans to
]
I 14 get relief on?
O 15 MR. CHOPRA:
There could be many reasons.
There j
16 could be lots of problems with the diesels.
They fix it, j
i l
17 they start it, and see if the problem is fixed.
So that l
i 18 causes you to test more.
19 MR. CARROLL:
I understand.
i 20 MR. GRIMES:
We have no specific plans to offer f
21 any more generic guidance on diesel testing other than that 22 which that was offered in generic letter 84-15.
Is that the 23 correct reference, Om?
24 MR. CHOPRA:
Yes.
25 MR. CARROLL:
84-15.
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1 MR. GRIMES:
What is presently contained in the l
2 improved standard technical specifications that was issued l
3 in September 1992, licensees have been directed to look at t
I 4
the improved standard technical specifications to determine 5
whether or not they could amend their licenses to change 6
other existing tests and practices that they currently have 7
in their technical specifications.
l 8
And if licensees determine that there is a portion 9
of the improved standard tech spec surveillance requirements 10 that they think offers some other relief that might reduce 11 the testing burden, then we encourage them through the 12 Commission's policy on line item improvements to. request it.
t 13 But I am not aware of any.
14 MR. MICHELSON:
Let me get a clarification of that 15 change you discussed, the one referring to the 24-hour i
16 single test.
What was the requirement before that in terms i
17 of how immediately must you do the test?
18 MR. CHOPRA:
Within eight hours.
19 MR. MICHELSON:
It was originally within eight J
20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />?
I 21 MR. CHOPRA:
Within eight hours and every eight l
s l
22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> thereafter.
23 MR. MICHELSON:
That part doesn't bother me as 24 much as if you lose one'of two diesels, and some plants only l
25 have two, I'm uneasy about running 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at full power l
l l
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1 without even knowing the other diesel would run, which is l
2 what I think you're now allowing.
I never heard that change 3
had gone through.
Maybe we should have seen it.
Maybe we 4
did, I did not recognize it.
l 1
5 MR. LINDBLAD:
Do you think there is a common mode r
6 failure mechanism involved in the associated diesel?
l 7
MR. DAVIS:
It could be.
I 8
MR. MICHELSON:
If we find out the second one l
9 doesn't run, of course, then they are obligated to start 10 their shutdown.
i 11 MR. LINDBLAD:
But if they were independent i
i 12 systems --
13 MR. MICHELSON:
I would hope that they are.
i 14 MR. LINDBLAD:
One could predict that the normal i
O 15 testing program gives some indication of their availability.
l 16 MR. MICHELSON:
Yes, but I do not know what I
l l
17 happened to the first diesel that caused the problem.
I l
j 18 wonder, why do we wait for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to test the second one?
l l
l 19 MR. WILKINS:
I think what Carl is saying is that 20 once the first one goes down, you are skating on thin ice.
l I
21 You have no backup.
22 MR. MICHELSON:
Yes, if the second one doesn't 1
)
23 run.
24 MR. WILKINS:
If the second one doesn't run you
)
25 have no backup.
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MR. MICHELSON:
Twenty-four hours running in that lv 2
condition seems a little strange.
l l
3 MR. GRIMES:
If I may, the way that we've i
4 organized the requirements in the improved standard tech 5
specs -- and I want to make clear that the improved standard f
6 tech specs will present the staff's current desired approach i
i l
7 in the way that diesel surveillances should be conducted l
8 because, as I mentioned, there is still a variety of l
9 different tech spec requirements from plant to plant.
10 There are a number of things that you want to do j
11 upon determining a diesel generator is inoperable.
The 12 technical specifications include provisions-for verifying-1 13 the line up, the breaker positions for the other diesel, for 14 checking to see whether or not there is a reason to believe 15 their might have been a common cause failure so that you 1
16 don't try and start the other diesel and then put yourself I
17 in a loss of on-site A/C power.
l 18 So there are a sequence of things and they have a 19 sequence of time associated with them that go up to starting 20 the other diesel within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
21 MR. MICHELSON:
I surprised, though, that it takes 22 you 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to determine'if you have a common load problem.
23 MR. GRIMES:
It doesn't.
That is a separate 24 problem My point is that there is a staggered set of 25 things to do and they are all outer bounds of times.
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don't expect licensees to have to take the full 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
j O
I 2
We tried to put an outer bound on what the maximum amount of j
3 time should be allowed for starting the diesel.
4 MR. MICHELSON:
That's what I thought the eight j
5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> used to be.
That was the bound.
And it was a 6
reasonable bound, I thought, we have been living it for many j
I 7
years.
I completely agree with you, repeated testing, I j
i 8
don't have any problem with removing the repeated testing.
9 But that first test, waiting 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to do it, that does.
l 10 sound strange.
i 11 MR. CARROLL:
I will bet you Carl that if you did i
12 a PRA analysis of that situation and there was no common 13 load element between the failure of the first and the second l
14 diesel, I'll bet the delta would be trivial.
l 15 MR. MICHELSON:
I don't doubt that at all.
16 MR. CARROLL:
You're operating on intuition.
17 MR. MICHELSON:
You're operating on common sense.
18 Common sense can do it within eight hours, common sense says 19 you ought to check it in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and not wait 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
20 What is the reason for waiting 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
21 MR. CHOPRA:
May I say something here,-sir?
22 You're right.
We say within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
It doesn't mean that 23 they have to take 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, they could do it before.
But we 24 also ask them to test and verify that off-site power is 25 available every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, so we do.have assurance that l
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165 i
1 although one diesel is down and the other one we haven't l
O 2
tested yet, but we know every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> we want to reassure l
I 3
that the on-site power is available.
4 MR. MICHELSON:
I think you must be sure on that 5
because you're running on it all the time.
I know if I lose l
6 off-site power I don't have to do any testing to tell me 7
that.
1 i
8 MR. CHOPRA:
It depend on your source.
j 9
MR. LINDBLAD:
There are separate requirements for 10 off-site powers.
l 11 MR. MICHELSON:
But your normal supply for off-l 12 site power you know immediately if it is not working.
I I
13 MR. LINDBLAD:
If the plant isn't standby you're 14 not so sure.
i O
?
15 MR. MICHELSON:
This is full power operation, I l
16 thought.
This rule must change a little bit, I think, for j
17
- shutdown, t
l 18 MR. GRIMES:
This is for everything except Modes 5 19 and 6.
20 MR. MICHELSON:
People who run these plants have 21 problems.
One of the problems is when you find one thing 22 that's down, you don't want to have to go down. 'So they'll i
23 wait 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to do the test simply because if they find 24 there is any kind of a problem, they have to start shutting i
25 down.
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MR. LINDBLAD:
I do not know that plant that takes 2
advantage of that, Carl.
3 MR. MICHELSON:
Then why_the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
i 4
MR. LINDBLAD:
I think they refer to that there 5
are a number of other steps they have to do in between 6
before they take the chance that they're going to lose the f
7 availability of the second unit.
8 MR. MICHELSON:
I have never heard eight hours f
9 being a pinch point on that.
I've never heard of that.as a 10 problem.
11 MR. CARROLL:
Why not one hour?,
i 12 MR. MICHELSON:
That's unreasonable.
I 13 MR. CARROLL:
Why is it. unreasonable?
14 MR. MICHELSON:
Because it does take time to check E
15 things out, but it doesn't take a day to check things out, l
l 16 that's all.
Go ahead.
17 MR. GRIMES:
If I may, we'd like to focus on what 18 this proposed action is.
19 MR. WILKINS:
That sounds like a good idea.
20 MR. CARROLL:
All I was trying to do was 21 understand the big picture that contributes to the excessive 22 testing.
23 MR. GRIMES:
My sense is based on what exposure 24 I've had to these issues in developing improved standard i
25 tech specs, that the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> versus 24' hours was addressed i
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when we developed generic letter 84-15.
It was not an issue 2
in the last two years, and we did go through and use generic 3
probabilistic analysis to test the validity of.these allowed 4
outage times or completion times, and we felt it was 5
reasonable at that point.
But we did not specifically focus f
(
i 6
on whether or not the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was the right 7
answer, but we would like to explain what this generic 8
letter is going to do relative to changes to plant technical 9
specifications.
f 10 MR. CARROLL:
One conformatory point, you have no 11 other initiatives in the hopper in terms of changing the i
I 12 testing of diesels that you can think of?
13
- 1R. GRIMES:
I hate to be so unequivocal as to say L
14 there are none.
The only thing that occurs to me is that 15 one licensee has requested a change to the practices for 16 load sequencers.
And load equencers and diesels have a l
17 very close and intimate relationship.
To that extent there l
l 18 may be a generic letter in the' works that has some relation l
19 to diesel testing that would come out at some point in the 20 future.
But that's the only thing that I can think of 21 that's in the works.
22 MR. CARROLL:
Okay.
Thanks.
All right.
Let's 23 move ahead at this point.
I 24
[ Slide.]
25 MR. CHOPRA:
Okay.
Just to give you a little l
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1 background.
This issue is part of the B-56 -- generic O
l 2
safety issue B-56, diesel reliability.
The staff 3
recommended five options to the Commission to resolve this 4
B-56 issue and the Commission approved option 4 and the 5
option 4 includes drop issuance of the revised rule and 6
incorporate NUMARC's initial reliability or demaintenance 7
program, namely Appendices D and E of the NUMARC 8700 into a 8
regulatory guidance.
I 9
And the second one -- sorry, the third one, is to 10 issue a generic letter to allow licensees to adopt the 11 accelerated testing requirements of the improved TEC Specs I
12 and then later on move tirose requirements when the 13 maintenance rule goes into effect.
But the staff concluded.
14 later on that maybe perhaps we don't need to wait'for the O
15 effective date of the rule, why not go ahead and let them 16 remove the accelerated testing requirements of now provided 17 they commit money to the diesel performance in accordance 18 with the rule.
19 The fourth --
20 MR. CARROLL:
For your information, Appendix D, at 21 least, begins on page 21 of Tab 10, if you're interested in 22 seeing what that has.
J 23 What is Appendix E?
1 24 MR. CHOPRA:
Appendix E is a reliability program 25 that NUMARC, as a matter of fact, NUMARC as well as the O.
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staff prepared together.
O l
2 MR. ZECH:
This is Gary Zech with staff.
Appendix
\\
3 E is not included in Reg Guide 1.160, just Appendix D.
l 4
MR. CARROLL:
How does Appendix E relate?
5 MR. ZECH:
It doesn't for this purpose.
6 MR. CARROLL:
It doesn't, all right.
i 7
MR. CHOPRA:
The fourth thing that you don't see i
8 here is the option 4 also included issuance of Regulatory j
9 Guide 1.9, Ref 3.
This guide simply integrates into a l
l 10 single document all the pertinent information that was l
11 included in Regulatory Guide 1.9, draft 2, Regulatory Guide.
12 1.108 and generic letter 84.15.
And this Reg Guide has 13 already been issued.
I believe it was issued in July.
14
[ Slide.]
O i
15 MR. CHOPRA:
So the proposed generic letter is l
6 going to allow a licensee to remove accelerated testing 17 requirements and the special reporting requirements of 18 diesel generators from the Tech Specs if they commit'the 19 money to EDG performance in accordance with the maintenance 20 rule and the guidance that is provided in Regulatory Guide 21 1.160.
22 MR. LEWIS:
Does 1.160 say " monitor" or does it 23 say " monitor and maintain"?
i 24 MR. CHOPRA:
Monitor and maintain.
i 25 MR. LEWIS:
That's an important distinction.
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MR. CHOPRA:
Yes.
Monitor and maintain.
2 MR. CARROLL:
Okay.
Now, the first bullet doesn't 3
mean anything to some of the earlier licensees because they 4
don't have these requirements.
l 5
MR. CHOPRA:
That's correct.
I 1
l l
6 MR. CARROLL:
Now, to the extent the licensees l
7 have accelerated testing requirements, are tney uniform and 1
l 8
present?
I 9
MR. GRIMES:
No, they are not.
1 l
10 MR. CARROLL:
Give me examples of the extremes?
1 l
i 11 MR. CHOPRA:
I'm sorry, I didn't get the answer.
12 MR. GRIMES:
To the extent that plants currently 13 have accelerated testing requirements, are they uniform?
i 14 And I said that they are not, because we are familiar that
, ('~.x t
15 there are plants that have the accelerated testing trigger l
16 values that are in the improved standard Tech Specs, but
)
17 there are some plants that have more stringent trigger 18 values.
19 MR. CARROLL:
So the difference is what triggers 20 going into seven days or seven tests with a day interval 21 between tests; is that it?
22 MR. CHOPRA:
I think they are uniform because ever 23 since we sent out generic letter ss.15 we introduced two out 24 of 20 trigger for the accelerated testing of the diesel 25 generators.
And almost all the plants today have already
("T
(,)
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i 1
implemented that Tech Spec change.
l O
2 MR. GRIMES:
Mr. Chopra and I differ only to the
?
3 extent that although we offered up the change in the 4
accelerated testing requirements which include both the 5
trigger and the frequency and details of how the. test should i
6 be performed, I've been advised that licensees have not j
7 uniformly adopted generic letter 84.15.
And when OM says l
8 almost that triggers me to say that I think that there are 9
some plants out there that did not adopt 84.15 and so if_we
[
l 10 were to do a survey and go through each of the plant f
11 technical specifications I think you would find differences.
12 MR. CARROLL:
All right.
13 MR. GRIMES:
But I don't know that that's l
l l
14 extremely relevant except to the extent that most plants l
c l
15 have accelerated testing requirements.
Some of the older I
l l
16 plants do not.
l 17 MR. CHOPRA:
I agree with that.
About 45 do not f
i j
18 have any testing -- accelerated testing requirements, but I 19 guess 60 some do.
20 MR. CARROLL:
Let me remind the Committee that'in l
21 the course of our review of the resolution of B-56, I guess j
l 22 is where it all started, we took a very strong position that 23 the requirement to do seven consecutive tests after you hit 24 some sort of a trigger was utter nonsense.
I guess.Hal kept 25 saying, what do you do when an airplane has_a problem?
You O
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1 fix it and take the airplane up and fly it around and land 2
it and if there are no problems, away.you go.
3 I'm, not sure it's quite that simple.
I think 4
there are some kinds of failures.
I might want to do 5
something beyond one test to demonstrate that it's_ fixed, j
6 but to just arbitrarily require seven consecutive tests was 7
something we strongly objected to.
8 MR. CHOPRA:
We have removed that requirement, but 9
I would like to point out one thing here.
The seven 10 consecutive starts, you may find them very excessive, but 11 the idea was to perform them on a weekly basis, so you want.
j l
12 to know if your diesel is performing well, because you know j
13 the normal test frequency is 31 days.
Even if you have 14 performed one test to verify the corrective actions,.but you 15 may not have really captured everything, so we wanted _them i
16 to do it on a weekly basis so that we know, yes, the 17 corrective actions have been adequately implemented by the l
18 licensees.
l 19 MR. LEWIS:
I think that the argument at the time 20 was that one can make a test for one test, one can make a 21 case for making enough tests to get valid statistical 22 information about the reliability of the diesel, but that 23 there was no argument for doing something in-between, 24 because seven tests provide no statistical information of 25 any value, and so it is illusory and perhaps deceptive, and ANN RILEY & ASSOCIATES, LTD.
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i 173 1
perhaps dangerous to pretend that they do.
I am making the O
2 point strongly, but those were the arguments, and I haven't i
3 heard otherwise from you.
In fact, you seem to be saying I
{
4 that the seven tests, picking up the other things, or 5
whatever your exact words were, do give you statistical 6
information about the reliability of the diesel, and they f
7 don't.
t l
8 MR. CHOPRA:
No, sir, I will not use the word' l
(
9
" reliability," no.
All I said was, it gives you a little r
l 10 warm feeling that, yes.
I don't want to wait for a month I
11 and see whether or not whatever corrective actions were 12 taken have been implemented properly.
I would rather know j
i l
13 on a weekly basis to see, yes, it does.
Maybe perhaps not i
14 seven starts, maybe three or four.
I don't know.
l l
i 15 Nevertheless, we have removed that requirement.
j l
16 MR. CARROLL:
All right.
17 MR. LEWIS:
Just to finish, you say you would like I
18 to know, but I think one needs more than what you would like 19 in order to justify this.
20 MR. CARROLL:
Let's move on.
21 MR. CHOPRA:
I guess the main thing is, the 22 licensee has to perform a root cause evaluation of each 23 failure, and that is the key point here.
They have to do a 24 good job on their maintenance so that they don't have any 25 failures, period.
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174 1
MR. GRIMES:
I would like to clarify, that-they 2
don't have any maintenance preventable failures.
The key.to i
3 maintenance rule and the key to the' guidance is, the root 4
cause evaluation should look to see whether-or not the i
5 maintenance program is being effective, and whether or not i
j 6
it needs to be changed so that the lessons that you have 7
learned from testing failures can improve the program that l
8 will ensure that the machinery operates when you want it to.
9 MR. CHOPRA:
Any questions on this slide?
10 MR. CARROLL:
I guess this.is the end of the 11 discussion of accelerated testing?
12 MR. CHOPRA:
That's correct.
13 MR. CARROLL:
Before we jump into reporting l
14 requirements, tell me how to read your generic letter, I O
15 find it contradictory.
I am on page 2 of Enclosure 1, and 16 for your benefit, members, that is 5 on the bottom of the 17 page.
Under " Discussion" you talk about Reg Guide 1.160, l
l 18 and in that first paragraph it says, "This guide" -- in l
l 19 other words, 1.160 -- "which offers guidance for the 20 licensees to follow to assure diesel generator performance."
21 It states that.
i 22 The rest of that paragraph is a quote from that 23 Reg Guide; is that correct?
24 MR. CHOPRA:
That's corre;t, it is.
25 MR. CARROLL:
In that quote, there is a statement ANN RILEY & ASSOCIATES, LTD.
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that or a parenthetical that says, "Except for triggers and O
2 testing of problem diesels as described in Appendix B."
i 3
There it says, "and that will be addressed separately by the 4
NRC."
Triggers and testing of problem diesels translates to 5
accelerated testing?
l 6
MR. CHOPRA:
That's correct.
7 MR. CARROLL:
Now I go to the next paragraph.
As 8
I read that, it says you have to adopt or you can satisfy or 9
you can remove accelerated testing from your tech specs if 10 you commit to a maintenance program and all that good stuff 11 in accordance with the provisions of 1.160, and finally it 12 ends up with the sentence, "These actions are intended to 13 close the matter of triggers and testing lfor problem 14 diesels."
How does it do that?
l 15 The previous paragraph that I read says you are i
16 going to do something in the future.
What have you done?
j 17 MR. CHOPRA:
This is addressing that part of the 18 problem EDG.
The problem EDG is the one that has perhaps 19 four failures in the last 25 tests, or two failures in the 20 last 20 tests, according to the present tech specs you have 21 to go on accelerated testing.
22 Now we have already killed accelerated testing.
23 MR. CARROLL:
You are already doing what now?
24 MR. CHOPRA:
We are removing this accelerated 1
25 testing requirement from the tech specs, so that means, by O
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1 virtue of doing that, we have resolved'this. problem diesel 2
issue.
3 The problem diesel issue was, if a diesel has four i
4 failures in the 25 tests, then you go on accelerated t
5 testing.
With this action, with this reported generic j
6 letter, we are.saying, you need not do any accelerated 7
testing.
So we have filled that gap.
8 MR. CARROLL:
Why didn't you say that in plain 9
English.
10 MR. CHOPRA:
Maybe we can elaborate on that last.
11 paragraph and make it more clear.
12 MR. CARROLL:
Okay, but your intent is that to.
13 satisfy this the licensee has got to commit to a maintenance i
14 program and one way of doing it is to monitor and maintain 15 EDG performance in accordance with the provisions of the 16 maintenance rule and consistent with Reg Guide 1.160, which 17 in turn endorses Appendix D of the NUMARC document except 18 for --
19 MR. GRIMES:
Except for Appendix D's explanation 20 of a problem diesel.
21 MR. CARROLL:
All right.
22 MR. GRIMES:
Would you put the previous slide up 23 for just a minute?
24
[ Slide.]
25 MR. GRIMES:
The logic that we are trying to O
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promote here is that licensees can implement a maintenance l
!O l
I v 2
program and recognize we don't have one to look at yet to 3
see how this is going to be accomplished in detail, but I
4 licensees are advised that they can use these triggers as a i
k 5
goal to initially establish their maintenance program.
)
i j
6 If they have a failure, however, the failure has s
+
i 7
to be evaluated for root cause.
Upon two failures, the goal j
i j
8 becomes moot.
You immediately go into evaluating trends and a
4 i
9 determining whether they are maintenance prevantable j
i t
10 failures.
11 MR. CARROLL:
Two failures in what period of time?
)
l l
12 MR. ZECH:
Any period of time.
If you have one i
i 13 failure that can be attributed to a maintenance preventable j
j 14 cause, if that were the initial criteria or their goal you 4
15 are allowed that one without establishing additional goals l
16 and additional monitoring.
i j
17 If you have two or multiple repeated failures, you 1
18 are required to --
i 19 MR. CARROLL:
The second one occurs 40 years after i
j 20 the first one?
21 MR. ZECH:
Well, they also have to in their goals.
)
i 22 consider the safety significance and the appropriateness of
)
23 the goals and the criteria based on the availability and the i
i 24 operability that is required of the equipment, so a 40 year l
25 period of time is not reasonable, but what we are requiring i
<i.
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178 t
l 1
or what we have alluded to in the Reg Guide, what NUMARC is i
j 2
doing, is based on the surveillance frequency and may 1
l 3
determine how many additional failures you could experience 4
in a period of time.
5 If it is a multiple month frequency, you could go I
l 6
several months before you would have to count it as a second
~
~
i j
j 7
maintenance preventable failure.
It depends on the i
j 8
equipment.
It depends on the significance of the system and l
l 9
the goals that you established and they are supposed to be i
a r
10 consistent with the safety significance.
)
i j
11 MR. CARROLL:
So the licensee is supposed to --
j 12 MR. ZECH:
They are only required by the rule to j
l j
13 establish the goals and their criteria for the NUMARC j
i i
{
14 guideline consistent with the safety significance of the l
J l
l 15 equipment.
J 16 MR. CARROLL:
So they would say if we have two l
}
}
17 maintenance preventable failures in five years then we have j
i 18 got to change our program.
19 MR. ZECH:
If that is what the period were that l
20 was set up and it was reasonable.
We would perhaps i
i 21 challenge that if in fact it was --
l 22 MR. CARROLL:
But it is up to them to decide.
}
23 MR. ZECH:
To initially -- that's correct.
i i
24 MR. CARROLL:
Okay.
e j
25 MR. LEWIS:
Have you confronted the question of-1 I, '
i 1
i i
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how to interpret the words " maintenance preventable" --
2 because every failure has, you know, ten different things 3
that contribute to it and anywhere down the line there may l
i 4
be something that is maintenance related.
l 5
Will that be interpreted as maintenance l
l 6
preventable?
7 MR. ZECH:
We just got off supporting NUMARC on l,
8 two workshops this past month, one in Atlanta, one in St.
i 9
Louis, and this very subject got a great deal of discussion.
10 What in fact is a maintenance prever. table f ailure?
What l
1 11 does it mean if you have one or more?
And it is really more 12 so an academic discussion because what you have to do is 13 look at what the reason was for the failure.
i 14 If you can attribute it to a maintenance type of O
'i 15 activity, that is very clearly a maintenance preventable J
16 failure.
If in fact there is a failure elsewhere in the 17 industry that the utility were aware of and it was 18 maintenance preventable and then they have the same problem l
19 at their plant, that could well be the second maintenance 20 preventable failure because they should have been aware of 21 it.
22 It was that kind of discussion that got a lot of-23 airing and will come out of the proceedings from these 24 workshops and we'll go back to look at it again with NUMARC.
25 Our intent is to hopefully clarify this area a little better
.O ANN RILEY & ASSOCIATES, LTD.
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1 so that the utilities when they implement the rule will have j
i 2
a fairly consistent idea of what that means.
l 3
MR. LEWIS:
Okay. The answer you gave me had two 4
parts.
5 One is -- I have to chastise you.
You used the l
I i
6 word " academic" as if it were a dirty word.
l 7
MR. ZECH:
It is.
8
[ Laughter. ]
9 MR. ZECH:
Strike that one from my testimony.
l 10 MR. LEWIS:
It's too late, too late.
Your soul is 11 doomed.
12 MR. ZECH:
Thank you.
i 13 MR. LEWIS:
You can't get it back from the devil.
(
f 14 But the second point is, what you have told me is j
O f
15 the classic answer.
That's a very interesting question; l
l 16 I'm glad you asked it.
i l
17 MR. ZECH:
It got asked several times in the l
l 18 workshops and we intend to look at it again and we'll have j
19 another workshop in the Spring and that will probably come j
j 20 out again as we discuss the inspection procedures, but l
j l
21 really the difference, Dr. Lewis, is whether or not if it.is 22 a maintenance preventable failure it could move you from-l 23 a(2) under the rule to a (1) under the rule.
Under a (2) the l
24 utilities by the NUMARC guidelines will set up criteria.
l 25 Now they may be the trigger values'in Appendix D ANN RILEY & ASSOCIATES, LTD.
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i 1
181 l
l I
1 to help them judge the performance of the diesel generators j
O i
I 2
but if they have a failure, maintenance preventable failure, 3
while they are doing their preventive maintenance, and that 4
is what is allowed by a (2), they may have to bump it up to j
i 5
a(1), which requires a more formal goal and more formal j
i 6
monitoring of performance and higher level management 7
attention because of that to get it fixed.
8 MR. LEWIS:
Okay.
You have increased the number-j l
9 of degrees of freedom I have to work with, because in the j
-i 10 past -- you keep using the terms that the triggers give you l
i 11 an indication or give you evidence.
Of course --
12 MR. ZECH:
-- they could be used as one; we're j
13 not dictating them.
l 14 MR. LEWIS:
At least I have always argued that 15 they cannot be used an one, but that's something that, yes, i
i 16 I feel like I am going through an earlier incarnation here, 17 but you have also raised the ambiguity of what is a i
l 18 maintenance preventable failure, which we'll be dealing 19 with.
20 MR. GRIMES:
Dr. Lewis, if I may --
21 MR. LEWIS:
You may.
22 MR. GRIMES:
At this point we expect that as we 23 approach the effective date in the maintenance rule that.
24 questions like this will continue to be pursued because you 25 are correct in observing that both the industry and the NRC O
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ought to have a fairly good understanding of what consists 2
of a maintenance preventable failure.
3 This action is recognizing that so long as the 4
licensee establishes a program to ask the question when they 5
do their root cause evaluation do we think this was a 6
maintenance preventable failure is a sufficient basis for us 7
to proceed with early implementation of this guidance and 8
allow licensees to remove these, as you observed, artificial 9
requirements from the technical specifications, if 10 artificial is the right way to describe it.
11 MR. CARROLL:
And to give both the Staff and the 12 licensees some experience in dealing with it prior to the 13 time the full maintenance rule is implemented.
14 MR. GRIMES:
And we believe that simply because of 15 the considerable controversy and debate and safety 16 significance of onsite AC power this is the right place to 17 start getting that experience and the right time to proceed 18 with developing programs that are going to perform root 19 cause evaluations that are going to try and do a systematic 20 evaluation of why the machinery doesn't work correctly and 21 what can be done to try and make it work better, 22 In that sense we are using reliability much more, 23 at a much higher plane.
24 As Gary pointed out, we are trying to get utility 25 managers to focus on why do these things not pass their-ANN RILEY & ASSOCIATES, LTD.
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i 183 f
1 tests and what can we do to make them operate better.
l O
i 2
MR. LEWIS:
First of all, I don't know what the i
3 difference is between a higher plane and a lower plane, but 4
as long as they are different planes.
5 My real problem with the term maintenance i
t 6
preventable, which may or may not have come up in your many i
7 workshops, is that when you use the word preventable, you 8
are playing an "if" game.
You are saying what if 9
maintenance had done something.
So you are projecting
-i 10 yourself into an alternate history.
You know, what if Jones 11 had actually been there instead of not been there?
What if 12 he had filed these points two mils further down?
Would the 13 relay have closed?
That kind of thing is what you are 14 playing and that is a can of worms and a deep pit to get O
15 into.
I i
16 MR. ZECH:
I think it is clear in the case of the 17 diesel generators what is intended by the generic letter and 18 what part of the maintenance progre.m or rule would be 19 implemented in this case.
20 Now, in a more generic sense, maintenance 21 preventable failure and the definiti.on did get a lot of 22 discussion.
But I don't think the participants or NUMARC.or 23 us were that far apart in our discussions.
It-basically is 24 that if you have a failure, it is going to have to be 25 analyzed regardless of what the cause was.
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i 184 1
MR. LEWIS:
Oh, sure.
2 MR. ZECH:
And that is going to lead you to 3
corrective action either under A(2) or under A(1) of the 4
rule.
That is the point.
5 MR. LEWIS:
I have never disagreed with that.
6 MR. ZECH:
That is the point.
The periodic review 7
of the program under A(3) also should put these types of 8
discussions before the licensee management, and clearly it i
9 is going to be performance-based.
So regardless of what you 10 call it, it is going to be scrutinized and a root cause 11 analysis applied.
12 MR. LEWIS:
But that is the place that we may have j
i 13 parted company, because, you know, of course, I have always l
i 14 been in favor of doing a complete analysis on any failure O
i 15 and fixing what is wrong.
How can anyone be against that?
16 But it is the next step which is inferring something about l
17 performance from single or small numbers of failures where I l
i 18 draw the line, because when you base actions on simply j
19 incorrect statistical inferences, you are bound to get into 20 trouble because mathematics'is unforgiving.
21 Another distinguished member of the staff once sat 22 across from the table on this very subject and said well, 23 you know, how mathematically you may be right, but as an 24 engineer I know you are wrong, and that leaves me a little 25 bit cold because -- well, let's go on.
J O
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MR. CARROLL:
Okay.
So accelerated testing is 2
dead.
3 MR. Cs.'OPRA:
That is correct.
l 4
MR. CARROLL:
All right.
Now let me play the 5
devil's advocate.
Where do I find your basis i;r justifying 6
throwing this longstanding requirement out?
7 MR. GRIMES:
Well, we told the CRGR it was because l
I 8
the ACRS convinced us it was the wrong thing to do.
9
[ Laughter.]
]
10 MR. SEALE:
The blood is oi. your hands.
l l
11 MR. CARROLL:
Very good.
Very good.
12 MR. GRIMES:
It is not a statistically valid way I
i 13 to conduct diesel testing.
l l
14 MR. CARROLL:
Thank you.
You may proceed.
l 15 MR. GRIMES:
Do you want to go on to the reporting l
t 16 requirements?
4 17 MR. CARROLL:
Bill has a question.
l 18 MR. LINDBLAD:
I disagree that accelerated testing
]
l 19 is dead.
I believe thac the 24-hour rule that we were i
20 talking about just earlier is acceler.ited testing, that it 21 could well be that the untested unit was tested only a day 22 before, but once the one unit fails, we accelerate the 23 period over which we test the other unit.
So in that sense, 24 accelerated testing still lives.
25 MR. CARROLL:
It is a question of nomenclature.
O ANN RILEY & ASSOCIATES, LTD.
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MR. LINDBLAD:
It is intensive repeat testing that 2
has gone aside.
So it is the repeated intensity of testing 3
that I think is gone.
4 MR. CARROLL:
No.
What is dead apparently is the l.
5 idea that on an individual diesel -- forget what its sisters l
l 6
are doing, but on an individual diesel, if it reached some 7
trigger, then you had to go into this mode of having seven-8 tests at least seven days apart or whatever it was.
9 MR. LINDBLAD:
I am arguing semantics rather than 10 i
11 MR. CARROLL:
Yes.
i 12 MR. CHOPRA:
I would like to point out one thing i
13 here, though.
When you are in an LCO and you are testing 14 the other diesel, that is a very simple test.
It is not a-15 full-loaded test; it's simply start and stopping just to l
16 make sure it starts.
17 MR. MICHELSON:
Let me make sure that'I-understand 18 what is being proposed and I will give you an example that 19 maybe will bring to light my concern.
20 If you have a diesel start one day for testing 21 purposes and find it doesn't start, then I understand within 22 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> you must make sure the opposite diesel will start.
23 A very simple test.
24 Now, in the meantime, on the first diesel, you 25 proceed to figure out why it didn't start and you found that ANN RILEY & ASSOCIATES, LTD.
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1 it had a dirty air system, so dirt got into the air-start i
2 motor arrangement and it didn't start.
3 Now, dirty air per se isn't necessarily common 4
mode because I will assume that these are completely j
5 independent, there are no common-air systems, nothing like i
6 that.
Yet, of course, the corrosion phenomenon that let the i
7 dirty air in in the first system might be leading to dirty 8
air in the second system, but perhaps later, beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 9
in fact, but sometime before the next 30 days or whenever i
10 the next test is performed.
t i
11 Now, how is that sort of problem accommodated?
l 12 What do you do about it?
j i
13 MR. GRIMES:
I apologize, I didn't clearly i
1 i
t l
14 understand what the problem is that you were pointing out.
l 15 MR. MICHELSON:
I am not pointing out a problem; I i
i 16 am trying to understand how it is treated.
I found dirty i
17 air in the first diesel generator that I started up.
l 18 MR. GRIMES:
Right.
i I
i l
19 MR. MICHELSON:
And in the meantime, I have done 20 my 24-hour test on the other one and it worked okay.
But it f
21 was a simple test.
I didn't tear the system apart or 1
22 anything; I just saw that it started.
23 Now, its air system may also be corroding from 24
--its common mode in the sense it is a corrosion phenomenon, 25 but corrosion is affecting the whole plant at all times in ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W.,
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1 188 1
some ways.
O-2 MR. GRIMES:
The bases for the tech. specs explain I
I I
3 that when you find an inoperable diesel generator, you 4
should first evaluate whether or not there is a potential-i 5
common mode failure in order to --
1 1
6 MR. MICHELSON:
What is common mode?
]
7 MR. GRIMES:
Common mode may be they have a common
]
]
8 air supply.
i 9
MR. MICHELSON:
But th9y don't in this case.
j i
10 MR. GRIMES:
Well, -- and I am trying to point out 11 an example that does address the question.
12 MR. MICHELSON:
Okay.
l f
13 MR. GRIMES:
If they had a common air supply, you
{
14 would want to first determine whether.or not this. dirty air O
l 15 supply might cause the other diesel to not operate so that l
?
16 you don't automatically go over and perform a test and cause i
l 17 both diesel generators to become inoperable.
I 18 As emergency officer. om Friday afternoon, around i
19 4:00, which is typical, we got a call from Oyster Creek and i
i 20 Oyster Creek reported that they had just performed a test on 21 their diesel and they had discovered that the diesel was i
22 inoperable because of the lube oil supply or something.
I 23 can't remember the particular detail.
But they determined 24 that one diesel was inoperable and they immediately went' 25 over and looked at the other diesel, and before they even F
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1 1
started it, they determined that the other diesel had the l
2 same problem.
They determined there was a common-cause l
3 failure and they only had one offsite line.
The did that in l
4 the matter of an hour.
They didn't wait 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and they j
i 5
didn't go off and test the other diesel.
They immediatelyL 6
went tn work on fixing the diesels.
7 MR. MICHELSON:
I think I understand that common 8
mode.
Mine is a different question, the question where j
9 there is no commonality in the event, there are no common l
\\
10 lubricants or anything of that sort.
They are a common l
i 11 design, though, and if one design is affected, it's a j
i 12 potential that the other design could be affected and I was i
13 trying to figure out how does your rule handle this kind of 14 situation.
l 15 You aren't going to require that.they go in and 16 examine the air system before they start'the motor, I don't 17 think, the generator.
I don't think that was your --
18 MR. GRIMES:
No.
All the technical specifications 19 require is that the licensee perform an evaluation to 20 determine whether there is a common cause.
If they conclude 21 that there is not, then the next step says test the other 22 diesel and make sure that it is working in order to provide 23 reasonable assurance that you have onsite A/C power, or i
24 otherwise, if you determine that there is not, then you shut 25 the plant down.
l l
i O
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[
1 MR. MICHELSON:
Okay.
j 2
MR. GRIMES:
The technical specifications do allow i
1 l
3 all the way up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to go test that other diesel.
l l
4 MR. MICHELSON:
Common sense tells'you if you have i
5 corrosion in one air system, and you. design'the two systems l
r 6
the same, you might have corrosion in the other.
There are j
7 cases where it might not be the case, though.
i 8
MR. GRIMES:
I can envision a plant manager i
i 9
saying, "This is a potential common mode failure.
I want to l
10 go check the air system on the other diesel before.1 perform
{
i 11 its test."
{
12 MR. MICHELSON:
That is what I am getting to.
l 1
13 What is your instruction concerning when to look for-common 14 mode?
In other words, what is a common-mode failure?
Is 15 that a common-mode failure to'have the air system in one l
l 16 diesel corrode?
l 1
17 MR. GRIMES:
The technical specifications require Il 18 that any finding that a diesel is inoperable, an assessment j
19 has to be made as to whether or not the reason for that l
20 inoperable diesel poses a potential common-load failure.
21 The technical specifications do not describe what 22 a common-load failure is.
It just requires that a-23 determination be made.
24 MR. MICHELSON:
They have to make a judgement as 25 to whether they think the other air system is also ANN RILEY & ASSOCIATES, LTD.
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191 1
corroding?
If they think it is, then.they are obligated to
{
O 2
shut the plant down in order to get into the second diesel?
3 MR. GRIMES:
That's correct.
4 MR. MICHELSON:
That is the only one they have 5
left, so, of course, there is a shut-down at that point.
l 6
MR. GRIMES:
Yes, sir.
j l
7 MR. MICHELSON:
So, they have every incentive not j
8 to tear into the other diesel, at least until they get the 9
first one running again.
I am just trying to figure how far u
10 you go on this common load in saying, "You had better check l
t 11 the second one before you_ start."
l 12 MR. ZECH:
If I could just say on the maintenance 13 rule, that is the type of logic or type of analysis we would 14 expect a utility to exercise also in a maintenance rule, O
15 even though it might not be required by the tech specs.
In i
I 16 separate systems, even there it should lead them to that 1
1 17 same question.
i 18 MR. MICHELSON:
Well, it looks to me like a dirty
]
19 air system on one diesel then leads you to a plant' shut down 20 because you couldn't have dirty air on the other one.
21 MR. ZECH:
No, I want to make clear --
22 MR. MICHELSON:
If you do the common-load 23 analysis, you have strong reason to believe that if the 24 common designs -- even though they are not connected --
25 there is a common potential that both of them are corroding O
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Court Reporters 1612 K Street, N.W.,
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=-
l l
l 192 l
l
+
t
-1 l
1 the same way.
l l
2 MR. ZECH:
That's true, but I want to make clear I
3 that all the technical specifications require is for 4
licensees to perform an evaluation and come to a conclusion.
If they concluded that there is a potential 5
l l
6 common-load failure, then we would expect licensees to 1
l l
7 address that through their normal maintenance processes, or testing processes.
That is part of the reason that there.is.
8 l
i l
9 a 24-hour time constraint.
We try to allow them enough time l'
10 to exercise that decision-making.
It would not necessarily' 11 lead to a plant shut-down, even if they did conclude that i
12 there was a common-load failure.
l l
l l
13 MR. CARROLL:
Let's finish the reporting 14 requirements.
Then maybe we can'have some more general O
15 discussion.
l 16
[ Slide.]
l 17 MR. CHOPRA:
Currently every diesel failure is.
18 reportable.
We found that very excessive.
So now they'have 19 to report it only in accordance with 10 CFR 50,.Part 21, l
20 Part 72, or Part 73.
21 However, the licensee, if they are going to adopt, 22 since it is a voluntary tech spec change, if they do, then 23 they have to commit to the maintenance rule.
Then the 24 licensee will maintain and use maintenance and testing 25 records to demonstrate compliance under 10 CFR 50.65.
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i 193 l
j 1
MR. KRESS:
Somewhere in the station black-out
{
l i
l 2
rule, they commit to one of two values of reliability for j
3 the emergency diesel generators.
4 MR. CARROLL:
That's correct.
5 11R. KRESS:
There is a requirement to monitor and f
l 6
maintain that reliability.
Does that show up in 10 CFR l
l 1
7 50.65, or is that going to be in the maintenance rule?
Is 8
this the wrong place to ask this quest, ion?
l 9
MR. GRIMES:
It is specifically addressed in Reg 10 Guide 1.160.
Under the discussion section, it tulks about 11 the relationship between the station black-out rule and its 12 assumptions regarding target reliability values and the j
l 13 maintenance program.
t I
I i
14 MR. CARROLL:
There is a footnote that was added, l
15 I guess I would say with our urging.
If you look at page_5 l
16 in your handout, read the footnote before you ask your l
17 question, or have you?
l 18 MR. KRESS:
Page 5.
i 19 MR. CARROLL:
At the bottom of the page --
t i
20 handwritten 5.
21 MR. KRESS:
It is kind of a negative statement.
[
22 It says it is not possible to do this,, but still the 23 requirements are there.
24
-The question is:
How are you doing to do it since 25 the requirements are there?
Either you have to be able to ANN RILEY & ASSOCIATES, LTD.
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1 do it, or you remove the requirement, or you do something
(
()
2 else.
That is the nature of my question.
1 3
MR. LEWIS:
I agree with you, Tom.
That is in the l
4 general category of you may be mathematically right, but we i
5 are going to do it anyway.
6 MR. CHOPRA:
I think we expect that the licensees 1
7 are going to maintain or monitor their diesel. performance'in f
8 accordance with the maintenance rule a (2), that they 9
shouldn't have any maintenance related failure.
If they do, l
a 10 they have to perform a detailed root cause analysis.
11 MR. CARROLL:
That is not the question.
i 12 MR. CHOPRA:
I know, but I am getting there.
If
)
13 they have two failures, then they have to go. to a (1) where l
14 they have to establish their goals.
The guide says that'you O
15 can establish the same goals that you have committed in your 16 submittals to the SBO, which are.95 or.975 for the diesel l
17 generators.
l 18 MR. CARROLL:
Oh boy.
Now how do I demonstrate 19 it?
20 MR. CHOPRA:
How do you demonstrate that?
- Well, i
i 21 then they are saying that you could use those trigger values i
1 22 as an indication that the diesel generator performance may 23 have degraded.
24
[ Laughter.]
l 25 MR. LEWIS:
Why can't we get through on this?.
(
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MR. CARROLL:
I don't know.
2 MR. LEWIS:
It.has been going on for years.
3 MR. CARROLL:
Did you read my green letter, Hal?
j r
4 MR. LEWIS:
No, I haven't yet.
Should I read it?
5 MR. CARROLL:
I guess I got mad.
6 MR. LEWIS:
I will read it because it will keep me i
7 shut up for awhile.
8 MR. CHOPRA:
We have put that footnote also in:the 9
generic letter to clarify the same thing that these trigger l
1 10 values do not really represent.
11 MR. CARROLL:
Okay.
Let me say it my way, Tom.
I.
I
{
12 am on the same subject.
l l
13 I guess my problem is that the footnote doesn't l
14 make the problem go away.
Any place you look in these O
15 documents, there is a clear inference that the trigger 16 values and monitoring methods really.are demonstrating.95 l
i 17 and.975 reliability.
I 18 MR. CHOPRA:
It is not.
19 MR. CARROLL:
Take a look at the first paragraph 20 of Appendix D, for example.
Let me find it.
Just to pick 21 one example, 21.
22 MR. CATTON:
What page?
23 MR. CARROLL:
Page 21.
24 MR. CATTON:
Handwritten?
25 MR. CARROLL:
Yes.
O ANN RILEY & ASSOCIATES, LTD.
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196 1
MR. CHOPRA:
Is this Appendix D?
2 MR. CARROLL:
Yes.
Now, if that doesn't clearly 3
infer that the trigger values for 20, 50, and 100 are 4
showing that you meet your coping capability, I guess I.
l 5
don't understand the English language.
6 This is just one example.
Look at the Reg Guide.
]
7 Now, it is fine to put the footnote in, but it doesn't make l
f 8
this kind of language go away.
9 MR. ZECH:
Let me try another approach to it.
t t
10 During the V&V processes that the plant went through, there 11 are about eight or nine plants, I believe, that went through 12 a few systems to define the-scope of the rule and to f
i 13 determine what the appropriate way might be to implement it.
i 14 One of the plants took a look at the' data that O
15 they assumed in their PRA for diesel generator availability, j
i 16 and run, and reliability.
They then looked at the data'that i
17 they had accumulated over several months and, in two of the t
5 18 three cases, they were able to show that they exceeded those l
l 19 values, but in the third case, which were successful runs, 20 they fell below their assumed value in the PRA.
So that, 21 through the maintenance rule, then requires an action.
22 They have to evaluate whether or not that lower 23 number would, in fact, in combination with the availability 24 and reliability still meet the data or still meet the 25 requirement of the station blackout rule, and if it does ANN RILEY & ASSOCIATES, LTD.
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197 l
l 1
fine.
It they have to make some changes, they have to l
2 change their goals in order to meet those criteria, and that 3
is the way the values are used.
But they are not used as i
4 specifically defined in Appendix D, they are-just examples 5
of ways to meet those assumed values in a PRA.
6 MR. CARROLL:
The problem with what you are 7
saying, Gary, is that if I have a year's worth of data on a 8
liesel, I can't tell whether it is at 97.5 percent.
9 MR. ZECH:
I understand that part.
10 MR. CARROLL:
I may know taat it is someplace 11 between 99 and 90, or something like that.
Does that say I
[
12 have failed?
l 13 MR. ZECH:
Well, it is a rolling one-year average, 14 that is what we allow under the Reg Guide.
I think the O-15 industry has taken it a little more conservatively than 16 that, but you can also consider industry data if the actual i
t l
17 plant data is not available, but you have to revise the 18 goals accordingly to meet the assumed values, then, under 19 the coping analysis and the station blackout rules.
1 20 It is not intended that this be a black and white f
L 21 number that you plug in, the number of starts, the number of 22 successful attempts for the starts, but it is used to help l
l 23 the licensee monitor the performance, make adjustments based 24 on performance, and look at the overall availability and 25 reliability of the equipment.
It is not intended to use the i
l ANN RILEY & ASSOCIATES, LTD.
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values that are specifically culled out as a litmus test as
)
2 to whether or not the diesel generators are in effect.
1 1
3 MR. LEWIS:
Gary, how can it even help them if it j
\\
4 doesn't carry any information?
j 5
MR. ZECH:
There is other data that can be used, 6
but you have to look at whether or not.that data is well l
l 7
founded, or is it conservative or not in meeting ~the goals.
l 8
MR. LEWIS:
Other data on the reliability?
1 9
MR. ZECH:
A good example is a plant who is l
10 starting up, and the one that we refer to is Watts Bar.
I 11 They have asked what should they use to establish the data i
12 for their plant?
l l
13 Well, they use sister plant data, they use j
i 14 industry data.
It is something they would have to consider j
O 15 as far as the reliability of it in terms of how it applies l
t 16 to their plant.
f 17 MR. CARROLL:
But that is how you establish the 18 goals, how do you demonstrate that you meet them?
l i
19 MR. ZECH:
There, again, it is the equipment
]
20 histories, the maintenance records, the availability of 21 support systems, if you lose cooling water to the oil, does I
22 that make an impact, sure it does.
You would look at that 23 and integrate it on a rolling one-year basis, or whatever 24 period of time they choose.
25 MR. KRESS:
That presupposes that you have made ANN RILEY & ASSOCIATES, LTD.
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some sort of an analysis industry-wide looking at a wide 2
population of diesels and have shown that if you have these 3
certain things in the maintenance program, if you have these 4
kinds of records, if you have this and this, then the 1
5 population of diesels will have a certain -- they will be i
6 above a certain level of reliability.
7 If you have done that, I would say, good.
That is 8
a logical-approach and a way to get out of this problem.
I 9
don't know if I have ever seen that anywhere, have you?
10 MR. LEWIS:
No, I haven't.
11 MR. KRESS:
That is what is missing that we 12 haven't seen.
13 MR. GRIMES:
An industry-wide evaluation of diesel i
)
I 14 reliability?
15 MR. LEWIS:
No, he is saying more than that.
He 16 is saying the development of reliability indicators through 17 monitoring the population.
In other words, wear limits, 18 temperatures, those things, and their relation to ultimate 19 reliabilities, which you can establish statistically by 20 looking at the population and then apply them'to individual 21 diesels.
That is what Tom is saying.
22 MR. KRESS:
That is exactly what I am saying.
23 MR. GRIMES:
That I would argue is something that 24 we are hoping will evolve as these programs are developed.
25 One of the common problems that we have had, and while I O
l ANN RILEY & ASSOCIATES, LTD.
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t 200 1
would hope that we could settle today all of the debate that 2
has gone on over the years that have derived from NUREG-3 1150 on how you take assumptions regarding the capability of 4
equipment to operate and a determination-about how often it 5
is going to fail, and then relate that to maintenance and 6
inspection findings.
They aren't one for one.
7 As Gary pointed out on Watts Bar, they have 8
certain assumptions about equipment reliability, but the 9
first refueling cycle is not going to give you a 10 statistically valid set of information to tell you that you-11 have satisfied all of those assumptions.
They will evolve 12 over time.
13 The maintenance programs are going to provide a 14 means to take trend information and then using an evaluation 1
0 15 and hopefully common sense and logic and thoughtful' I
16 consideration of what you find, there will have to be a i
17 relationship between the inspection findings and all of the 18 assumptions regarding reliability, availability, and what 19 you need in order to cope with station blackout.
20 The guidance also points out that you can use the 21 results from your IPE to try and establish goals or targets, 22 or something that you can relate your surveillance findings 23 to.
24 MR. LEWIS:
The problem that at least some of us 25 or at least one of us has with that objective is that if you O
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1 commit to this generic letter incorporating these flawed t
t 2
criteria, it will impede your progress toward a rational i
i 3
well-founded system rather than speed it up because it will,
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4 as people have said, close the subject and it will close it i
l 5
in an imperfect way whereas it would be better to leave it i
I 6
open, I think, and maybe others think, and proceed to a more i
j 7
logically based, forgive me, mathematically correct system.
r l
i l
8 MR. KRESS:
By the way, the approach I suggested l
l l
9 was an engineering approach.
10 MR.-LEWIS:
I have no problem with that l
l 11 engineering approach.
12 MR. CATTON:
And mathematically correct only makes 13 sense if I have the equation.
l t
14 MR. CARROLL:
Okay.
I do want to allow a little l
15 olc of time for NUMARC if they have any comments that they 16 would like to make.
Warren, did you want to say something?
17 MR. HALL:
Sure.
18 MR. CARROLL:
Do you want to come on up front?
i 19 MR. HALL:
Good morning, gentlemen.
My name is 20 Warren Hall.
I am with NUMARC, a manager in the operations 21 management support services division and Alex Marion sends 22 his apologies.
I didn't have a speech or a presentation 23 scheduled, but I thought there were a few things I'd like to 24 clarify.
First, on the generic letter we also -- we think 25 on its face it's probably a pretty good. deal for the ANN RILEY & ASSOCIATES, LTD.
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1 industry.
We do have some comments on it and agree with you l
i 2
that there needs to be some clarifications made, Mr.
l.!
3 Carroll, and we will submit some comments.
We have sent out l
4 information and our comments or will send them out'to our-l t
5 members this week for them to look at and let them decide 6
what they want to do, if they want to send individual ones.
{
7 But NUMARC will comment.
l 8
I'd like to make a couple of clarifying remarks on 4
i 9
the maintenance rule aspect of this thing.
They left-out a i
10 couple words and I'm sure I'll get some raised eyebrows over i
11 here if I step on my toes.
They left out a couple of key 12 words where they said, "more than one maintenance l
1 13 preventable diesel failure will cause going to A-1."
That's 14 not the way that we specified the maintenance rule.
If you
)
15 have a maintenance preventable failure of a particular 16 component you do have to do the root cause analysis, 17 corrective actions, et cetera, that type of thing.
- However,
)
1 18 the way the maintenance rule guideline was established was 19 if you have another failure of that diesel and you go and 20 find out what that failure was and that it was a different 21 failure, you have to go through the same steps again.
You 22 have to go through root cause analysis, corrective actions, 23 et cetera.
24 If you have not violated your performance 25 criteria, we have said it's not necessary for you to put
(
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that into A 1 We have, however, stated that if you have a; O
2 repetitive maintenance preventable failure, you must go to 3
A-1 whether or not you have violated your performance 4
criteria, or if you have exceeded your performance criteria.
5 And the other thing that we've had in there is.functiona'l l
i 6
failure.
We've talked about maintenance preventable j
l 7
functional failure -- Dr. Lewis is moving his head down; i
8 again.
9 Our purpose there is there are pieces of equipment i
i 10 that might fail on a diesel or in another system that 11 perform no safety-related function, have no impact on that f
12 system's capability to perform its safety. function and that f
r 13 is the reason that we put that in there to kind of separate l
L i
14 the two out so that you don't get the utility tied up in 15 insurance, as it were, if there's a failure of some piece of 16 equipment that has no safety function, no safety purpose, is 17 only in a system that may be there.
And for that reason we i
18 have used the word " functional failure" in that particular l
l f
19 aspect.
l 20 MR. CARROLL:
So if the nameplate falls off the 21 diesel --
22 MR. HALL:
If the nameplate falls off the diesel 23 because the guy didn't put the thing back in right, that's 24 probably a maintenance preventable failure, but that I
(
25 certainly wouldn't classify it as one that would cause you l
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204 1
to want to move it to A-2.
2 MR. CARROLL:
Got you.
3 MR. LEWIS:
What if the screw wasn't put in right 4
during maintenance?
5 MR. HALL:
It's a maintenance preventable failure, i
6 but it does not prevent it -- it doesn't prevent the diesel' 7
from performing its function.
Now, if the' screw was put in 8
wrong in maintenance that caused something to happen and the 9
diesel didn't perform its function, different story.
10 MR. LEWIS:
But the fix is not to do the 11 maintenance that have led to the failure of putting the-l 12 screw in right.
Now, let me ask another question.
13 You used, two or three times, the term " violating 14 your performance criteria."
How do you know when you've --
l 15 MR. HALL:
Exceeding your performance criteria 16 would probably be a better word.
Violation is not --
17 MR. LEWIS:
Which performance criteria do you have l
18 in mind?
19 MR. HALL:
You establish performance criteria for 20 your diesel?
l 21 MR. LEWIS:
Yes.
What performance criteria?
22 MR. HALL:
Well, that's the utility's call.
We 23 have made some suggestions and some guidant e in there that 24 they can use their value for reliability that they have 25 committed to for the station black out rule.
O ANN RILEY & ASSOCIATES, LTD.
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205 1
1 MR. LEWIS:
That's all I needed to know.
2 MR. CARROLL:
For.95 or.975?
3 MR. HALL:
For.95 of.975.
4 MR. LEWIS:
That's all I needed to know.
5 MR. HALL:
Those are the only things that I wanted.
6 to say.
Are there any other questions?
If not, that's it.
7 MR. CARROLL:
Any questions of Warren?
[. o response.)
8 N
9 MR. CARROLL:
Thank you.
Any other questions of.
10 the staff?
11 MR. DAVIS:
I would like to ask one, Mr. Chairman.
12 If a plant discovers that the on-site AC power is not 13 available is it a requirement that he immediately shuts the 14 plant down?
15 MR. CARROLL:
No on-site power?
16 MR. DAVIS:
Yes.
17 MR. CARROLL:
No emergency on-site power?
18 MR. DAVIS:
Right.
19 MR. CARROLL:
What do the latest and greatest 20 standard Tech Specs say, Chris?
21 MR. CHOPRA:
If both 22 diesels are down, then I believe you have 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to shut 23 down the plant.
Or you have 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to --
24 MR. CARROLL:
Two hours.
25 MR. CHOPRA:
But 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to bring the other --
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1 one of the diesels -- you have to make that other diesel i
2 available.
i 3
MR. GRIMES:
If I may, restore one diesel to 4
operable in two hours.
If not, you enter the controlled 5
shut down via mode 3 and 6, via mode 5 and 36.
6 MR. CARROLL:
Does that answer your question?
7 MR. DAVIS:
Yes.
But I want to follow it up with j
l 8
a comment.
It seems to me that there may be cases where i
l
?
9 that's not a risk-effective strategy.
Because shutting the f
i 10 plant down does not eliminate the need for on-site AC power 11 if you have a loss of off-site power.
I 12 MR. CARROLL:
You're right.
i 13 MR. DAVIS:
That's one thin.
The other. thing is I
14 that shutting the plant down takes that power producing i
O 15 element off the grid.
I i
16 MR. CARROLL:
That's right.
I i
17 MR. DAVIS:
And may decrease the -- or increase f
18 the instability of the grid increasing the possibility of i
loss of off-site power.
And thirdly, if you shut the plant l
19 20 down there is a point that you no longer have steam-driven
~
21 capability for core decay heat removal.
)
1 22 MR. CARROLL:
Also true.
l 23 MR. DAVIS:
Aux feed in the case of PWR and RCIC l
24 and the case of BWR.
I'm not convinced it's a good strategy 25 to shut down.
l i
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MR. CARROLL:
Well, I think what Chris will tell 2
you and I'll try it for him, is the present standard Tech 3
Specs are not risk based.
They're intuition based, if you 4
will and the staff does have an effort -- I'm not sure how 5
quickly it's proceeding, but an effort to look at Tech Specs 6
from a risk-based perspective.
l 7
MR. GRIMES:
I tend to agree with you.
As a i
8 matter of fact, we were very upset last year when' Brunswick 9
found that the bolts in the walls for the diesel generator i
10 were only bolt heads, and they decided that both of their i
11 diesels were inop and in the middle of the night took two 12 units down simultaneously.
They satisfied the tech-23 requirement.
I 14 Did they do a good thing, probably not.
That was 15 kind of a dumb thing to do to crash two units during the 16 middle of the night because they don't have the right kind 17 of structural confidence in the diesel generator building.
18 MR. DAVIS:
If they had left them to run, would l
I 19 that have been a violation of NRC regulations?
20 MR. GRIMES:
It would have been a violation of the i
21 tech specs, yes, sir.
22 MR. DAVIS:
What choice did they have then?
23 MR. GRIMES:
They could have requested enforcement 24 discretion, and we have done that on a number of occasions._
25 But I wanted to go on to say --
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i 208 1
MR. CARROLL:
There is also the provision, the l
O i
2 captain of the ship provision, or whatever it is, what is j
i 3
that?
l t
4 MR. LINDBLAD:
Unilaterally, they could have
{
t 5
decided that, too.
(
6 MR. GRIMES:
The point that I wanted to make is 7
that the regulations currently require,.if you can't satisfy l
8 your license conditions, you shut the plant down.
It 9
presumes that the safe condition is to shut the plant down, l
i 10 but the shutdown risk study has pointed out that that is.not l
l t
11 always true.
As a matter of fact, particularly with respect
[
t f
12 to A/C power, it is probably not true, and we have ben i
l 13 discussing a possible tech spec that could say that under j
14 circumstances where the shutdown condition is more risky j
15 maybe the right tech spec action is, go to Mode 3 or go to f
I 16 Mode 4.
But that is not going to be an easy thing to sell 17 to lawyers.
18 If we can clearly describe what constitutes a safe 19 plant condition, the shutdown risk tech spec proposals may 20 include something like that.
21 MR. DAVIS:
Thank you.
t 22 MR. CARROLL:
Actually, the comment on your l
}
23 selling it to lawyers, this controversy over statistics on l
24 emergency diesel generators has turned out, I think, that 25 the Commissioner who had the best insight on what was going ANN RILEY & ASSOCIATES, LTD.
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209 j
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1 on happened to be a pretty smart lawye O
2 MR. LEWIS:
He was also the first commissioner to 3
leave.
4 MR. CARROLL:
Yes.
i I
5 What else in the last two minutes do we want to 6
talk about?
f 7
MR. LEWIS:
I wanted to follow-up your comment l
l 1
8 about the captain of the ship clause, which has been a I
9 matter of some controversy.
Could a utility utilize the 10 captain of the ship clause to violate a tech spec when it 11 clearly -- and not shut the plant down -- in a case where it' 12 is clearly in his judgment the safer thing to do.
13 What would happen to him?
14 MR. GRIMES:
Unfortunately, we have not had a lot 15 of experience with the implementation of 50.54 (x)..
The I
16 closest enforcement cases that we have had have usually I
17 resulted in some kind of enforcement discretion because the j
18 operations center is advised that the licensee is in a i
19 situation, that awakens a duty officer in the middle of the 20 night, the region is contacted, and some time before 8:00 in 21 the morning a decision is made about what the right thing to 22 do is, both the captain of the ship and his pilot agree on 23 what the safe thing to do is.
24 In theory, the 50.54 (x) provision says, as long as 25 the captain of the ship made a decision that was in the best ANN RILEY & ASSOCIATES, LTD.
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i
l 210 1
interest of safety and that it appears to be a reasonable 2
decision, then he can violate his tech specs.
3 MR. LEWIS:
But people are certainly nervous about j
4 doing that.
j i
5 MR. LINDBLAD:
It was done during Hurricane Andrew l
i 6
at Turkey Point when communication was' lost with the 7
headquarters.
l 8
MR. LEWIS:
Then, of course, it is clearly l
l 9
justifiable.
I have often pointed out the difference in l
10 wording between 50.54 (x) and the analogous provision in the l
i 11 Federal Air Regulations, which are absolutely unambiguous, l
12 the captain can do anything he pleases if he declares an i
13 emergency, and I like that.
14 MR. SEALE:
And no second guessing.
j 1
15 MR. LEWIS:
That's right, there'is no second 16 guessing, where as the NRC thing is riddled with second 17 guessing.
j 18 MR. KRESS:
If he turns out to be wrong, he has to l
19 walk the plank.
20 MR. WILKINS:
In the aviation example, if he turns 21 out to be wrong, he is dead.
22 MR. LEWIS:
Not necessarily.
People have been 23 known to survive crashes.
I have even survived in-flight 24 emergencies that required violation of the Federal Air 25 Regulations.
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l 1
MR. CARROLL:
All right.
O l
2 Any more questions on this?
j i
3
[No response.)
4 MR. CARROLL:
We will try to have a letter on the l
5 table this afternoon for you to look at.
j t
6 We thank the staff for their presentation and I f
7 really think you should try to clarify this letter.
I am i
8 surprised it got through CRGR because it is confusing to me.
j i
9 MR. GRIMES:
We got a lot of help writing this 10 letter.
You might have noted that before it went out.for j
t 12 public comment, it got noodled two or three times, too.
We-I i
12 expect public comment, we will certainly take your comments j
l 13 into serious consideration for the final version of the
[
t 14 generic letter when it is presented to the Commission.
15 MR. WILKINS:
Thank you very much, Mr. Grimes, and
{
l 16 your staff.
17 We will now take a 15-minute break and resume at l
t 18 10:15.
19
[ Recess.]
20 MR. WILKINS:
Let us come to order.
The next 21 agenda item is number 11 and it deale with proposed 22 rulemaking on the fracture toughness requirements and 23 thermal annealing for reactor pressure vessels and Bob Seale 24 is the cognizant subcommittee chairman and I would' turn the t
i 25 meeting over to you.
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MR. SEALE:
Thank you, Mr. Chairman.
On the 16th
.\\
2 of August we had a subcommittee meeting at which we heard 3
about this particular package of rules and guidance and that 4
time was picked so that Dr. Shewmon could attend before he 5
set out for his period of time in Turkey.
l 6
MR. WILKINS:
By the way has he, in fact, by now?
7 MR. SEALE:
Yes.
As a matter of fact, he was j
B leaving from that meeting.
9 MR. CARROLL:
And we got an update.
Somehow or i
10 another he communicated, I guess through INTERNET, to Al 11 that they had picked up their new Volvo in Sweden and as of 12 two or three days ago, they had gotten as far as Stuttgart f
i 13 and expected to be in Turkey in two more weeks.
14 MR. WILKINS:
Very-good.
I apologize for i
i i
15 interrupting you.
i i
16 MR. SEALE:
Perfectly fine.
We received that 17 presentation, made a few comments and we now have the formal 18 presentation for the committee.
To make that presentation, 19 I will turn the podium over to Larry Shao.
20 MR. SHAO:
Today we are going to present to you 21 the proposed revision to 10 CFR 50, Appendix G on Fracture 22 Toughness Requirements and proposed revision to 10 CFR 50, 23 Appendix H on Material Surveillance Program Requirements.
24 We also will present to you proposed revision to 25 10 CFR 50.61, the Pressurized Thermal Shock rule.
In O
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addition to these, we will also present to you a proposed i
l 2
rule and reg guide on thermal annealing on reactor vessels.
l 3
Al Hiser will make the detailed presentation.
I 4
MR. CARROLL:
While he is getting ready I will j
l 5
share with the members Steve Mays assessment of our last l
6 session.
It said it reminded him-of a country western song-7 entitled, "What Part of No Don't You Understand."
8
[ Laughter.]
9 MR. HISER:
Thanks.
As Mr. Shao mentioned we have 10 proposed revisions to these three documents that I will be 11 presenting this morning and also a proposed rule and a draft 12 reg guide on thermal annealing.
13 What I want to do to start off is go over the 14 proposed revisions but before I discuss any of the details I 15 want to describe the reasons for the changes that we are 16 proposing this morning.
17
[ Slide.]
18 MR. HISER-The most important reason stems from a 19 review of the Yankee Nuclear Power Station reactor pressure 20 vessel, that is the official name for the Yankee Rowe plant j
21 which I am sure everyone is familiar with.
It really is the 22 review of the structural integrity of the reactor pressure 23 vessel that has brought us here today for the most part.
24 In addition, a second reason is the NUBARG backfit 25 claim and an appeal of a CRGR determination on their claim l
[
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1 dealing with requirements for core criticality during 2
pressure and leak testing.
3 Stemming principally from the Yankee Rowe review, 4
we received guidance from the Commission to go back and look i
5 at the RPV regulations and make revisions and changes as 1
6 necessary to approve those.
l l
7 In addition, NRR and RES staff performed pretty l
O much a top to bottom review of the regulations in this area 9
looking for the need for clarifications, corrections and i
10 changes for consistency.
I 11 MR. LINDBLAD:
Mr. Hiser, could you refresh my
{
12 memory of who NUBARG is?
j 13 MR. HISER:
That is the Nuclear Utility Backfit j
14 Analysis Review Group.
l l
15 MR. LINDBLAD:
Thank you.
16 MR. WILKINS:
Thank you, Mr. Lindblad for asking i
17 that question.
18
[ Slide.]
19 MR. HISER:
Now what I want to do over the next 20 couple of slides is go into a little bit more detail of the 21 review of the Yankee Rowe vessel'and I think this provides a 22 really good background on some of the changes that we are 23 looking at.
24 So as background, the review began in 1990 and 25 principally focused on PTS and Appendix G issues.
This.is i
i I
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Appendix G of 10 CFR 50.
The PTS issues stemmed principally l
2 from the method for calculating embrittlement estimates in 3
the PTS rule.
4 Now if you will remember, this is 1990 and in 1991 I
5 we published an amendment to the PTS rule so this goes back j
6 to the original rule.
In that rule the requirements were 7
that you use an equation to calculate embrittlement.
It-8 didn't say include any other information.
It said, "use 9
this equation."
10 For virtually every plant, that is an appropriate 11 method for doing the embrittlement estimate.
For Yankee I
12 Rowe, the surveillance data dating from the early 1960's 13 indicated much greater embrittlement than that equation 14 would indicate and further, the Yankee Rowe vessel operated 0
15 at a much lower temperature than the bulk of the plants that 16 went into the calculation method.
17 So Yankee Rowe had surveillance data and had an 18 irradiation temperature that indicated that there may have-19 been greater embrittlement than the PTS rule would indicate.
20 Now to show how responsive the staff is, we included these 21 sorts of considerations in the 1991 amendment to the rule.
22 So Yankee Rowe has already had an impact on the 23 PTS rule in that we require' licensees to consider 24 surveillance data and any plant operational characteristics 25 such as low operating temperature in improving their i
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1 216 1
embrittlement estimates.
j I
2 Now in the PTS review, the review quickly led to a j
3 probabilistic fracture mechanics assessment according to the 4
rule and one of the things that we found was significant 1
5 difficulty in using and interpreting the reg guide.that i
6 provides staff guidance on performing those calculations ar^
l 7
that is Reg Guide 1.154.
l 8
I won't go into any detail on our plans to address a
9 this reg guide because revisions are longer term items.
So l
10 we are talking probably three or four years before we would 11 be back here.
12 MR. LINDBLAD:
Mr. Hiser, do I remember there was l
13 some Oak Ridge reactor data on irradiation and temperature, 14 low temperature, and was that part of the issue as well, the O
15 HFIR?
16 MR. HISER:
No.
This is all the vessel material r
I 17 or irradiation temperatures on the order of 500 degrees and J
18 higher.
The HFIR was much lower.
19 MR. LINDBLAD:
Thank you.
20 MR. HISER:
And the mechanisms of embrittlement 21 are substantially different.
i l
22 MR. SGAO:
The HFIR work related to reactor vessel 23 supports.
24
[ Slide.]
25 MR. HISER:
Besides PTS there were issues related ANN RILEY & ASSOCIATES, LTD.
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1 to Appendix G and Appendix H of 10 CFR 50.
Within Appendix 2
G there is a requirement that vessel beltline materials have 3
to have a Charpy upper shelf energy greater than 50 foot 4
pounds throughout the lifetime.
l 5
There were a lot of concerns and questions about i
l 6
what is the process if the Charpy upper shelf energy is less 7
than 50 foot pounds.
There are two mentions in appendix G 8
of equivalent margins analyses.
9 There is a mention of additional fracture 10 toughness data.
There is a mention of an essentially 100 11 percent volumetric inspection of the material.
What is the 12 sequence for each of those steps?
That was one of the big 13 issues that rose.
14 Within Appendix H of 10 CFR 50, there were some 15 concerns about the applicable version of ASTM standard E-16 185 and I will go into a little bit more detail on how we 17 have sought to fix these problems a little bit later in the 18 presentation.
l 19 Now as the Yankee Rowe review was proceeding, 20 Yankee wanted to offer to perform a thermal annealing of the 21 reactor pressure vessel.
There was a lot of uncertainty as 22 to the regulatory process for that annealing, specifically 23 the criteria for the engineering assessments-were undefined.
i 24 There also were concerns over what the-exact approval 25 process would be.
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We tried to address this by coming up with a 2
proposed rule and a draft reg guide on annealing.
Arising i
3 out of this as well again was Commission guidance to revise i
4 and clarify the RPV regulations and the staff outlined i
5 proposed changes in these two SECY papers and then f
6 summarized them in this third paper.
l 7
[ Slide.]
]
l 8
MR. HISER:
Now what I want to do for the three 9
documents that we are revising is first, provide a little l
10 bit of background and content and then describe the specific 11 changes that we are proposing.
f 12 The PTS rule was initially published.in-1985.
I 13 mentioned early the 1991 amendment.
The purpose of that f
i 14 amendment was to resolve inconsistencies with reg guide
{
15 1.99, revision 2.
l 16 As you will see on the next slide, we did about 17 two-thirds of the job on that amendment and really didn't do l
j 18 the whole job.
So that has caused us to propose some j
l i
19 additional revisions to the PTS rule.
l 20 Now the rule provides embrittlement screening 21 criteria based on a parameter RT-PTS.
RT-PTS is an index on 22 fracture toughness at the vessel end of license fluence.so 23 it is the worst case for the operating period for the plant.
24 For axial welds and base metals, RT-PTS has:to be 25 kept below 270 degrees Fahrenheit and for circumferential ANN RILEY & ASSOCIATES, LTD.
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1 welds has to be below 300 degrees Fahrenheit.
These are the O
2 two screening criteria that there is a lot of mention to.
3 If the RT-PTS values are projected to exceed-these j
i 4
screening criteria, then a flux reduction program is 5
required.
If upon further calculation flux reduction is 6
inadequate to keep RT-PTS below the screening criteria then 7
a probabilistic fracture mechanics analysis is required.
i i
8 This would be the analysis that reg guide 1.154 3
9 describes and this analysis is supposed to be submitted 10 three years before the screening criteria will be exceeded.
I 11 MR. KRESS:
Does that specify the use of f
i 12 particular analysis methods or codes or tools or equations?
j 13 MR. HISER:
The reg guide is somewhat specific in j
i 14 terms of what the staff recommends.
The rule itself is not O
15 specific.
16 MR. KRESS:
But the reg guide is?
17 MR. HISER:
Yes.
18 MR. LINDBLAD:
It specifies some kind of an event I
19 that involves cold shock to the vessel as well?
20 MR. HISER:
Pressurized thermal shock is an 21 overcooling with pressure and it describes the procedures 22 needed to determine what the limiting response is.
23 MR. LINDBLAD:
But it is based on some scenario of 24 an event that generates a thermal ~ shock, is that right?
25 MR. HISER:
Yes, that is. correct.
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i 1
MR. CATTON:
They have to do a search, don't they, j
O 2
to figure it out?
l 3
MR. HISER:
Yes.
There is a lot of analysis of t
4 the systems.
5 MR. SHAO:
It would depend on the system.
l i
6 MR. HISER:
We'are not able to specify a specific 7
transient because of the plant specific nature.
8
[ Slide.]
l 9
MR. HISER:
The proposed revisions to the PTS rule f
10 are listed here.
The first change would make the RT-PTS 11 calculation method identical to that in reg guide 1.99, 12 revision 2.
The specific changes that we are proposing are 13 to the method for determining the initial RT-NDT and we are 14 also proposing to explicitly add the equation used for O
15 calculating the margin term.
)
l 16 A second change is to incorporate thermal 17 annealing as an acceptable option for meeting the 18 requirements of the rule.
This is not a relaxation of the 19 requirements.
It simply provides licensees with greater 20 flexibility in conforming to the rule..
21 MR. WILKINS:
Excuse me just a minute, Mr. Hiser.
22 I want to make sure I understand that second bullet.
-If one 23 predicts the RT-PTS to be greater than 270 degrees, then 24 this is a proposal that wou'l be an acceptable option, is 25 that right?
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l 1
MR. HISER:
That is correct.
l O
I i
2 MR. WILKINS:
Thank you.
j 3
MR. HISER:
The third change is simply a l
4 restructuring of the rule.
Right now the method for
[
l 5
calculating RT-PTS is factored into the requirements.
We 6
think this will add significantly to the clarity of the rule 7
to break that out.
I 8
[ Slide.]
9 MR. HISER:
Now Appendix G of 10 CFR 50 was f
10 initially published in 1973 and the last technical amendment i
11 was about ten years ago in 1983.
This Appendix provides the 12 fracture toughness requirements for ferritic materials of 13 the pressure boundary components.
I 14 Its key aspect is that it references Appendix G of f
([)
15 Section III of the ASME code for a lot of the details.
This
-i 16 Appendix requires evaluation of pressure-temperature limits i
t i
17 and minimum metal temperature and provides requirements for-l 18 Charpy upper shelf energy as outlined here.
l i
19
[ Slide.]
l 20 MR. HISER:
In terms of the proposed revisions to 21 Appendix G, we would propose a restructuring of Sections IV f
22 and V of the current Appendix G.
The P-T limits and minimum j
23 temperature requirements that are currently in Section IV l
t 24 would be identified principally in a new table.
1 i
25 The procedures for Charpy upper shelf. energy below j
i
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l ANN RILEY & ASSOCIATES, LTD.
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I 222
\\
1 50 foot pounds would be clarifieC.
We would make it clear i
2 that an equivalent margins analysis is required three years i
3 before the upper shelf energy is going to-be below 50 foot 4
pounds.
This really maintains that requirement.
l 5
But basically you can simply do the analysis to 4
1 6
meet the requirements of Appendix G at this time.
7 The additional fracture toughness data may'be.
f i
8 obtained for inclusion in that analysis.
We would delete.
i 9
the requirement for volumetric inspection.
Right now the
}
i 10 ASME code Appendices VII and VIII are being implemented 11 through 10 CFR 50.55 (a) along with augmented inspection t
12 requirements.
We feel that those are adequate to replace 1
13 the requirement for volumetric inspection in this case.
14
[ Slide.]
I 15 MR. HISER:
In addition, we would specifically 16 require that pressure and leak tests required by the ASME 17 Code be completed prior to core criticality.
That is a 18 specific statement that we would add to Appendix G.
l 19 This basically implements a CRGR recommendation to i
20 the EDO which again goes back to the NUBARG backfitting 21 claim and appeal.
Within Section IV, we would delete the-22 d.esign to permit annealing requirement because it doesn't 23 make sense to have a requirement for something that is 24 option since annealing is optional.
It is not a 25 requirement.
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1 Further, we would change the reference from j
r l
I 2
Appendix G of Section III to Appendix G of Section XI of the i
3 ASME Code.
Section III is the construction code and Section 4
XI is more of an operating plant code.
So it is more of a 5
logic at this point and the two appendices are identical so
{
l 6
there is no change in requirements.
7 The last modification of Appendix G would be to j
1 8
delete the existing language on annealing and replace it 1
9 with a reference to the proposed thermal annealing rule that 10 again I will describe a little bit later.
11 MR. LINDBLAD:
Does the change of the reference to 12 Appendix G to Section XI also sweep some of the older units 13 under the tent that weren't constructed to Section III?
14 MR. HISJR:
No.
Appendix G has a lot of the 15 calculational procedures and all this does it take it.ror 16 Seccion III to Section XI.
It really wouldn't impact any l
l 17 plant.
i 18 MR. LINDBLAD:
Thank you, t
19 MR. SHACK:
Al, is that being done however because 20 you are anticipating changes in Appendix G through Section 21 XI and you would then presumably endorse those changes?
22 MR. HISER:
Yes.
That really is the intent of it.
23 MR. SHAO:
I think Bill had a point.
Some of the l
24 older plants were not built to Section III so in-this way, 25 everything is in reference to Section XI.
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[ Slide.)
2 MR. HISER:
Appendix H of 10 CFR 50 requires the 3
use of a material surveillance program to monitor.
4 irradiatial embrittlement of the beltline materials of the 5
RPV.
This appendix references ASTM Standard E-185 for a lot 6
of the details on surveillance programs and also Appendix H.
7 permits the use of an integrated surveillance program and I i
8 hope everybody knows what that is.
j i
9
[ Slide.)
.)
J 10 MR. HISER:
The proposed revisions to Appendix H i
11 are outlined here.
The main revision would clarify the.
l l
12 version of E-185 that is applicable to each portion of the 13 surveillance program.
The specific wording that we are 14 proposing is indicated here.
l O
15 Further, we would discontinue a provision that is i
16 currently in Appendix H that permits the reduction on the i
17 amount of testing in integrated surveillance programs when j
i 18 initial results agre e with predictions.
So we would l
19 discontinue that provision.
20 MR. CATTON:
Why?
It seems to me that if they can 21 predict it, they ought to get some relief.
22 MR. HISER:
We are not sure.
For one thing, we 23 don't have any critaria for judging when' initial results 24 agree with predictions.
In addition, the limited expens'e in 25 doing the testing provides us with very valuable data on ANN'RILEY & ASSOCIATES, LTD.
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225 t
1 embrittlement.
So those are the principal reasons.
2 MR. LINDBLAD:
That are vessel specific or for the 3
broader industry research program.
4 MR. HISER:
Both, vessel specific but also it l
5 aides us in providing additional data for reg guide 1.99 6
recalculations.
7 MR. CATTON:
I guess I am still missing something.
8 If the initial results agree with the predictions, why can't 9
they reduce the amount of testing?
10 MR. HISER:
We don't have any criteria for how' l
11 good the agreement has to be.
i 12 MR. CATTON:
You can draw a line right through the 13 data point.
Shouldn't that do it?
It is a good comparison.
14 MR. WILKINS.:
Do you use a nice thick pencil or do j
O 15 you use a 4-H pencil to draw that straight line?
16 MR. CATTON:
The kind of data I have seen on this, 17 any pencil is okay.
18 MR. WILKINS:
I could use the end of this gavel to f
i 19 draw that line.
20 MR. LINDBLAD:
Whatever the thickness of the 21 pencil is, the statement was when it agrees with the 22 predictions and if the predictions had an uncertainty band 23 which I suspect they did, then presumably it would cite what 24 the thickness of the pencil was.
I 25 MR. CATTON:
That's right.
I just don't 1
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2 MR. WILKINS:
You can't give them credit for it 3
MR. CATTON:
Right.
4 MR. HISER:
We don't have a similar provision for 5
non-integrated programs and we have also in some cases with 6
later capsules find some surprising results that we would be 7
afraid that we would end up missing something that we might 8
need to take cognizance of.
9 MR. SHAO:
A1, maybe you ought to explain ~the 10 integrated surveillance program.
For instance, instead of 11 getting material for each vessel, the integrated 12 surveillance program is they put three or four materials in 13 one vessel and then they put that Arkansas vessel into 14 another vessel surveillance.
So instead of having their own O
15 material they use material that is shared among four or five 16
- vessels, l
17 MR. CATTON:
What you are telling me is that the l
18 testing is not good enough.
So if the calculation happens 19 to match it, it is just fortuitous.
I understand that l
20 reason for taking that out.
21 MR. SHAO:
But for each individual vessel we don't 22 have such a relaxation, only the integrated vessels, they 23 have such a provision.
24 MR. HISER:
I am rot sure what the intent of this 25 really was initially.
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1 MR. WILKINS:
Larry, that sounds to me like you O
l 2
are saying there is no value to the integrated surveillance t
3 test.
l 4
MR. CARROLL:
That's right.
i 5
MR. SHAO:
Wait a minute.
Maybe I didn't explain i
6 myself very clearly.
Suppose you have a vessel by itself, 7
Yankee Rowe, you have to test all the years.
You have to f
8 test every three years, six years, nine years and so on.
i 9
But row because they don't have the material for Arkansas,
{
10 they use Davis-Besse material.
11 This way they only have to look at the initial i
12 value.
You don't have to test it for the rest of the life.
13 But that is not fair for Yankee Rowe because they have their 14 own material and in the meantime, they would track all the O.
15 way to the end of the life.
16 MR. SEALE:
If I may, isn't the point that the i
17 initial value gives you the intercept on the curve but you 18 have to do the subsequent testing to get the slope and there l
l 19 is some scatter in the slope.
20 MR. CATTON:
All right.
The scatter in the slope 21 is going to tell me how far I can project.
This just seems 22 sort of silly.
23 MR. SHAO:
Let me make another argument here.
24 Suppose your life is 40 years, okay.
A human's ius 70 years.
25 MR. CATTON:
Sometimes I feel like it.
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l 228
[
1 MR. SHAO:
After 20 years you make a check and
{
2 everything is okay.
It doesn't mean you don't have to check 3
it every 40 years or 50 years or 60 years. 'Like eyesight,
[
4 you do it every ten years, you do it ten years, 20 years, 30 5
years and 40 years.
I 6
MR. HISER:
My understanding is that this l
7 provision has only been implemented in the case of a couple 8
of plants and we do have a grandfather clause in there that-I 9
would not force those plants to go back and do the testing.
t 10 MR. CATTON:
What is going to happen to the new 11 plants like AP-600.
12 MR. SHAO:
They have to do it every few years.
i 13 MR. CATTON:
Testing is independent of their i
14 ability to predict the behavior.
O 15 MR. SHAO:
Yes.
I 16 MR. CATTON:
That is what that says.
i l
17 MR. HISER:
That's right.
That is the purpose for
{
18 surveillance.
I 19 MR. LINDBLAD:
But if you agreed with that, you 20 would change ASTM E-185.
21 MR. HISER:
E-185 has no impact on this.
22 MR. LINDBLAD:
Isn't that what describes the 23 integrated surveillance program?
Or what is the program 24 that describes the integrated surveillance program?
j i
25 MR. HISER:
That is appendix H of-10 CFR 50.
E-1 O
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229 l
1 185 just tells you how to design a surveillance program, O
2 withdraw schedule and that sort of thing, what materials you 3
need to use, what sort of specimens, how many specimens, j
4 that sort of thing.
The integrated program is solely within j
i 5
Appendix H.
6 MR. LINDBLAD:
I am sympathetic with Ivan's 7
remarks.
It seems to me that if you define what you meant B
by initial results, whether it is the intercept or intercept 9
plus slope,-and if they agree with predictions, then 10 certainly you use your predictions with a scatter band in i
j making your conservative assumptions, I am sure.
j 11 l
12 MR. HISER:
I think the staff conclusion is that f
i 13 that would be quite an effort to develop those criteria.
14 The cost involved in the testing is. fairly trivial'once the O
l 15 specimens have been irradiated.
16 MR. SHAO:
You are going all the way to 40 years I
17 or 60 years in this case.
18 MR. CATTON:
What is the period of the testing now I
l 19 before you put this clause in?
How often do they have to do 20 this testing?
21 MR. HISER:
It depends on the expected 22 embrittlement for the vessel.
I think a minimum of three 23 capsules up to five capsules.
24 MR. CATTON:
How often do they look.at them?
25 MR. SHAO:
About every five years or so, four or O
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230 1
five years.
i j
I 2
MR. SERPAN:
Chuck Serpan from Research, f
3 MR. CATTON:
Why are you talking about 40 years?
l l
4 MR. SHAO:
The life of the vessel is 50 years.
l 5
MR. CATTON:
I understand that.
So they want ts 6
change their testing interval from five years to ten years i
7 because they can demonstrate to you that they really have'a 8
hot shot prediction approach.
{
i 9
MR. HISER:
The idea is not that they increase the
{
10 testing interval.
It is that you end all testing.
j 11 MR. SHAO:
You end the testing.
12 MR. HISER:
If there are any operational changes 13 14 MR. CATTON:
That is not what that says.
O l
15 MR. SERPAN:
Yes, it does.
What it says is if the l
16 first data point agrees you don't have to do any more 17 testing.
We don't allow that for other plants.
18 MR. CATTON:
I understand that.
That is not what 19 it says though.
20 MR. SERPAM:
That is what it is supposed to say.
21 MR. CATTON:
It says, " reduce amount of testing."-
22 It doesn't say " cancel testing."
23 MR. SERPAN:
That is correct.
l j
24 MR. CATTON:
But cancelling testing is kind of l
25 dumb.
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I 231 1
MR. WILKINS:
You are going to reduce it to make 2
it more convenient.
3 MR. CATTON:
But not allowing me to change the 4
period of testing when I have a good tool for predicting is 5
also kind of dumb.
6 MR. SERPAN:
Reducing could be 99 percent.
There 7
is no specificity in that and that is why we want to get rid 8
of that.
MR. CATTON:
When you use the word " reducing," you 10 mean to zero.
11 MR. SERPAN:
Then you are in an argument as to 12 what is reducing and somebody says, 'well, 99 percent" and 13 we say, "no, two percent."
That is a source of argument.
14 MR. LINDBLAD:
But you can resolve that argument 15 in writing a good regulation.
16 MR. SERPAN:
The point is we don't allow that for 17 other plants when they have their own data.
We are not 18 allowing it for the integrated surveillance program.
l 19 MR. CATTON:
Then you should allow it for them, l
L 20 too, I think.
l 21 MR. SERPAN:
No, because just one point does not a 22 curve make as Dr. Seale said.
23' MR. WILKINS:
Ivan, you have hit them over the 24 head with it five times now.
I don't know whether you are i
25 going to get any further.
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l I
232 l
1
>R.
CATTON:
Probably not.
2 MR. HISER:
But I think maybe the key point came j
3 out, reducing within the context of Appendix H means i
4 termination of testing.
i 5
MR. CATTON:
You certainly need a couple of test i
I 6
points.
Tnereafter, it seems to me that if you are 7
predicting, well, you should be allowed to stretch it.
l I
8 MR. SHAO:
Another point is that this is not i
9 consistent with other plants, i
10 MR. CATTON:
That is a separate issue.
j 11 MR. LINDBLAD:
Is that a safety reason?
12 MR. SHAO:
If you want to reduce them, you should I
13 reduce it at all plants.
14 MR. WILKINS:
Well!
O l
15 MR. CATTON:
If all plants predict, fine.
j 16 MR. SHAO:
They cannot.
)
i 17 MR. CATTON:
If they can't, then there is no j
l f
I I
18 problem.
j 19 MR. WILKINS:
Why don't you proceed, Mr. Hiser?
20 You have heard us and so has Mr. Shao.
l 21
[ Slide.]
22 MR. HISER:
I will go ahead and describe the 23 thermal annealing rule and draft reg guide.
The first thing 24 I want to do is provide a short description of. thermal 25 annealing for those who may not be familiar with it.
O~
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Basically, thermal annealing of the vessel is 2
achieved by heating the vessel to temperatures higher than 3
the operating temperature.
For commercial light water 4
reactors in the U.S.,
this would probably involve 5
temperatures from 650 to 850 degrees Fahrenheit for about a 6
week.
7 Thermal annealing is beneficial in that it 8
recovers the embrittlement caused by irradiation.
In 9
particular, higher annealing temperature or the greater the 10 difference between annealing temperature and operational 11 temperature gives greater recovery.
12 The benefits of annealing are that it can restore 13 the upper shelf energy, reduce RT-NDT and RT-PTS and it can 14 widen the pressure-temperature curve operating window.
15 MR. WILKINS:
You did not say but I assume it is 16 true that not only is the higher annealing temperature gives 17 greater recovery but greater time of annealing will give 18 greater recovery.
19 MR. HISER:
That is correct.
20 MR. WILKINS:
Is there a saturation in that?
21 MR. HISER:
Yes.
There is a saturation effect.
22 MR. SEALE:
First order of saturation.
23 MR. HISER:
Yes and one week has found to be a 24 pretty optimum time as opposed to say a two week period.
25
[ Slide.]
O ANN RILEY & ASSOCIATES, LTD.
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1 MR. HISER:
Why do we need a thermal annealing 2
rule and a reg guide?
The existing 10 CFR 50 Appendix G 3
addresses annealing principally in the context of the 50 l
4 foot pound criterion on upper shelf energy and we know from j
I 5
extensive experimental data that annealing is also 6
appropriate to reduce RT-NDT.
7 The Appendix G requirements principally deal with l
8 the evaluation of recovery from materials tests only and the t
9 method that is given there is not practical in all cases.
10 In addition, Appendix G contains no requirements on the 11 engineering aspects of annealing.
12 Further, the proposed annealing of the Yankee Rowe 13 vessel highlighted the need for more complete regulatory 14 framework in terms of application and approvals and that 15 sort of thing.
16
[ Slide.]
17 MR. HISER:
Now the proposed annealing rule has 18 two principal components, an application and a 19 certification.
The application is subject to the approval 20 by the Director of NRR and should be submitted three years 21 prior to the anneal.
I will go into a little bit more 22 detail on each one of these.
23 MR. WILKINS:
Three years just sounds like an 24 incredibly long time.
What is the Director of NRR doing l
25 during that three years?
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MR. HISER:
There is a lot of review.
These 2
applications involve a lot of complex analyses.
3
[ Slide.]
4 MR. HISER:
I think if I describe what needs to be 5
considered.
6 MR. SEALE:
Another point here.
When you say 7
submitted three years prior to anneal, I assume that means 1
l 8
three years prior to the point when the utility actually 9
begins the annealing and not when the Director of NRR gives 10 his approval.
11 MR. HISER:
That is correct.
I 12 MR. WILKINS:
And he would have to approve l
13 considerably ahead of time in order for the utility to get 14 started in three years.
l O
15 MR. SEALE:
There is a long front end before you f
i 16 actually begin the annealing.
{
f 17 MR. WILKINS:
Actually if I had seen this slide, I l
\\
l 18 might not have asked my question.
19 MR. HISER:
The thermal annealing application has 20 three principal parts to it, an annealing operating plan, 21 requalification inspection and test program and a fracture 22 toughness recovery and reembrittlement program.
23 The thermal annealing operating plan, in that plan 24 the licensee basically will describe their proposed 25 parameters in terms of time and temperature, how they l
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propose doing the annealing in terms of the method and the O
1 2
procedures.
1 3
Besides demonstrating that they are going to do 4
good things to the vessel in terms of restoring the fracture l
5 toughness, we want to make sure that_they don't do bad 6
things to other parts of the system.
So we want to make 7
sure they don't degrade any other equipment, components and 8
structures.
9 Now in terms principally of the vessel but also i
10 the attached piping, there is a need for thermal and stress i
11 analyses and also they have to consider ALARA.
The i
l 12 operating plan in addition would project the recovery that l
i 13 they expect and also project the reembrittlement that they l
i 14 expect once they restart the plant.
O 15 Now the Requalification Inspection and Test 16 Program is intended to demonstrate that the proposed 17 annealing conditions were not exceeded during the actual i
18 vessel annealing.
In addition, the results from this 19 program would define the actual annealing time and 20 temperature that would be used in evaluating the actual 21 recovery.
22 The Fracture Toughness Recovery and 23 Reembrittlement Program, in terms of the. fracture toughness 24 recovery,-licensees would be required to use surveillance 25 specimens if either untested or tested specimens are v
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i 4
237 1
available and the data from that program were credible i
1 2
according to the PTS rule, u
l 3
In addition, licensees could take samples from the j
i 4
beltline to evaluate recovery or they could use a j
i
}
5 computational model if they justify the data that went into 4
1 t
j 6
that model.
On each of those points, I will go into a i
7 little bit more detail when I describe the reg guide, f
8
[ Slide.]
l 9
MR. HISER:
Now the certification, the post-anneal t
10 certification, would be submitted by a licensee if the i
j 11 licensee can certify that the annealing was performed within j
1 12 the proposed annealing conditions.
i j
13 In this case they would provide these various j
l 14 items, the post-anneal properties, the reembrittlement l
I 15 trends and then they would also project RT-NDT and Charpy 3
1 4
16 upper shelf energy at the end of their proposed period of l
l 17 operation.
j i
18 If there was some deviation from the application l
I l
19 and the annealing was not performed within the proposed l
1 i
I 20 annealing conditions, then they would have to submit 4
1 i
ij 21 justification for subsequent operation and that would have
)
22 to be approved by the Director of NRR before restart.
i j
23.
MR. WILKINS:
Teach me some metallurgy or physics-1 i
J 24 anyway.
Reembrittlement is a function of the fluence and.
I i
i i
25 the temperature at which the vessel is operating.
Let's i
i i
i i
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. ~,
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238 1
make this isothermal for the moment.
[
2 MR. HISER:
All right.
3 MR. WILKINS:
So it is a function of the fluence f
4 and with time then the embrittlement goes up, all right?
f 5
MR. HISER:
Yes.
'I 6
MR. WILKINS:
How you stop and you anneal.
I 7
MR. HISER:
Yes.
8 MR.. WILKINS:
And the embrittlement drops. ~Now f
9 after you put the vessel back in service, does it continue j
i 10 with the same slope as a function of fluence?
i 11 MR. HISER:
You are stealing my thunder.-
l 12 MR. SHAO:
We have a viewgraph on this.
i 13 MR. WILKINS:
All right.
I really am quite 14 ignorant in this matter.
15 MR. HISER:
If I can defer your question for about l
16 another.ouple of slides.
i 17 MR. WILKINS:
All right.
)
18 MR. SEALE:
You are asking a good question.
19
[ Slide.)
20 MR. HISER:
I want to go ahead and describe the 21 proposed or draft reg on annealing.
This reg guide provides 22 guidance on the format and content of applications for.
23 thermal annealing.
24 It describes the criteria that the staff will use-25 in evaluating the application.
It doesn't provide criteria ANN RILEY & ASSOCIATES, LTD.
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1 on annealing.
It provides the criteria that the staff will I'
2 use to evaluate the application.
3 Again, I will describe in a little bit more detail' i
4 on the thermal annealing plan, the requalification program, j
5 the fracture toughness recovery and reembrittlement program 6
and a little bit more on the certification.
i 7
[ Slide.]
8 MR. HISER:
The Thermal Annealing Operating Plan 9
has many parts to it.
Among other things the operating plan-10 should describe some background on the vessel in terms of 11 the operating history, surveillance program results and the 12 reason for annealing.
It would provide a description of the f
13 reactor pressure vessel in terms of the dimensions and the I
14 beltline materials.
l b
15
[ Slide.]
16 MR. HISER:
I mentioned before that besides doing 17 good things to the vessel we want to avoid degrading other 18 parts of the system.
Other equipment, components and l
19 structures have to ce evaluated to ensure that they are not 20 degraded.
21 Some of the specific items that we are interested i
22 in are outlined here along with some of the concerns that we l
23 have.
As an example, the biological shield, loss of l
24 strength and loss of neutron absorption capability are some 25 of the things that we are concerned about.
In addition, i
i l
1
(
l I
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240 l
storage of the core internals during the annealing is l
1 1
2 something that would need to be described.
I 3
[ Slide.]
l j
4 MR. HISER:
The Operating Plan would also provide i
1 5
proposed parameters of annealing and this would be j
6 principally the temperature and time-at-temperature, say 850' 7
degrees Fahrenheit for one week would be an example.
8 It would provide information-on the'heatup and i
9 cooldown rates and also limitations on these parameters.
If 10 your heatup and cooldown rates are too high, then thermal 11 stresses will be too high and that would cause some problems 12 so we want to make sure that there are limits on the 13 parameters.
14 The Operating Plan would also describe'how the 15 annealing is to be performed in terms of the method, 16 instrumentation, operational steps, the temperature control 17 system.
All of these things would be described in the 18 application.
19
[ Slide.]
l 20 MR. HISER:
Now a major part of'the application 21 would involve thermal and stress analysis of the vessel-and 22 the attached piping.
These analyses would be used to 23 establish time and temperature profiles, assess the maximum-24 concrete temperature and would evaluate this whole list of 25 deformations and stresses and effects that are important.
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[
1 Resulting from this analysis would be specific j?'
i 2
limiting conditions in terms of highest temperature, highest.
]
)
3 stress and strain and again.' limiting heatup and cooldown-t 4
rates would result from these analyses, j
^
1 5
[ Slide.]
l
)
j 6
MR. HISER:
Principally based on the results of 1
7 the thermal and stress analyses, the Operating Plan _would q
8 define the proposed ann 2aling conditions and this would f
9 principally be a time and temperature boundary.
So the 1
3 application would describe certain bounds on critical i
10 l
l 11 temperatures that would need to be maintained during the i
i 12 annealing.
{
13 In addition, ALARA considerations would be l
14 included in the Operating Plan and finally, the plan would q
l 15 project the recovery and reembrittlement, a
16 MR. WILKINS:
Now I didn't see in that Operating 17 Plan and perhaps it is someplace _else the procedures for 18 preparing the reactor for the annealing operation.
You did 19 refer to storage of the core internals, for example.
That 20 is the kind of thing I am talking about and also for 21 restoring it after the annealing has been completed.
Is 22 that part of the Operating Plan or is that part of the
{
23 application?
24 MR. SHAO:
That is-part of it.
25
[ Slide.]
)
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-l 1
MR. HISER:
That would be included, we believe, j
2 under the item here, annealing. method, instrumentation and 5
3 procedures.
This would cover all of the operational steps.
l 4
MR. WILKINS:
All right.
That is subsumed in i
5 that.
Thank you.
6
[ Slide.]
7 MR. HISER:
The Requalification Inspection and' r
?
8 Test Program has three main. parts, a monitoring program, an t
9 inspection program and a test program.
The monitoring l
l 10 program is basically intended to assure that the annealing l
11 was within the proposed annealing conditions.
12 The program submitted as a part of the application 13 would indicate what measurements are going to be made during j
'l 14 the annealing, the meastrement frequency and would discuss j
15 the record retention that they would apply.
t 16 The inspection program cou2d involve pre and post-17 rnneal visual examinations of say the vessel,.the vessel-l 18 flange, any critical components and maybe there are some
.)
i l
19 critical deformations that the licensee is concerned about.
20 So they would be described in this program.
21 Another possibility would be some sort of an NDE 22 program for the RPV beltline.
With the augmented inspection 23 requirements that are coming into effect in 10 CFR 50.55 (a),
24 the post-anneal condition might be a good time to do that 25 NDE exam.
i i
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. a
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l 243 l
l 1
The test program would be intended to demonstrate 2
the effectiveness of the annealing and to assure that no l
3 degradation of the vessel and other affected structures, i
i 4
components or equipment occurred.
i 5
So this is intended to demonstrate that we did l
6 good things to the vessel and we didn't degrade any other 7
part of the system.
8
[ Slide. )
j 9
MR. HISER:
I mentioned a little bit earlier the i
10 fracture toughness recovery program.
There are three major 4
I 11 parts to it.
If the licensee has a surveillance program I
12 that is credible according to the PTS ru'e and broken or 13 untested specimens are available, then they are required 14 within the rule to use those specimens to evaluate recovery.
O 15 The thermal annealing application would indicate what their 16 plans are in this area.
l l
17 In addition, the rule has a provision where i
18 licensees may remove material from the vessel beltline to i
l 19 assess the recovery.
That method would be described in this 20 plan.
As a final option, a computational method using a 21 generic equation can be used.
Within the reg guide we do 22 have a model that we are proposing for use.
23 MR. LINDBLAD:
Do I understand that by saying that 24 you really don't want to keep any archival specimens but 25 that you really want to test everything you have with the ANN RILEY & ASSOCIATES, LTD.
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current methods?
2 Many people think that at some time in the future l
l l
3 we will have different tests that will give us different 4
information and iu will be nice to have old archival 5
specimens co work with.
But you are not leaving that open?
6 MR. HISER:
That pretty much would be.on a case-1 7
by-case basis.
Ne would hope that what the licensees l
l 8
propose would not preclude any future improvements in the 9
technology.
We would not require that they test all of f
10 their remaining surveillance specimens as an example.
j l
11 MR. LINDBLAD:
No.
I read that to say "no i
12 specimen shall be left unbroken."
l t
13 MR. HISER:
No.
That was-not intended.
14 MR. LINDBLAD:
I see.
15 MR. HISER:
It is just that there are methods that 16 use an unbroken specimen.
l l
17 MR. LINDBLAD:
What is an untested specimen then?
l l
18 MR. HISER:
They may have extra specimens that l
l 19 were not tested from previous capsules or they may have a 20 capsule that has not been tested yet that could be used for i
21 this evaluation.
t 22 MR. LINDBLAD:
And your program requires them to 23 break it under test.
24 MR. HISER:
It would require them to use some i
25 specimens in that manner, yes.
i i
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l I
245 1
MR. LINDBLAD:
I thought it read "all" specimens.
O.
2 MR. HISER:
No.
It does not read "all."
3 MR. LINDBLAD:
All right Thank you.
1 4
MR. HISER:
Actually, I think we give them a lot 5
of leeway in terms of what they are able to propose and how I
6 they use that data.
7 MR. SHACK:
Do they have the choice or they must l
8 use the surveillance data if they have a surveillance 9
program?
10 MR. HISER:
If they have surveillance specimens 11 and it is a credible program and there are specific criteria 12 on credible, they must use specimens from the program.
13 Now in some cases licensees have trashed their 14 tested specimens in which case it may be a credible program
)
O l
15 but they have no material to use but we would require them i
i 16 to use the material if they have it, not all of it l
17 necessarily but at least in some way.
18
[ Slide.]
19 MR. HISER:
I'come to the Chairman's question l
20 about reembrittlement.
The reg guide suggests that a l
21 lateral shift method is appropriate to project 22 reembrittlement.
Further, a surveillance method is also 23 used to monitor reembrittlement.
Now the lateral shift 24 method assumes the same embrittlement trend as the pre-25 anneal operating period.
1 O
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246.
1 l
1
[ Slide.)
2 MR. HISER:
I will show a cartoon to[ illustrate l
t 3
what we mean by that.
On the left hand side we have the i
4 transition temperature shift, delta RT-NDT and on the right' 5
hand slide, we have Charpy upper shelf energy.
l 6
The initial embrittlement trend is shown here and i
l i
i 7
here at this point, the licensee has performed an annealing l
recovery and in this case is an increase in the. upper shelf 8
9 energy.
In the case of shift, it is a reduction in the i
10 shift.
i 11 If this is the post-anneal shift, this'is the 12 post-anneal upper shelf energy, then the way the lateral i
13 shift method works is that you take this part of the curve t
14 and slide it over to this data point.
So essentially we O
15 just have a lateral shift of each curve.
i 16 MR. WILKINS:
My eyesight may not be as good as it j
i 17 used to be but those curves don't look like that is what you 18 did.
19 MR. HISER:
They are.
I think it is an optical 20 illusion.
21 MR. WILKINS:
All right.
I will concede that.
22 MR. CATTON:
A smoke screen.
23 MR. WILKINS:
But this, in fact, answers the 24 question that I asked.
25
[ Slide.]
(
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I
- 247, 1
1 1
1 MR. HISER:
Now limited experimental data indicate 2
that the lateral shift method bounds the reembrittlement l
i 3
that we have seen.
The analysis is a mean curve analysis 4
and we add only a single margin term on at the end so we are j
5 not adding margin upon margin so we are so excessively l
6 conservative.
7 Within the reg guide, we do have explicit 8
equations for performing the lateral shift.
The 9
surveillance method for that data to be used to monitor i
10 reembrittlement, the results must meet the credible data 11 requirements that are in the PTS rule.
Within the reg j
I 12 guide, we also have some description of using materials test 13 reactor irradiations for specimen preconditioning.
I 14 MR. WILKINS:
Excuse me.
You referred to U.S.
15 data.
Are there foreign data accessible to you?
I had 16 heard that the Russians did a lot of annealing.
17 MR. HISER:
We have limited access to the Russian 18 data.
In a general sense, it is consistent with'what we 19 have for U.S.
data.
The materials and conditions are very 20 different so we can't directly use their results but it 21 confirms the philosophy that we have included in the reg 22 guide.
23
[ Slide.]
)
24 MR. HISER:
Now within the post-anneal
~
25 certification would be a description of the overall ANN RILEY & ASSOCIATES, LTD.
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i l
1 annealing process and principally what we are looking for is j
l i
2 sufficient detail to evaluate the annealing.
i 1
3 Included in the certification report would be I
4 results and evaluation of inspections and tests and also an j
5 evaluation of the effectiveness of the annealing and again, 6
this would include the percent recovery, the reembrittlement i
7 rate and an evaluation of the allowable operating period 8
given those two things.
l 9
That basically is the presentation that I have on 10 this package.
11 MR. SEALE:
Are there any questions?
12 MR. LINDBLAD:
Mr. Hiser, perhaps I missed it in f
13 your presentation but is there any requirement in an j
14 annealing program that both samples be made of the actual O
15 vessel material after annealing?
?
16 MR. HISER:
No.
That is one of the options that i
i 17 licensees have in determining the percent recovery but it is 1
18 not a requirement.
19 MR. LINDBLAD:
Do the small size specimens anneal 20 the same way as the base metal?
21 MR. HISER:
It is purely kinetics based.
22 MR. LINDBLAD:
So size of sample doesn't matter?
23 MR. HISER:
It should not come into play.
We do 24 have some work ongoing at Oak Ridge looking at very large 25 fracture toughness specimens and we will have a confirmation O
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of that but we don't expect that there is any difi, ence.
j 2
MR. LINDBLAD:
But that is assuming solution 1
I 3
annealing complete total annealing rather than a' tempering 4
operation.
Thank you.
5 MR. SEALE:
Bill.
6 MR. SHACK:
You give a long laundry. list on page 7
12 and 13 of the reg guide of the things people should l
8 evaluate but there is no acceptance criteria.
It is very t
9 clear what you do as far as the fracture toughness and 10 recovery.
All this other stuff you compute and there is 11 nothing to tell you, "well, the strains are too large or I 12 should redesign my annealing process to reduce the plastic' 13 strain."
Why no acceptance criteria or is it just too much j
~
l 14 on a case-to-case basis?
15 MR. HISER:
I think it is too much on a case-to-16 case basis and we wanted to keep this a more performance 17 based document.
We 6.on't tell licensees'you have to use 18 this annealing temperature, this annealing time.
It is up 19 to them to propose and evaluate.
So basically what we-20 wanted to do is just make sure that we had covered all of 21 the items that they should look at.
22 MR. SHACK:
But it could be performance based and 23 you could tell them to keep the plastic strain and the 24 piping below and they can anneal it any way they wanted but 25 they would at least know what they have to aim for.
O ANN RILEY & ASSOCIATES, LTD.
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MR. HISER:
They would have to maintain the 2
current ASME code requirements and we feel that is I
3 sufficient in terms of the requirements.
4 MR. SHACK:
Was that actually mentioned?
5 MR HISER:
It may not be mentioned explicitly-but i
6 that is sort of an overriding requirement overall.
7 MR. SHACK:
So it is given?
8 MR. HISER:
Yes.
9 MR. SEALE:
Any other questions?
10
[No response.]
l 11 MR. SEALE:
Could we now hear what the schedule is 12 for the next actions on this particular issue?
13 MR. SHAO:
Hopefully, we are very soon, by the end 14 of the year, we are going to issue it for public comment.
O 15 MR. HISER:
I guess basically at this point'
(
16 assuming that we receive a letter from ACRS concurring in i
l i
l 17 this package, then we are ready to go back for office 1
18 concurrence to the EDO and probably within two or three i
19 months we would out for public comment.
l 20 MR. SEALE:
Is that all?
l l
21
{No response.]
22 MR. SEALE:
If there is nothing else, then I will 23 turn the meeting back over to you, Mr. Chairman.
l 24 MR. WILKINS:
Thank you very much, Mr. Shao and 25 Mr. Hiser.
That was a very interesting presentation.
When l
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W.,
Suite 300 Washington, D.C.
20006 (202) 293-3950 i
i P
r 251 i
1 you can get a mathematician like me to ask questions about O
2 upper shelf enerq2es and embrittlement, you know you got my j
3 attent: ion all right.
I 4
MR. SEALE:
And to be satisfied with the answers.
5 MR. WILKINS:
Well, of course, I am relying on you 6
and Bill to detect any attempt on their part to pull the 7
wool over my eyes and I am sure they didn't try but they I
8 might have succeeded because they assumed I knew more than I l
9 actually did.
10 MR. CARROLL:
I am a little puzzled by that l
l 11 statement.
I thought you also had a degree in mechanical' i
12 engineering.
13 MR. WILKINS:
I do indeed and that is why I can-14 spell "Charpy."
15
[ Laughter.)
16 MR. KRESS:
He doesn't like that~information to I
17 get out.
i 18 MR. CARROLL:
I see.
19 MR. WILKINS:
I like to trap them, you see.
Of 20 course, Larry knows this.
We have a_ proposed letter.
21 MR. SEALE:
Yes.
22 MR. WILKINS:
And we have a few minutes before the 23 next agenda item is supposed to be taken up and the next 24 agenda item probably won't take as long as it has been 25 scheduled anyway so why don't we look at your proposed ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W.,
Suite 300 Washington, D.C.
20006 (202) 293-3950
252 1
letter.
It is in pages 111 and 112 under tab 11.
2 MR. DAVIS:
We don't need the reporter for this,
)
3 do we?
J 4
MR. WILKINS:
That is a good question.
I don't j
5 think we need her and, in fact, I think we can let her go 6
until october.
Let me just make one final-check of the l
7 agenda before I commit myself to that but I believe that is 8
correct.
Yes, that is correct.
There is no requirement.
-j 9
this afternoon and we are completed with the morning session 10 that needs to have transcripts.
Thank you.
11
[Whereupon, at 11:12 a.m.,
the reported portion of f
i 12 the meeting was concluded.]
l l
13
()
15 j
i 16 I
1 17 l
18 19 20 21 22 23 1
24 25 i
O ANN RILEY & ASSOCIATES, LTD.
I Court Reporters 1612 K Street, N.W.,
Suite 300 l
Washington, D.C.
20006 l
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- - - ~ ~. - -.
- -. - -. - - - -. ~ - - - -. -
REPORTER'S CERTIFICATE j
This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING:
401st ACRS Meeting i
i I
DOCKET NLHBER:
Bethesda, MD PLACE OF PROCEEDING:
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken e
by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
s Waulow SMn l
Of ficial Iteporter Ann Riley & Associates, Ltd.
l l
1 l
i O
t
}
!O NRR STAFF PRESENTATION TO THE i
ACRS 4
i fl;
SUBJECT:
PROPOSED GENERIC LETTER ON REMOVAL OF ACCELERATED TESTING AND SPECIAL i
REPORTING REQUIREMENT FOR EMERGENCY GENERATORS FROM PLANT TS
}
j DATE:
SEPTEMBER 10,1993 i
i 4
PRESENTER:
OM P CHOPRA i
!O i
i i
PRESENTER'S TITLE c
l
/ BRANCH /DIV: ELECTRICAL ENGINEER / ELECTRICAL ENGINEERING BRANCH / DIVISION OF
]
ENGINEERING l
1 PRESENTER'S NRC TEL.NO:
504-3265 1
- O i
]
i o
i l
REMOVAL OF ACCELERATED TESTING AND SPECIAL REPORTING REQUIREMENTS l
FOR EMERGENCY DIESEL GENERATORS l
FROM PLANT TECHNICAL SPECIFICATIONS O
...._.,_.m.,__s m.
m..
O BACKGROUND e
DIESEL RELIABILITY ADDRESSED IN GENERIC SAFETY ISSUE B-56.
ALTERNATIVES TO RESOLVE B-56 PRESENTED IN SECY-93-044.
COMMISSION APPROVED OPTION 4.
e O
O DROP ISSUANCE OF THE REVISED SBO RULE.
o ADDRESS DIESEL RELIABILITY IN THE MAINTENANCE PROGRAM AND RELATED REGULATORY GUIDANCE.
O ISSUE A GENERIC LETTER.
I O
1-l
O PROPOSED GENERIC LETTER ALLOWS LICENSEES TO REMOVE ACCELERATED TESTING AND SPECIAL REPORTING REQUIREMENTS FROM TECHNICAL SPECIFICATIONS.
REQUIRES COMMITMENT TO MONITOR DIESEL PERFORMANCE IN ACCORDANCE WITH 10 CFR 50.65 AND REGULATORY GUIDE 1.160.
O REQUIRES ROOT CAUSE EVALUATION AND O
CORRECTIVE ACTIONS FOR ALL DIESEL FAILURES.
DIESEL PERFORMANCE CRITERIA OR GOALS O
COULD BE MONITORED BY NUMARC GUl DANCE TRIGGER VALUES.
O MORE THAN ONE MAINTENANCE-PREVENTABLE DIESEL FAILURE OR FAILURE TO MEET PERFORMANCE CRITERIA WOULD REQUIRE GOALS AND MONITORING UNDER 10 CFR 50.65 (A)(1).
O -
!O j
ELIMINATES SPECIAL REPORTING i
REQUIREMENTS.
i l
i o
CONTINUE TO REPORT FAILURES UNDER i
10 CFR 50 PART 21, PART 50.72, OR PART 50.73.
i i
i i
o LICENSEES WILL MAINTAIN AND USE i
MAINTENANCE (AND TESTING) RECORDS TO DEMONSTRATE COMPLIANCE UNDER i
ilO I
i I
i 1
.! O,
O O
O RES Staff Presentation to Advisory Committee on Reactor Safeguards PROPOSED RULE PACKAGE ON FRACTURE TOUGHNESS AND THERMAL ANNEALING REQUIREMENTS AND GUIDANCE FOR i
LIGHT WATER REACTOR VESSELS 4
i 1
Allen Hiser, Jr.
Fracture and Irradiation Section Materials Engineering Branch j
Division of Engineering September 10,1993 1
j i
O O
O PROPOSED REVISIONS 10 CFR 50.61 - Pressurized Thermal Shock Rule 10 CFR 50 Appendix G - Fracture Toughness Requirements 10 CFR 50 Appendix H - Reactor Vessel Material Surveillance Program Requirements PROPOSED RULE 10 CFR 50.66 - Thermal Annealing Requirements DRAFT REGULATORY GUIDE Reg. Guide on " Format and Content of Application for Approval for Thermal Annealing of RPV" (Draft Guide 1-027) - - -
l l
REASONS FOR THE CHANGES l
Review of Yankee Nuclear Power Station RPV l
NUBARG backfit claim and appeal on requirements for core criticality during pressure and leak testing i
e Commission guidance Comprehensive NRR and RES staff review identified need for
- clarifications
- corrections
- changes for consistency O O
O
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O O
O REVIEW OF YANKEE NUCLEAR POWER STATION Review began in 1990
- focus became PTS and Appendix G issues
'/NPS PTS issues stemmed from method of calculating embrittlement estimates in the PTS rule
- surveillance data
- temperature effects Significant difficulty in using and interpreting the e
PTS regulatory guide (RG 1.154)
- revisions are longer-term items -
REVIEW OF YANKEE NUCLEAR POWER STATION (cont.)
issues -- 10 CFR Part 50 App. G and H e
- process for Charpy USE < 50 ft-lb
- applicable version of ASTM E 185 Reg. process for thermal annealing of the RPV not clear
- criteria undefined opportunity for public participation Commission guidance in SRM to revise and clarify RPV regulations Proposed changes outlined in SECY-91-333, SECY-92-173, and summarized in SECY-92-283 O O
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BACKGROUND AND CONTENT
- Published July 23,1985
- Amended May 15,1991 - resolve inconsistency with Regulatory Guide 1.99, Revision 2 Rule provides embrittlement screening criteria
- Axial welds and base metals: RTPTS < 270 F
- Circumferential welds: RTPTS < 300 F e If RTPTS projected to exceed screening criterion, flux reduction required
- If flux reduction inadequate, fracture mechanics analysis required - 3 years before exceeding criteria i
- i
O O
O PROPOSED REVISIONS TO 10 CFR 50.61 Make RTPTS analysis identical to Regulatory Guide 1.99, Revision 2 -- embrittlement estimates are consistent
- Method for determining initial RTNDT Equation for margin term Incorporate thermal annealing as acceptable option -- greater flexibility to the rule Restructure PTS Rule -- clarity (a) Definitions (b)
Requirements (c) Calculation of RTPTS
_7_
I 10 CFR 50 APPENDIX G l
l FRACTURE TOUGHNESS REQUIREMENTS i
1 O O
O
O O
O 10 CFR PART 50 APPENDIX G FRACTURE TOUGHNESS REQUIREMENTS:
BACKGROUND AND CONTENT Published 1973, last technical amendment 1983 Fracture toughness requirements for ferritic materials of pressure boundary components l
References Appendix G Section lil of ASME Code Requires evaluation of pressure-temperature limits and minimum metal temperature o
Requirements for Charpy upper shelf energy
- 75 ft-Ib pre-service
- 50 ft-Ib throughout the vessel life
PROPOSED REVISIONS TO 10 CFR PART 50 APPENDIX G
- Restructure Sections IV and V of current Appendix G
- P-T limits and minimum temperature requirements identified in a new table
- Procedures for Charpy USE below 50 ft-lb
- " Equivalent margins" analysis, 3 years before < 50 ft-Ib
- Additional fracture toughness data "may be obtained" for inclusion in analysis
- Delete requirement for volumetric inspection -
augmented inspection requirements (ASME Code Appendices Vll & Vill) already required under 10 CFR 50.55a e
e
O O
O PROPOSED REVISIONS TO 10 CFR PART 50 APPENDIX G (cont.)
Specifically require that pressure and leak tests required by ASME Code be completed prior to core criticality Implements CRGR recommendation to the EDO June 7,1990
- NUBARG backfitting claim and appeal
- Safety concerns:
- hindrance of finding leaks at high temperature
- Delete the " design to permit annealing" requirement
- Change reference from Appendix G of Section lil to Appendix G of Section XI of the ASME Code
- Delete existing annealing language and reference the proposed thermal annealing rule
. 1
_-___,y,,g, 1
10 CFR 50 APPENDIX H f
REACTOR VESSEL MATERIAL SURVEILLANCE PROGRAM REQUIREMENTS 9
9
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CONTENTS OF 10 CFR PART 50 APPENDIX H REACTOR VESSEL MATERIAL SURVEILLANCE PROGRAM REQUIREMENTS Material surveillance program required to e
monitor irradiation embrittlement of the RPV beltline materials References ASTM Standard E 185 Integrated surveillance programs
PROPOSED REVISIONS TO 10 CFR PART 50 APPENDIX H Clarify versions of ASTM E 185 for various portions e
of surveillance program
- "The design of the program and the withdrawal schedule must meet the requirements of ASTM E 185-73 or the editio.a of E 185 that is current on the issue date of the ASME Code to which the RPV was purchased" Discontinue provision for reducing amount of testing e
in integrated surveillance programs when " initial results agree with predictions" O O
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PROPOSED RULE AND DRAFT REGULATORY GUIDE ON THERMAL ANNEALING 4 '
i i
DESCRIPTION OF THERMAL ANNEALING
- Thermal annealing achieved by heating RPV to temperature higher than operating temperature
- For commercial LWR:
650-850 F,168 h
- Thermal annealing " recovers" embrittlement caused by neutron irradiation
- Higher annealing temperature or (Tanngat - Topen) gives greater recovery
- Annealing can
- Restore upper shelf energy
- Reduce RTNDT and RTPTS
- Widen P-T curve " operating window" #
i
O O
O NEED FOR THERMAL ANNEALING REGULATION AND REGULATORY GUIDE e Existing Appendix G addresses annealing only in context of 50 ft-lb criterion
- annealing also appropriate to reduce RTNDT
- Appendix G requirements on annealing inadequate
- evaluation of recovery from materials tests only
- method not practical in all cases
- no requirements on engineering aspects
- Proposed annealing of Yankee Nuclear Power Station
- highlighted need for more complete regulatory framework i
I I :
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PROPOSED RULE ON THERMAL ANNEALING 10 CFR 50.66 i
i
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O OVERVIEW OF PROPOSED ANNEALING RULE 1
Application for Thermal Annealing e
- F abject to approval by the Director, NRR
- Submitted three years prior to anneal 4
Certification of Annealing Effectiveness 19-4
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CONTENTS OF THERMAL ANNEALING APPLICATION Thermal Annealing Operating Plan
- Proposed annealing parameters (time and temp.)
- Proposed method and procedures for annealing
- Assess equipment, components and structures affected
- Thermal and stress analyses
- ALARA considerations
- Project recovery and reembrittlement Requalification inspection and Test Program
- Monitoring, inspection, tests Demonstrate proposed annealing conditions not exceeded
- Define actual annealing time and temperature Fracture Toughness Recovery and Reembrittlement Rate Assurance Program
- Use available surveillance specimens if " credible"
- Can take beltline samples
- Can use computational model if justified O O
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CERTIFICATION OF ANNEALING EFFECTIVENESS Certify that annealing was performed within the proposed annealing conditions
- Provide post-anneal RTNDT and Charpy upper shelf energy values
- Estimate reembrittlement trends for RTNDT and Charpy upper shelf energy
- Project RTNDT and Charpy upper shelf energy for end of proposed period of operation if cannot certify, submit justification for subsequent e
operation
- Approval by Director, NRR, required before restart -
DRAFT REGULATORY GUIDE 1-027:
FORMAT AND CONTENT OF APPLICATION FOR APPROVAL FOR THERMAL ANNEALING OF REACTOR PRESSURE VESSELS"
-2 2-O O
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O O
O DESCRIPTION OF DRAFT REGULATORY GUIDE 1-027 e
Provides guidance on format and content of applications for thermal annealing e
Describes the criteria that the NRC staff will use in evaluating annealing applications o
Elaborates the provisions of the thermal annealing rule
- Thermal Annealing Operating Plan
- Requalification inspection and Test Program
- Fracture Toughness Recovery and Reembrittlement Rate Assurance Program
- Certification THERMAL ANNEALING OPERATING PLAN
Background
- Reason for annealing
- Plant operating history
- Surveillance program results
- May use reference to prior submittals e
Description of RPV
- Dimensions
- Beltline materials
- Identification of regions to be annealed O O
O 2
m A
O O
O THERMAL ANNEALING OPERATING PLAN Leont.)
- Equipment, components and structures affected
- Biological shield Loss of strength, neutron absorption
- Concrete
- Design temperature
- Properties irradiated concrete a
- Piping
- Description (materials, dimensions, restraints)
- Design requirements
- Known indications of potential flaws
- Other equipment or instrumentation
- Storage of core internals
- Overall layout of containment
- Coffer dam (if needed),
THERMAL ANNEALING OPERATING PLAN (cont.)
Proposed parameters of annealing Target temperature, time-at-temperature Heatup and cooldown rates Limitations on those parameters
- Annealing method, instrumentation and procedures Operational steps Temperature control system Measurement accuracy and reliability Radioactive contamination controls e
o
-27,
O O
O THERMAL ANNEALING OPERATING PLAN (cont.)
e Thermal and stress analysis Establish time and temperature profiles Maximum concrete temperature Should evaluate
- Residual deformations
- Residual stresses
- Elastic-plastic creep effects
- Distortions and bending
- Piping displacements
- Effects of thermal gradients
- Effects of restraints (nozzles, piping)
Specify limiting conditions
- Highest temperature
- Highest stress and strain
- Limiting heatup and cooldown rates.
THERMAL ANNEALING OPERATING PLAN (cont.)
Define the proposed annealing conditions e
Time and temperature boundary
- ALARA considerations In accordance with 10 CFR 20.1206 Focus on occupational exposure Other considerations should be addressed
- Projected recovery and reembrittlement G
G
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4 q
O O
O REQUALIFICATION INSPECTION AND TEST PROGRAM e Monitoring program Assure annealing within proposed annealing conditions What to measure (temperatures, strains, deflections, etc.)
Measurement frequency during heatup, steady-state and l
cooldown Record retention e inspection program
. Pre-and post-anneal visual examination NDE program for the RPV beltline e Test program Demonstrate effectiveness of annealing Assure no degradation of RPV and other affected structures, components or equipment 29-v.,
-n.
.-a
EVALUATING FRACTURE TOUGHNESS RECOVERY
- Vessel surveillance program method
- Broken or untested specimens
- Irradiated vessel material method
- Material removed from the vessel beltline
- Computational method
- Generic equation 9
9
- - - ~
a
- - - a-----
^
^ o o
o GUIDANCE FOR REEMBRITTLEMENT RATE ASSURANCE PROGRAM e
" Lateral shift"
- Same embrittlement trend as pre-anneal operating period
- Limited US data indicate reembrittlement bounded by initial embrittlement trend
- Analysis is "mean curve" analysis plus margin term
- Explicit equations provided
- Surveillance method
- Results must meet credible data requirements in PTS rule
- Use of MTR irradiations for specimen preconditioning - -
LATERAL SHIFT METHOD LATERAL SHIFT METHOD Annealing g Initial USE initial Embrittlement Rate Recovery 3
Post-Anneal Condition
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1.ateral Shift Reembrlitlement Rate
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Recovery b
Post-Anneal Condition I
2 Fluence (n/cm, E > 1 MeV)
Fluence (n/cm, E > 1 MeV) 2 e
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O O
O POST-ANNEAL CERTIFICATION e
Description of the overall annealing process Details sufficient to evaluate the annealing e
Results and evaluation of inspections and tests i
e Annealing effectiveness:
Percent recovery Reembrittlement rate Allowable operating period
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