486th Meeting - October 5, 2001

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               486th Meeting

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Friday, October 5, 2001

Work Order No.: NRC-039                             Pages 266-396

                   NEAL R. GROSS AND CO., INC.
                 Court Reporters and Transcribers
                  1323 Rhode Island Avenue, N.W.
                     Washington, D.C.  20005
                          (202) 234-4433.                         UNITED STATES OF AMERICA
                                 + + + + +
                            486TH ACRS MEETING
                                 + + + + +
                              OCTOBER 5, 2001
                                 + + + + +
                            ROCKVILLE, MARYLAND
                                 + + + + + 
                       The Advisory Meeting met at the Nuclear 
           Regulatory Commission, Two White Flint North, Room 
           2B3, 11545 Rockville Pike, at 8:30 a.m., Dr. George E.
           Apostolakis, Chairman, presiding.
                 DR. GEORGE E. APOSTOLAKIS, Chairman
                 DR. MARIO V. BONACA, Vice Chairman
                 DR. DANA A. POWERS, Member
                 DR. WILLIAM J. SHACK, Member
                 DR. THOMAS S. KRESS, Member at Large
                 DR. JOHN D. SIEBER, Member
                 DR. F. PETER FORD, Member
                 DR. GRAHAM  B. WALLIS, Member
                 DR. STEVEN L. ROSEN, Member.           ALSO PRESENT:
                 DR. NOEL DUDLEY, Executive Secretary
                 SAM DURAISWAMY, 
                 Designated Federal Official
           ACRS STAFF:
                 DR. JOHN T. LARKINS, Executive Director
                 RAJ AULICK
                 CHRIS GRIMES
                 BARRY ELLIOT
                 LIZ THOMPSON
                 JACK SORENSEN
           .                                 I-N-D-E-X
                          AGENDA ITEM                      PAGE
           Opening Remarks by ACRS Chairman . . . . . . . . 269
           Interview Review of the License Renewal. . . . . 271
                 Application for the Turkey Point Nuclear 
                 Power Plant and Westinghouse Topical 
                 Reports Related to License Renewal
           Subcommittee Report by Dr. Ford. . . . . . . . . 340
           Presentation by John Sorensen on Safety. . . . . 360
                 Culture and Risk-Informing General
                 Discussion Design Criteria
           .                           P-R-O-C-E-E-D-I-N-G-S
                                                    (8:30 a.m.)
                       CHAIRMAN APOSTOLAKIS:  The meeting will
           now come to order.  This is the second day of the 
           486th meeting of the Advisory Committee on Reactor
                       During today's meeting the Committee will
           consider the following:
                       Interim Review of the License Renewal
           Application for the Turkey Point Nuclear Power Plant
           and Westinghouse Topical Reports Related to License
                       The Report of the ACRS Subcommittee on
           Materials and Metallurgy; Draft Report on Safety
           Culture and Risk-Informing General Design Criteria;
           Future ACRS Activities/Report of the Planning and
           Procedures Subcommittee.
                       Reconciliation of ACRS Comments and
           Recommendations; Preparation for Meeting with the NRC
           Commissioners; and Proposed ACRS Reports.
                       This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Mr. Sam Duraiswamy is the Designated
           Federal Official for the initial portion of the
                       We have received no written comments or
           requests for time to make oral statements from members
           of the public regarding today's sessions.  A
           transcript of portions of the meeting is being kept,
           and it is requested that the speakers use one of the
           microphones, identify themselves, and speak with
           sufficient clarity and volume so that they can be
           readily heard.
                       I have an announcement.  Ms. Jesse Delgado
           joined the ACRS/ACNW staff on September 10th, 2001. 
           Jesse, would you stand up.  Jesse has worked for the
           NRC for the past 13 years, and 7 years with the
           Division of Reactor Projects, and 6 years with the
           Events Assessments Generic Communications, and Non-
           Power Reactors Branch, NRR.
                       Due to national emergencies, she has been
           providing part-time support to the Incident Response
           Center.  She is the newly elected Court Chair of the
           Hispanic Employee Program Advisory Committee, and on
           behalf of my colleagues, I welcome you to the staff. 
           Now you can sit down, dear.
                       The first item on our agenda is the
           Interim Review of the License Renewal Application for
           the Turkey Point Nuclear Point Plant and Westinghouse
           Topical Reports related to license renewal, and our
           expert on the subject is Dr. Mario Bonaca.  Mario,
           it's yours.
                       DR. BONACA:  All right.  Good morning.  We
           met on September 25th to review -- the subcommittee on
           license renewal met on September 25th to review the
           application on Turkey Point and the SER, and we found
           the application quite complete and scrutable. 
                       We directed the staff to come in and give
           us some specific insights on some points at the end of
           the presentation by the staff and the licensee.  
                       I will also give you some perspectives on
           the subcommittee, and the recommendation for what we
           should be doing with the report, and whether or not we
           should have an interim report or just a final report.
                       And I can tell you right now that the
           recommendation from the Subcommittee was that we would
           not have an interim report now, but wait for all the
           open items to be closed, and then have a final letter
                       And the reason is that there are only four
           open items and we did not identify other issues that
           would cause for us to delay the SER.  With that, I
           will pass it on to the staff so that we can hear a
           presentation from the staff.
                       MR. AULICK:  Good morning.  I am Raj
           Aulick, and I am the project manager for the Division
           of Application for License Renewal for Turkey Point.
                       I would like to make one point that Mr.
           Steve Koenick, who is not here, and he is my backup
           project manager, has been a great help in the
           preparation of this SER.
                       At this point I would like to briefly
           summarize the status of the staff's review of the
           Turkey Point License Renewal Application.
                       The application was received a little over
           a year ago, and this was the fifth application
           received by the NRC, and three applications have been
           approved so far.  
                       This is the first Westinghouse BWR, and it
           is a two unit site, and each unit is designed for 2300
           megawatt thermal.  The site is shared by two oil and
           gas fired engineering plants.
                       The plant is located in Florida City,
           about 25 miles from Miami, and about the same distance
           from the Florida Keys.  The license for Unit 3 expires
           on July 19th, 2012, and for Unit 4, on April 10th,
           2013.  The application was requesting a 20 year
           extension of the licenses.  
                       DR. BONACA:  One observation purely for
           information for the members.  This is the first plant
           that has a turbine building.  It does not have an
           external enclosure.  
                       Now, that doesn't mean anything negative
           regarding the equipment, but simply that it is a
           different environment from what we have seen in
           previous applications, and it was interesting for us
           to look at it in that respect, and maybe the staff can
           comment on that at some point, and if that created any
           different environment for materials, and different
           kinds of aging mechanisms.
                       MR. AULICK:  No, I think they have a
           design to address those things, and the equipment was
           designed for weather, for rain and weather conditions.
                       The review schedule is based on a 30 month
           schedule, and this was originally issued with an
           acceptance letter on this application in October of
           2000.  As noted, the SER with open items was issued in
                       DR. POWERS:  Can you tell me how you set
           up these schedules?
                       MR. AULICK:  Yes, please?
                       DR. POWERS:  Can you explain to me how you
           set up these schedules?
                       MR. AULICK:  Basically, when we received
           the application, we had certain templates based on our
           previous experience, and we sat down with the staff,
           and --
                       DR. POWERS:  Well, where is your previous
           experience on license renewal for PWRs?
                       MR. AULICK:  Mostly the experience has
           been done with -- you know, a little more extended,
           but previous ones have been 25 months with no hearing. 
           But this was much shorter because of fewer open items.
                       And I was going to make a point that as
           you can see there are fewer open items, and the
           applicant has requested to move up the review schedule
           since it has been decided that there is no hearing on
           this plant.
                       So we are in the process of discussing
           with the applicant and with the internal staff
           internally that we will support the preparation of the
           final SER.  So we hope to issue a revised schedule and
           a recommendation to the Commission in the next few
                       And as time goes and we gain more
           experience, we will look at the schedule and the staff
           loading, and --
                       DR. POWERS:  Well, I just can't help but
           wondering if you were pressed to do these in record
           breaking time doesn't lead to perfunctory reviews, and
           that's why we have fewer and fewer open items and
           issues being raised.
                       MR. GRIMES:  Dr. Powers, this is Chris
           Grimes.  My observation is that we set out with the
           first application to use a 30 month review schedule
           with a hearing, and when the Commission denied a
           hearing, we went to a 25 month scheduled for Calvert
           Cliffs and Oconee, and we used all of that time.
                       And with the later reviews, we have found
           that we are using about the same amount of time for
           the body of the review, and so about the same level of
           effort is going in, and it is getting -- more
           attention is focused to the sensitive areas of the
           review, or the areas where the guidance has some
           controversy to it.
                       So I don't think that the review process
           is speeding up so much.  We are seeing the improvement
           in the schedule as Raj mentioned at the back end,
           where with fewer open items to resolve there is less
           time required to address the open items.
                       But I don't think that the fewer open
           items are a reflection of any rush to finish the jobs. 
           I would observe for the applications received in 2001
           that it has been largely a workload management problem
           because the applications came in closer together, and
           we have to do about the same amount of work overlaid
           on top of each other.
                       And so we are finding that moving
           milestones around in order to spread the work in a
           more effective way is our major challenge.  
                       MR. AULICK:  Any more questions on the
                       DR. BONACA:  I have a question in general,
           and not so much specifically to Turkey Point, but it
           is apparent to me that from application to application
           every applicant seems to be very -- I mean, reviewing
           every request for additional information from previous
           applicants, and then trying to prevent an open item on
           some issues.
                       This process is happening and of course it
           will be expected.  So do you have any projection if
           this is going to at some point -- you know, once
           applicants begin to use the GALL report as a reference
           document, and the SRP as a guidance for format, and
           then there is a lot of lessons learned that they can
           use, what is the optimal time that you can imagine
           that it will take for an application to be thoroughly
                       MR. GRIMES:  This is Chris Grimes.  At
           this point, we have just -- we are nearing the
           completion of the demonstration project, where we have
           exercised a generic aging lessons learned, and we have
           tried to get some insights, in terms of further
           lessons to improve the guidance and the efficiency of
           the process.
                       And I am still inclined to stick with the
           20 month product schedule until we have gotten through
           at least the class of 2001, and perhaps even the 2002
           applications, before we have enough data to really get
           a good picture about the optimal review schedule.
                       As I mentioned before the review schedule
           seems to be driven more in terms of the proximity of
           applications, one to the other, than it does with the
           effectiveness of the guidance to perform the reviews.
                       And we would hope that we will get some
           feedback and experience from the recently completed
           standard review plan, and regulatory guide, that would
           help us to develop an optimum schedule for the future,
           but I still think that right now that 20 months for
           the product schedule looks like a good working model,
           at least for the initial plan.
                       One of the other things that we have
           considered is using the acceptance review as a basis
           to try and custom design review schedules based on an
           expectation about how much or the value of the
           application of the improved renewal guidance.
                       And right now we are concentrating on what
           we can do to optimize resource utilization more than
                       DR. BONACA:  Well, I asked the question
           with specific interest to the ARCS workload, because
           we see these applications coming, and in fact more
           effectively being formatted, and are more scrutable,
           and it is easier for us to review them, and we find
           less open items.
                       So I just was wondering what kind of
           impact there is.  I am sure that Noel Dudley here is
           aware of that, and so what you are telling me right
           now for the foreseeable future is that the pace of
           reviews you expect to me pretty much the same as you
           have had in the past?
                       MR. GRIMES:  Yes, sir.
                       DR. BONACA:  Thank you.
                       MR. AULICK:  The next slide.  FPL has
           actively participated in industry groups on license
           renewal, including the Westinghouse Owners Group. 
           Four reports were submitted by the Westinghouse Owners
           Group for staff review.
                       The safety evaluation on the staff topical
           reports are intended to be stand alone documents, but
           in the case of Turkey Point, they were not
           incorporated by reference in the application, because
           at the time of the Turkey Point application the staff
           review on these reports was not complete.
                       And Mr. Barry Elliot will speak on the
           staff's evaluation on these reports later on this
                       DR. BONACA:  I have a question on this. 
           We reviewed four WCAPs, and they were the ones that
           are not referenced, but they are used in the
           application, or at least there is a discussion there
           about the applicability.
                       However, through the application there is
           some discussion of other WOG reports.  For example,
           license renewal application procedure.  Are there
           other Westinghouse Owners Group Reports that have been
           developed in support of license renewal?  That is the
           question that I have.
                       MR. ELLIOT:  Westinghouse developed an
           overall basis document for license renewal.  We were
           not asked to review that.  And also Westinghouse
           initially -- and specific to Turkey Point, they
           prepared a report on underclad cracking, and impact
           and fatigue crack growth.
                       Those are the two that I know about that
           we didn't discuss, but we discussed a little bit at
           the last meeting -- it was on the WCAP on underbleed
                       The general one is used by everybody in
           all of the Westinghouse-type plants as a basis for
           their integrated plan assessments.
                       DR. BONACA:  Okay.  I understand now
           because it wasn't clear, and I saw some reference to
           the document listed in the SER, I think, and so I was
           curious about that.  We did not review that and you
           did not review that?
                       MR. ELLIOT:  Right.
                       DR. BONACA:  Okay.  Thank you.
                       MR. AULICK:  As part of our review the
           staff identified four items, four open items, and
           these are -- the first one is scoping of seismic II/I
           Piping Systems.
                       The staff reviewed the information
           provided in the application and responses to the
           staff's questions in this area.  The staff did not
           agree with the applicant's scoping criteria for
           Seismic II/I Piping Systems.
                       The staff's position is and has always
           been that Seismic II/I piping systems should be within
           the scope of license renewal.  This is the same issue
           which was an open item on Hatch, Plant Hatch.
                       And we had requested the applicant, the
           Florida Power and Light, to wait until a resolution is
           reached on that plant, and then we will pursue that. 
           Now the resolution has been reached on the Plant
           Hatch, and so we have started discussions with the
           applicant to resolve this issue.
                       DR. BONACA:  There are some differences,
           however, between Hatch and Turkey Point, right?
                       MR. AULICK:  The way they approached the
           II/I issue, in the case of Turkey Point, what they
           have done is they have -- since the location of the
           non-safety system which could impact the safety of
           their system is depending on the locations.
                       So what they have done is they have gone
           with an area approach, and as a result, they came up
           with 8 or 9 areas where the systems are located, and
           then they are going to go and analyze the scoping and
           screen those structures which could impact.
                       So I think that Hatch addressed this issue
           a little differently, and so we are --
                       DR. BONACA:  I thought Hatch has
           seismically qualified supports and Turkey Point does
                       MR. AULICK:  No, Turkey Point also has
           seismic approval, but the piping portion is not
                       DR. BONACA:  I think that in Turkey Point
           the seismic supports are in scope?
                       MR. AULICK:  They are in scope.
                       DR. BONACA:  All right.  I understand.  
                       MR. AULICK:  So at this time now we have
           started discussions and they are going to look at the
           piping portion of the systems.  The next issue is the
           Reactor Vessel Head Ally 600 Penetration Inspection
                       In the LRA the applicant specified that
           this inspection program is designed to manage the
           aging effects of cracking due to stress corrosion in
           the reactor vessel head penetration nozzles.
                       Recently -- and I think earlier this year,
           the reactor coolant pressure boundary leakage from the
           vessel had penetration nozzles that were identified at
           a few plants.
                       And the staff has asked what is industry
           doing to resolve this current license issue, and
           consider this an emerging issue.  The staff expects
           that the applicant will augment the scope and
           attributes of the inspection program consistent with
           the resolution reached by the industry group.
                       Based on our discussions with the
           applicant, they will wait and agree with that.  So
           once that commitment is made, I think we will consider
           this issue to be resolved.
                       DR. BONACA:  Could you tell us just
           briefly what their plans are for inspections
           consistent with NEI activities?  Are you going to do
           that later?
                       MR. ELLIOT:  Well, I think that Turkey
           Point 3 -- and actually I am not the reviewer of the
           bulletin response, but I have some idea.  I think that
           Turkey Point 3, the next outage is committed to do a
           head inspection, and I think --
                       MR. AULICK:  It is this month.
                       MS. THOMPSON:  Yes.  This is Liz Thompson
           from FPL.  Actually, Turkey Point Unit 3 shut down
           over this past weekend for a scheduled refueling
           outage, and we anticipate performing the head
           inspections, 100 percent visual, on Unit 3 this
           weekend, which it is scheduled for.
                       And then Turkey Point Unit 4 is scheduled
           for a refueling outage in the spring, and we will
           perform the same inspection there is what is planned.
                       DR. SHACK:  Have you been performing
           visual inspections of the head?
                       MS. THOMPSON:  Visual inspections as
           accessible.  We do have some insulation to remove, but
           being a Westinghouse plant, that is an easier task
           than what some of the CE plants are dealing with,
           where their insulation design is quite different.  
                       So we are making some special preparations
           and we do have --
                       DR. SHACK:  Your insulation design is
           what, reflective metal, or --
                       MS. THOMPSON:  I am not familiar with the
           details of it.  I am not handling that myself, but I
           understand that we are going to be able to get in
           there.  We do have some remote equipment that can go
           in and help keep the doses down for performing the
                       DR. BONACA:  Is this the first time that
           you inspected the head?
                       MS. THOMPSON:  We have not inspected
           mechanical connections as part of our regular RCS
           leakage monitoring condition.  And of course if
           anything is identified, it gives us the opportunity to
           look further.  So that is really the starting point.
                       DR. SHACK:  Do you have a history of
           canopy sealed weld leakage?
                       MS. THOMPSON:  We have had canopy sealed
           welds leaking, yes, as well as Inconel leaks.  And we
           have done substantial cleanup of the reactor heads. 
           We did have a substantial leak in the mid-to-late
           '80ish time frame, and I think we have implemented
           substantial improvements to our program and our
           ability to detect.
                       And we are very, very sensitive to really
           any primary side, non-I-soluble, RCS leakage
                       DR. BONACA:  Okay.  Thank you.
                       MR. AULICK:  I will go to the next one of
           the open items, the reactor vessel underclad cracking. 
           In Chapter 4 of the LRA the applicant stated that a
           generic evaluation of the underclad cracks has been
           extended to 60 years using fraction mechanics
           evaluation based on a set of design cycles and
           transients, with occurrences to cover 60 years of
                       They also stated that these design cycles
           and transients, which are contained in the
           Westinghouse Report 15238 -- and this is the one that
           you mentioned which is not part of the topical report
           -- bounds the Turkey Point Units 3 and 4.
                       Therefore, the conclusions of the WCAD and
           WCAP are applicable to Turkey Point.  Now, this report
           is under staff review, and it is in the concurrence
           process, and we hope to issue the final safety
           evaluation sometime this month.
                       So once this report is issued, and as a
           result of the review, if there are any plant specific
           requirements identified, the applicant will need to
           meet those plant specific requirements to resolve this
                       The last open item is acceptance criteria
           for field erected tanks internal inspection.  This is
           a new program which is used for managing the aging
           effects of loss of material due to corrosion of tanks.
                       And the tanks in question are two
           condensate storage tanks, and two refueling water
           storage tanks, and one shared demineralized water
           storage tank.  
                       DR. BONACA:  The question that I have on
           this is that there are discussions -- I mean, as we
           discussed at the subcommittee meeting, there are five
           -- the applicant presented five, one-time inspections,
           and two periodic inspections as new programs.  
                       Of those, there is a proposed one-time
           inspection of tanks, and now if I remember the CSD,
           the condensate storage tank, are exhibited before
           corrosion of some kind of welds and coating
           degradation of several areas.
                       And so the question I have is the open
           item regarding the justification for this being a one-
           time inspection?
                       MR. AULICK:  Open-item.  We asked that
           question and the response was that that degradation in
           the condensate storage tank was because of operating
           experience and poor workmanship to the fabrication.  
                       And it was more flaking and so they have
           taken care of that problem, and we also asked that
           once this program is delivered what will be the
           acceptance criteria for a one-time inspection for the
           next follow-up.
                       DR. BONACA:  Are you accepting that this
           not going to be happening again?  I mean --
                       MR. AULICK:  Well, that is an open item,
           except --
                       DR. BONACA:  So the one-time inspection is
           an open item?
                       MR. AULICK:  Yes, and what will trigger
           the follow-up action once degradation is noticed.
                       DR. BONACA:  Okay.  Because my sense from
           the open item was that this was more than this, and
           you wanted to have some programmatic elements, such as
           depth of -- well, some indications of what would
           prompt additional inspections. 
                       MR. AULICK:  That will be part of the
           acceptance criteria.  
                       DR. BONACA:  Well, why would you go for a
           one-time inspection when you already have corrosion in
           the past?  I mean, you have to be sure that that has
           been taken care of forever, and I don't understand how
           you can do that.
                       MR. AULICK:  Well, according to the
           applicant, it was not -- there were some operational
           history probably, and system errors, and some other
           water which added to the degradation of the paint.
                       They have analyzed it, and they believe
           that it is -- and they have inspected under the tank,
           and they did not find any corrosion or any
                       DR. BONACA:  Well, I thought that the DWST
           and the RWST have never been inspected?
                       MR. AULICK:  No, DWST has been inspected. 
           I think it was maybe not complete information, but the
           RWST has not been inspected.
                       DR. BONACA:  I think you should correct
           the SER.  The SER says it was not inspected.
                       MR. AULICK:  We can do that, yes.
                       DR. BONACA:  And how can you then
           understand the basis for justifying a one-time
           inspection when some of the tanks have never been
           inspected, and that some have been inspected found
           some corrosion.  
                       There may be some unique reasons why you
           have those, and I accept that, but still the basis for
           a one-time inspection is purely to confirm that
           something is not happening.
                       MR. AULICK:  Well, that's it exactly,
           because we expect not to find anything.  And maybe FPL
           wants to add on the reasons for the degradation on the
           storage tank?
                       MS. THOMPSON:  I can do that.  Liz
           Thompson again from FPL.  The condensate storage tanks
           in the earlier years of operation had a situation
           where we actually recirculated some steam back into
           the tank, and the steam caused the coating
                       That was identified through an inspection,
           and the inside of both tanks basically have been
           stripped and recoated over the years to standards that
           meet our standards today.  
                       And based on that we considered what
           occurred on the condensate storage tanks to be
           somewhat of a unique situation.  The DWST, the
           demineralized water storage tanks, and the RWSTs, did
           not experience any similar type operating conditions.
                       Of course, we have also changed our
           operating practices.  We don't allow that to occur
           anymore to protect the coatings on the inside of the
           condensate storage tanks.  
                       And we have done an inspection as Raj has
           mentioned in the DWST.  So based on that, we don't
           believe we are going to find degradation occurring,
           and the one-time inspection is basically to confirm
                       As with all of our programs, in the event
           that we do find something, then we apply our
           corrective action program, which would go back and
           assess whether or not we need to take further action
           other than just correcting any particular condition
                       DR. BONACA:  So the plan is to inspect all
           the tanks once, and if you find something, then you
           would have to address it by changing the one-time
           inspection to a periodic?
                       MS. THOMPSON:  Yes.
                       DR. BONACA:  Okay.  I have another
           question regarding these one-time inspections or new
           programs.  If you look at the application, there are
           seven new programs.  
                       When I read the correspondence between the
           staff and the applicant, I found that on -- I believe
           on the medium and low voltage cables that there was a
           concern with adverse localized effects of heat in
           containment, and that the applicant agreed to develop
           a new program for those.
                       MR. AULICK:  Yes, that is correct.
                       DR. BONACA:  Now, that program is not
           identified in the application, because the application
           made by the applicant did not have the program
           included in it.  
                       And I have trouble in understanding -- I
           would have to go through the SER and all the
           correspondence to find how many new programs there are
           that are not in the application because they were
           developed as part of the RAI and negotiations between
           the staff and the applicant.  Where am I going to find
           this information?
                       MR. AULICK:  I think looking back that it
           probably would have been in the first chapter, and we
           could have stated that in addition to the new programs
           in Section 3.8, that another new program was
           developed.  So up front and in the summary.
                       DR. BONACA:  Yes, I would like that very
           much.  I mean, I think it would be very helpful for a
           reviewer to understand what you have developed as a
           result of the interaction between the staff and the
           applicant so that one has a global perspective of what
           the new programs are.  
                       I have seen only that one and that was not
           listed among the new programs in the application. 
           There may be others, and --
                       MR. AULICK:  No, this was the only one. 
           I debated on this as well in doing it in Section 3.8,
           but since the questions were being asked on Section
           3.7, I decided to keep it there.  But I think we could
           have highlighted in the Chapter 1 summary.
                       DR. BONACA:  Well, certainly that is a
           recommendation that I would like to provide for
                       MR. AULICK:  I think that helps.
                       DR. BONACA:  Because after I read that, I
           was left with the question of what have I missed. 
           There are additional programs that I haven't seen. 
           All right.  You are telling me that is the only new
                       MR. AULICK:  That is the only new one,
           right, which is not in the sections.
                       DR. BONACA:  Thank you.
                       MR. AULICK:  The next slide is on
           inspection activities.  As part of the staff review,
           two team inspections and one audit were conducted on
           the Turkey Point site.  The teams reviewed several
           scoping and screening documents, and the team also
           reviewed several AMR supporting documents for the new
           and existing programs.
                       The team concluded that these documents
           were complete and easy to follow.  The team also
           walked down to a selected system to assess the overall
           condition of the plant.  FPL prepared --
                       DR. BONACA:  I thought you had a meeting
           also in 2000, the year before?
                       MR. AULICK:  Yes, an audit was done and it
           was done in November.
                       DR. BONACA:  An audit?  Okay.  So you had
           four visits.
                       MR. AULICK:  Four visits, but the last
           visit was one, but we divided it into two weeks.  But
           there were four visits, correct.  To assist the staff
           in their review, the FPL staff, several documents were
           prepared, called "Quality Instructions."
                       These provided step-by-step instructions
           for the review of systems and structures applications,
           and specifically, QI Instruction 5.3, which identified
           those systems and structures which are within the
           scope of license renewal.
                       They also developed another document which
           tells you procedures for screening those components
           and structures that will require an AMR, and the
           screening methodology pretty much follows NEI 95-10.
                       And another document that was prepared was
           for procedures for guidance and performing aging
           management reviews.  And another document which was
           prepared was instructions and guidance for identifying
           and evaluating TLAAs.
                       The teams looked at some of these
           documents and found them to be very useful.  And the
           teams prepared these technical documents for their
           staff, and professional license renewal applications. 
           FPL created a license renewal group.  This is a group
           composed of about 30 members.
                       And all these staff members were given job
           specific training which was required and documented
           and this was all under the QA program.  And all
           support engineering staff at the plant sites were also
           given training under the engineering training program,
           which is also documented.
                       And special presentations were made to the
           management and other staff personnel.  Now, as part of
           their work, license renewal boundaries have been
           marked on the plant drawings, and design control
           procedures have been revised, including the checklist
           to include the license renewal to ensure that proposed
           changes do not impact the license renewal
                       And I mention this because this was raised
           at the subcommittee meeting on the training and
           qualification of the personnel preparing the
           application, and how they relate to the on-site
                       DR. BONACA:  Is this the first application
           that was made available in this binder with the PNIDs
           attached to them?
                       MR. AULICK:  No, all the data that are
           highlighted --
                       DR. BONACA:  Because for the others they
           were not as accessible at this time.  We have these
           convenient binders here with all the information.
                       DR. ROSEN:  Is this the first application
           also to provide a CD-ROM or was that a typical thing? 
           I found that very helpful.
                       DR. BONACA:  We had them before, but this
           was --
                       MR. GRIMES:  This is Chris Grimes. 
           Arkansas was the first to provide it on a CD-ROM at
           the time of the application.  Calvert and Oconee
           provided CD-ROMs, but that was at the conclusion of
           the review, because they had EPRI compile their
           application materials on CD-ROM for the industry to
           draw on.
                       But since then all of the applicants have
           provided CD-ROM material.  They use different styles
           of packaging the information and using Hyper-Links,
           and all of the plants provided us with drawings.
                       Turkey Point did provide them in these
           convenient binders, and the rest of them provided
           essentially the usual D-Sized drawings marked up in
           various ways, depending on what their engineering
           practices are.
                       DR. BONACA:  I understand, however, that
           -- Bill, you were telling me that you went through a
           CD-ROM and that was different from the previous one.
                       DR. SHACK:  Yes, I thought this one was
           better organized.  I really found it very helpful to
           be able to go from link to link.  This is the first
           one where I really thought that the CD-ROM was a far
           better way to get through the application than the
           paper version.
                       MR. AULICK:  And then a concern which was
           raised at last week's meeting, at the subcommittee
           meeting, was the visual testing, and we had one
           examination for reactor vessel internals, including
           baffle bolts.
                       It was determined that this type of
           examination may not detect cracks due to assisted
           stress corrosion.  We discussed this with the
           applicant, and this issue was raised at the
           subcommittee, and so they are proposing that this be
           identified by ultrasonic examination of the baffle
           bolt, and then they will perform an enhanced VT-1
           inspection capable of detecting 1.5 mil.
                       DR. BONACA:  I think an issue here was
           raised by Dr. Shack that the applicant had in fact
           included both VT-1 and ultrasonic for the baffle
           points.  Therefore, that was adequate with that
           clarification, but the text in the SER implies --
                       DR. SHACK:  Well, I am happy with this
           solution.  If you are going to have VT-1 to look for
           cracks, you do have to set an acceptance standard with
           something like that.
                       DR. BONACA:  Does it require clarification
           in the SER?
                       MR. ELLIOT:  Barry Elliot, Materials and
           Chemical Engineering Branch.  The ultrasonic
           inspection is part of an industry program developed
           for techniques for inspecting the baffle bolts.  And
           enhanced VT-1, it isn't so much as a qualification,
           but that you have to be able to take a .5 mil wire,
           and that would qualify the inspection capability.
                       DR. BONACA:  Well, there is no
           clarification in the SER.  I mean, there was a
           misunderstanding, and I thought it was that the staff
           accepted VT-1.
                       MR. ELLIOT:  We have changed our position
           to require --
                       MR. GRIMES:  Dr. Bonaca, this is Chris
           Grimes.  The answer is yes, we would expect to clarify
           the SER.
                       MR. AULICK:  That will end my
           presentation.  Are there any questions before Barry
           starts his presentation?
                       DR. FORD:  I have a question.  It is more
           a request than a demand.  It would really be much more
           helpful to us -- because it would add some quantity to
           assessment during the SERs of the various programs
           that the licensee is using for the aging management
                       I get the impression that you correctly
           identified all the degradation modes, and then you
           essentially -- and what you didn't do or give the
           impression of is there a program to manage this from
           Westinghouse, or wherever else, and without any
           quantification as to how effective those programs are.
                       And as you go into the licensing renewal
           period will it still be adequate.  So it is more a
           question of believability.  I don't doubt that you
           have done it, but I haven't see it.  
                       DR. BONACA:  This is something that we
           have seen for about -- well, clearly license renewal
           depends so heavily on existing programs.  So if you
           commit to an ASME umbrella program, et cetera, the
           licensee's application doesn't go to a description of
           the program because there is an expectation that
           current CLD places a requirement on the quality of
                       And there has been a significant
           interaction between the industry and the staff on
           industry wanting to have no discussion of the existing
                       And I agree with you that for the reviewer
                       DR. FORD:  And since many of the aging
           management program deal with environmental
           degradation, and cracking specifically, rely on the
           ASME 11 approach, but who is to say that the ASME 11
           approach is adequate.  In many cases it is not.
                       And yet by just having said that I taking
           the ASME 11 approach, that sort of is given the
           blessing on this approach.  And unfortunately the
           environmental degradation doesn't always follow the
                       MR. GRIMES:  This is Chris Grimes.  The
           standard that we are using and the style guide that we
           developed for the safety evaluation was one that
           demands that the staff present the aging effect that
           is to be detected and managed, and then a conclusion
           that is built around why we believe that the aging
           management program is demonstrably affected.
                       And that was the whole point in developing
           the report on generic aging lessons learned.  What
           evidence do we have that these programs are
           demonstrably affected.
                       And we have generally found that we find
           it difficult to quantify the effectiveness of the
           programs.  Instead, what we rely on often is an
           articulation of what we have not found by virtue of
           the aging effect as being adequately managed by virtue
           of inspection techniques and repair techniques that
           identify and correct the condition.
                       ASME, in particular, has been challenged
           by us to go back and reflect on those things that
           license renewal has caused as additional programs
           above and beyond ASME, because the ASME feels that the
           -- their view was that their programs are quite
           demonstrably affected at managing the applicable aging
                       And so we have challenged them to try and
           build on our safety evaluation conclusions, which in
           the future we would refer to GALL, because we have
           gone through generically and described the basis upon
           which we have concluded that particular programs, and
           specifically ASME and EQ, and other standard programs.
                       But the whole style of our safety
           evaluation is built around what can we say about the
           effectiveness of the programs to manage the applicable
                       And if you have any particular suggestions
           about how we can change the style of our writing guide
           for the staff so that they could more clearly
           articulate that, we would be happy to consider that.
                       DR. BONACA:  Any other questions on the
           general application and the SER?  You had some
           comments, Steve, regarding the documentation and
           training of the staff at the site.
                       DR. ROSEN:  Yes, I did at the
           subcommittee, and Raj referred to that in his remarks. 
           I was satisfied I thought with his coverage of the
                       In general, and just for the record, my
           feelings are that the engineering support personnel
           training program for the utilities needs to actively
           set requirements for the training of engineers to not
           only preserve the programs that are put in place for
           license renewal throughout the remaining license term,
           but also to train a whole new generation of engineers
           in this.
                       Because people who have been at these
           plants for all these years have not typically thought
           about license renewal in the context of a regulated
                       And my experience is that that is now just
           beginning to come into play in the utilities, and the
           infrastructure is in place for a very sound
           engineering support personnel training program.  But
           it does not have this feature generally.
                       And I understand that INPO is working on
           changing the criteria for that, and I think that is
           going to be necessary.
                       MR. GRIMES:  This is Chris Grimes again. 
           I would like to build on that thought by pointing out
           that license renewal focuses specifically on aging
           management, and one of the penance that we try to
           build on is this concept that the ongoing regulatory
           process handles everything except for aging effects
           applicable to passive components.
                       We do not have a specific review feature
           that looks at qualification and training of personnel,
           because as you point out, we have a much broader view
           that the process for qualifying and maintaining a
           sound engineering staff, or reactor operators, or
           whoever, is something that transcends license renewal.
                       And that there are emerging technologies
           comparable to aging effects and aging management
           programs that need to be part of the routine of the
           training and qualification of personnel, operating
           experience, and changes in regulatory requirements,
           changes in the licensing basis, advancements in steam
           generator tube inspection techniques.  
                       There is a whole suite of things for which
           you want to both capture the corporate memory and
           build on it, and have a future generation of staff
           that is going to have a sound foundation to maintain
           plant safety in the future.  
                       DR. ROSEN:  I think we are agreeing,
                       DR. BONACA:  I would like to go back for
           just a second about the discussion that we had and
           that Dr. Ford raised.  If in fact you have a program
           right now under ASME that is being used to inspect and
           qualify defects of some type, and the program is not
           adequate, how is it being accepted in an adequate
           program for the full licensing term?  
                       I don't know if I used the right word here
           when I said inadequate, but you mentioned the
                       DR. FORD:  Well, the ASME code for
           corrosion and fatigue, and the environment affects on
           fatigue which is in the design basis is not adequate
           for some boiling water applications.
                       The ASME 11 code for crack growth, and in
           which you use the mean line of the data, is not
           adequate for the scatter of data that you see for the
           -- for instance, stress corrosion and cracking for
           missile head penetrations.
                       So if you just follow the ASME 11 code
           blindly, and without taking into account the scatter
           of data around the curves, you are going to have
           problems.  That is what I would like to see being
           addressed by the licensee and the staff when they say
           that a program is good.  
                       It is not good as you get more data coming
           out in the literature and the codes that were written
           a long time ago are no longer necessarily good.
                       DR. BONACA:  But I would expect that given
           this insight, and evidently open knowledge, the staff
           today would inspect those licensees affected by this
           issue to use additional information to purely the
           application or the ASME-3 Code.  I would expect that
           to happen.  I mean, the staff can answer the question.
                       MR. ELLIOT:  I have discussed this
           question before, and the NRC uses the ASME code as
           guidance and as its requirements.  But when it sees
           that the requirements are not adequate, we set up
           additional requirements.  
                       We put out generic letters, and we put out
           bulletins, and which requests people to do things
           differently, or not requested all the time, but
           provides them sufficient information that they may
           need to do things differently.
                       That is our process.  Examples are the BWR
           internals program.  I mean, inspections were not
           adequate based on the ASME code, and a separate
           program had to be developed.  
                       Another example currently is the CRDM head
           cracking.  I mean, the inspections of the ASME code
           don't appear to be adequate at the moment, and they
           may be, but we are still evaluating that. 
                       And when we finish the evaluation, we may
           have recommendations to do other things.  As far as
           the fatigue crack growth, that is recognized as a
           generic issue, and it is addressed in our SER.  
                       The NRC has a process for handling
           situations that come up that the ASME code is not an
           acceptable method, and we implement that process. 
                       DR. FORD:  As I said in the very
           beginning, I don't doubt that that process goes on,
           but it is not scrutable.  When you read the SER, it is
           not immediately apparent to you that you went through
           that detailed analysis and that has been taken into
                       All you see is, yes, so and so has a
           program, and it's all right.  You didn't see the --
           the thought process that you just articulated, you
           don't see that set out.  And you don't see a graph,
           and I have never seen a graph.
                       DR. SHACK:  Well, I think that is a little
           unfair though.  I mean, the inspection program for,
           say, stress corrosion and cracking in boiling water
           reactor piping was set out 20 years ago now, and it
           certainly is not an ASME code.  
                       It is an accelerated, more aggressive
           inspection schedule, but you don't expect to see the
           justification for that in the inspection schedule.  If
           the guy is following that, and just that aggressive
           inspection schedule, you don't have to rejustify that
           inspection schedule every time.
                       As Barry mentioned, the fatigue problem is
           a recognized one.  Every one of the license renewal
           documents has to address the fact that the ASME 3
           code, environment fatigue curves, are known not to be
           conservative, and they address it.
                       But they refer to NUREG -- you know,
           documents, where it is discussed.  But they don't
           reproduce that numerical basis in every report, and I
           think that would be unreasonable to expect.
                       DR. FORD:  I put myself in the position of
           being an informed technical guy out in the public who
           is reading these documents on whatever the court
           reporter says, and he says, hey, it didn't take into
           account this or that.  He doesn't have easy --
                       DR. SHACK:  Well, there is certainly a
           section in the license renewal document that says that
           environmentally assisted fatigue, and how do I address
           it.  And he goes through it.  Now, admittedly, he
           doesn't show any graphs.
                       DR. FORD:  Well, nor is there a statement
           of the problem.
                       DR. SHACK:  I would disagree.
                       DR. BONACA:  I think there are, yes.  The
           reason why I am pursuing this --
                       DR. FORD:  Well, a statement of the
           problem, the specifics, that such and such, et cetera.
                       DR. SHACK:  I think it is, but you can't
           rely on your -- you know, just using the straight ASME
           code basis, and that you have to take into account
           environmentally assisted fatigue in a way that has
           been found acceptable by the NRC, which is basically
           a considerably enhanced augmented fatigue fact.
                       DR. BONACA:  The point that I would like
           to make is that my thinking is that it would be 12
           years before we get into licensing renewal for this
           plant.  We had better have adequate inspections
           between now and then, and the burden I am not placing
           on license renewal. I am placing it on the existing
                       So my expectation is that the existing
           programs have in fact that burden now, and that the
           staff reviews that part of the licensing, with the
           knowledge that 12 years from now probably there are
           going to be additional problems that we find with
           these inspections, and modifications that we have to
           make, just as we have had on these CRDMs.
                       But again the point that I am making is
           that I always look for the burden in the existing
           problems because they have to serve us well for the
           next 12 years for this plant, for example, before we
           step into license renewal.
                       But I understand, and my sense was that
           the programs -- I mean, when you go on the site and
           you review these programs that are described in the
           back, are you looking at them in detail from scratch,
           or are you simply assuming that because they are
           accepted today they are okay?
                       I don't have a sense that you don't review
           them, because you have comments that you make
           regarding changes or commitments.  For example, take
           the CRDM issue.  That is one where they looked at it,
           and they said, well, the existing program is not good
                       And they say you have to modify that to
           include inspections, commitments that you have through
           NEI, the programmatic steps, and inspections that you
           have for that kind of plant, and so on and so forth.
                       So to me that is an example that they are
           in fact looking at the adequacy of existing programs. 
                       DR. FORD:  I would start off by saying
           that I believe that.  It is a question that somebody
           outside of this room, or that there is something about
           the topic on how does he feel, and I just got the
           feeling when I was reading things that you don't go
           into the depth that you did.  You are selling yourself
                       MR. GRIMES:  This is Chris Grimes, Dr.
           Bonaca.  I am particularly sensitive to the concern
           that the staff evaluations are not scrutable.  We
           constantly are challenged by trying to present safety
           evaluations that present a sufficient amount of detail
           to show the extent of the staff review.  
                       But at the same time don't present so much
           detail that it ends up being overwhelming.  We are
           currently going through an exercise with a
           communications specialist contractor to try and
           articulate generic aging lessons learned and aging
           management programs for the general public, and we are
           targeting the 11th grade level, because the standard
           is usually the 4th grade level.
                       And we have attempted to try and present
           enough information, but not too much information, and
           now we are going to go to the tri-fold brochure
           approach to condense it even further.
                       We do a lot of material incorporated by
           reference, which is a technique that has been used
           since engineers first picked up a slide rule, and then
           to the extent that we try to point to details in the
           graphs and the data, and all the material that it is
           drawn on.
                       And then Dr. Ford is presenting to us yet
           a new communication challenge in terms of the
           believability of a demonstrably effective aging
           management program, which as I said before, we are
           open to any and all suggestions on ways that we can
           improve the articulation of our evaluation basis.
                       But I agree with Dr. Shack.  I think that
           if I were asked to point to one program for which we
           have done a very good job of explaining the nature of
           the problem, and the nature of the solution, it is the
           environmental effects of fatigue.
                       And so that is the best that we have got
           to offer right now, and if that one isn't scrutable,
           I don't know what of anything that we do or the ACRS
           does that is.
                       DR. BONACA:  Well, it's interesting, you
           know. It is a question of communication, and maybe in
           the specific areas where it is a known fact that
           existing -- for example, the ASME programs, just be
           qualified or enhanced, or complimented or supplemented
           by additional inspections, one could maybe have an
           expanded discussion.
                       Again, not just for all of them, but for
           just a few, so that there is a better sense of the
           continuation, because this is a comment that is not
           new to this committee.
                       I mean, other members have expressed the
           same frustration at times in the past because this is
           a huge --
                       DR. SHACK:  Well, I think GALL is an
           improvement there because it is referenced there, and
           many of the SERs do have that problem.  You know, we
           found it acceptable.  End of statement.  
                       And in this one it is a GALL document, and
           you go back and there is a reference to a NUREG, and
           to a generic letter.  I mean, it is a traceable kind
           of thing.  Admittedly, it isn't all together, but you
           can pull the string.
                       DR. BONACA:  Well, yes, but again it is a
           huge management program, and it is a huge umbrella of
           activities, and so I think with the communications, I
           think the feeling is to try and find some way in which
           you can put in some windows.
                       Now, there are some, and again the open
           items on the CRDM clearly goes to the heart of the
           issues, and in fact it is very specific in the way it
           is spelled out, and the concern with where the
           location of the crack growth is coming from and those
           elements.  But anyway that is a suggestion that you
           want to consider.
                       DR. FORD:  And another calibration factor. 
           As you know, I am a fairly new member to this group,
           and I am just becoming use to negotiating with this
           wealth of paper.  
                       And maybe I am calibrating myself to that,
           but equally I am also representative of a whole
           technical community out there who doesn't know these
           details.  And maybe that is the community that maybe
           ultimately you may have to impress.
                       MR. GRIMES:  And the irony in all of this
           is that we do get a lot of that because we share these
           experiences internationally.  And by the time that we
           have gone through and explained why we do what we do,
           and how we do it, then the recipient now understands
           and has learned, and so now they are calibrated.
                       And then we say, yeah, but how can we
           avoid having to go through that with the next new
           introduction to the world of aging management, and we
           just have to continue the process of trying to learn
           how to communicate better.
                       But I do want to react to Dr. Shack's
           point, and that is we are always -- we are sensitive
           to and always looking for safety evaluations that say
           we have reviewed all of this stuff, and we find it
                       And I look for those because I say, "and
           where did the because go."  
                       DR. BONACA:  One thing that I want to say
           is that certainly renewal or new applications which
           will have references to GALL will be more helpful.  
                       A suggestion that I have also for all of
           the members for the next review is that we already
           have the final GALL.  It is quite informative when you
           go through it, because it says what is acceptable, and
           what is not.  
                       It does not go into extreme detail, but it
           has quite a level of detail, insofar as, for example,
           that this is not sufficient.  Now, at times you are
           left with the question of, well, what do you want.
                       But it leads you through and explains
           typically what enhancements are expected.  
                       DR. ROSEN:  Let me assure you, Dr. Bonaca,
           that I also as a new member have been given my
           personal copy by the ACRS staff of the GALL report.
                       DR. BONACA:  Yes, and it is much more
           manageable than it used to be.  That's good.  Okay. 
           Any other questions or comments in general to the
           application?  If not, then we have now a presentation
           regarding the WCAP.
                       MR. ELLIOT:  I am Barry Elliot with the
           Materials and Chemical Engineering Branch of NRR. 
           There are four WCAPs that we were requested to review. 
           The license renewal rule requires each applicant for
           a license renewal to contain an integrated plant
                       In an integrated plant assessment,
           applicants must identify the aging effects for the
           components within the scope, the programs to manage
           the aging effects, and identify any time limiting
           aging analysis for the components.
                       And in these four WCAPS, that is the way
           the Westinghouse Owners Group organized the report and
           I am going to go through and go through the highlights
           that they have provided.
                       The first report deals with piping and its
           associated pressure boundary components, like valves,
           pumps, and bolting.  The aging effects you see up
           there and you can read them.  
                       What we would like to say is that to
           manage fatigue related cracking, this WCAP proposes
           analyses, methods, and inspection requirements, to
           manage corrosion of external surfaces caused by
           leakage of borated water.
                       They propose a boric acid corrosion
           program in accordance with their commitments to
           Generic Letter 88-05.  A loss of material by wear of
           RCP and valve bolted closures.  The WCAP proposes to
           do in-service inspection to the ASME Code, 
           Section 11, and ANSI OM standards.
                       For lost of bolting preload caused by
           stress relaxation, the WCAP proposes to do in-service
           inspection to ASME Code Section XI.  
                       The WCAP identifies two TLAAs for piping
           and other associated pressure boundary components,
           which are fatigue evaluation and leak-before-break.
                       DR. ROSEN:  Did you purposely avoid
           discussing the reduction in fracture toughness due to
           thermal aging?
                       MR. ELLIOT:  Oh, I'm sorry, I left that
           out.  I missed it.  They propose analysis methods and
           inspection requirements to manage reduction of
           fracture toughness due to thermal aging.  That is what
           is in the WCAP. 
                       DR. BONACA:  Now, looking at this WCAP, I
           did not look at this one.  I was assigned to review
           the pressurizer, and I did that, but the format is
           identical for all of them.  And you have the SER in
           front of it.
                       And then you have a number of areas where
           you disagree with --
                       MR. ELLIOT:  Well, where we disagree, we
           have license renewal action items.
                       DR. BONACA:  Exactly, and so could you
           expand on that?  In certain cases where you disagree,
           you just go to closure, and typically those are areas
           where you have to go to plant specific, or your simply
           chose to ask the applicant to resolve the issue.
                       DR. SHACK:  Well, the topical report
           wasn't adequate I think is the action in many cases.
                       DR. BONACA:  Yes.
                       MR. ELLIOT:  What happens is that when we
           have license renewal action items, the applicant
           missed an aging effect that we thought was
           appropriate, or the program that they proposed we
           thought was not sufficient, and therefore an applicant
           who wants references would have to address those
           specific issues, about whether or not the aging effect
           applies to their plant that we think might.
                       Or that the program should be supplemented
           and then they would have to address whether the
           program would need to be supplemented.  That would be
           the action items.
                       MR. GRIMES:  Dr. Bonaca, this is Chris
           Grimes.  I would like to back up one step and go back
           to the review process that we go through.
                       We get these topical reports in from the
           owners groups, and the first thing that we do is issue
           a draft safety evaluation report that identifies what
           we believe are deficiencies in either the
           identification of the scope, or the aging effects, or
           the program attributes that are required to
           demonstrably reflect that the aging effect can be
                       We issue that in draft and then we give
           the owners groups or the generic entity an opportunity
           to try and resolve them on a generic basis.  And so
           they get a chance to challenge our challenges.  
                       And if we can't settle it on a generic
           basis, but we agree to disagree, or they say we can't
           do that generically, that ends up being an interface
           requirement, that then is characterized in terms of
           applicant action item.
                       DR. BONACA:  This is the reason why I am
           raising the question, is to understand the
           completeness of the review.  For example, for the
           pressurizer, I believe in the pressurizer topical
           reports that there are nine applicant action items.
                       However, in the SER, there is only a
           requirement of a discussion of four.  The reason is
           that the applicant in the application complied with or
           explained how they met all the requirements of the
           pressurizer topical report, but you found that four of
           them were not sufficient.
                       And so for those four, you set the
           additional applicant action items, and you resolve
           those through a request for additional information.
                       MR. ELLIOT:  Right.  We put out questions. 
           As, for example, with respect to Turkey Point and the
           pressurizer for all these, we put questions that
           resulted from the review of the WCAP and applied them
           to Turkey Point.
                       MR. GRIMES:  I would also like to point
           out that Raj mentioned earlier that as we started the
           review the staff SERs for the topical reports hadn't
           been completed, and so we didn't know what the
           complete set of applicant action items were.  
                       And in Oconee and Arkansas, the safety
           evaluation goes through and addresses applicant action
           item by applicant action item.  And that is a very
           easy thing to do when the topical report SER has been
           published and the list of action items is clear.
                       This review started off with the two
           running in parallel, and so I found that on both
           Turkey Point and Hatch the staff evaluation tends to
           generalize all the applicant action items that we are
           satisfied except for.  And that was because the
           counting had not been done yet.  
                       DR. BONACA:  Okay.  I understand now.  All
           right.  I understand.  
                       MR. ELLIOT:  The next WCAP was the WCAP
           for reactor vessel internals.  The WCAP identifies the
           aging effects as shown up here; to manage the
           reduction of fracture toughness, and irradiation and
           stress corrosion cracking, and irradiation creep and
           void swelling due to neutron radiation.
                       The WCAP takes credit for the Section 11
           inspection, and then for the baffle/former bolts, and
           the barrel/former bolts, which we would propose
           augmented ultrasonic inspection over and above the
                       For managing the combination of stress
           relaxation and high-cycle fatigue for preloaded
           components.  WCAP takes credit for Section 11
           inspection and a fatigue management program.
                       And then finally for wear, which would be
           wear of the bottom mounted flex thimble tubes, and the
           WCAP proposes to perform ultrasonic or eddy current
           examination per responses in conformance with licensee
           responses to I&E Bulletin 88-09.  And there is one
           TLAA in here and that is for fatigue.  
                       For the pressurizer WCAP, there are two
           aging effects, fatigue related cracking, and PWSCC of
           Inconel 82/182 weld metal and sensitized stainless
           steel safe ends.
                       The WCAP takes credit for managing PWSCC
           through its in-service inspection and Section XI
           Program, and for fatigue, it has Section XI, and also
           a fatigue management program similar to what was said
           for the internals.  There is one TLAA here and that is
           for fatigue.
                       DR. WALLIS:  What does a fatigue
           management program look like?
                       MR. ELLIOT:  A fatigue management program
           is where they do in a fatigue study the number of
           transients proposed for the life of the plant are
           documented, and then the study does what is the effect
           on the usage factor for the plant or for the
                       And the fatigue management program would
           be where the licensee will count the number of cycles
           to ensure that they have not exceeded the limits of
           their analysis.
                       DR. WALLIS:  So it is straight-forward
           bookkeeping in a sense?
                       MR. ELLIOT:  It is bookkeeping and keeping
           track of transients that occur during the life of the
                       DR. WALLIS:  Is there any kind of check
           that this is on track?  How does the inspection feed
           into the -- well, you have a theory for fatigue, and
           you keep track of all these things, and is there some
           check that the theory conforms to the reality
                       MR. ELLIOT:  Well, the purpose of the
           fatigue management program is to count the actual
                       DR. WALLIS:  Well, how do you know that
           your theory is actually is appropriate for this?
                       MR. ELLIOT:  Well, you actually go out
           then and inspect.
                       DR. WALLIS:  So you check?  So there is a
           check to see if the theory is actually conforming to
           some reality?
                       MR. ELLIOT:  Yes.
                       DR. BONACA:  And particularly in the
           inspection program they will take in the most
           susceptible components, right?  You have an
           identification of what is the most susceptible
                       DR. WALLIS:  So it guides your inspection
           in a way?
                       MR. ELLIOT:  Yes.
                       DR. WALLIS:  And you know when to look for
                       MR. ELLIOT:  Yes.
                       DR. WALLIS:  And I asked because there is
           a kind of litany here.  You know, whenever you have
           something like X, you have a management program for X,
           and I would be interested in knowing sometimes what X
           is, and what the management program for X is.
                       DR. BONACA:  We didn't get a word yet
           about how well he felt that all the issues were
           addressed and how comfortable you are with these
                       MR. ELLIOT:  Well, the management program
           for the fatigue program is the counting of the actual
           transients by the applicant, and keeping track of it.
                       The fourth WCAP deals with reactor coolant
           system support, and there are two aging effects; loss
           of material and a decrease of strength of steel
           component, and concrete embedments from aggressive
           chemical attack and corrosion; and then stress
           corrosion cracking of the bolting.
                       The WCAP for steel components is that they
           manage the loss of material and decrease in strength,
           and the WCAP takes credit for in-service inspections
           of ASME Code, Section XI.
                       And for the concrete embedment, it is an
           in-service inspection to ACI 349 Code, and leakage
           identification walkdowns.  For the stress corrosion
           cracking of bolting, WCAP takes credit for in-service
           inspection to ASME Code, Section XI.  And there was
           only one TLAA, and that was fatigue.
                       And this is our summary for the staff
           review, and we have gone through this before, and that
           is that where we found deficiencies either in the
           aging effects, the scope, or the aging management
                       And we have identified license renewal
           action items, and the first part of this slide
           identifies how many action items were identified by
           the staff for each of the WCAPs.  
                       I just want to give you some background
           here.  Of course, anybody could go to these and -- we
           say in the SER that if you reference this and you
           follow these applicant action items that you could
           show that you could show that you have managed aging
                       There is another thing that this is used
           for.  When we wrote GALL and we went back to these
           programs, and made sure that we -- these were some of
           our basis for our programs in GALL in addition.
                       Anyway, in conclusion, upon completion of
           all renewal applicant action items, license renewal
           applicants who reference the WOG reports adequately
           demonstrate that the aging effects of the components
           in the scope of the WOG report can be managed so that
           there is reasonable assurance that the components will
           perform their intended functions in accordance with
           the current licensing basis during the period of
           extended operation, and that is our presentation. 
                       DR. BONACA:  Now the question that I had
           was some of these issues are plant specific, and
           therefore, you have to have an applicant action item.
                       MR. ELLIOT:  Yes.
                       DR. BONACA:  Some of them are generic and
           Westinghouse chose not to -- or WOGG chose not to
           address the concerns of the staff because they
           disagree with you?
                       MR. ELLIOT:  Well, I can't speak for
           Westinghouse, but what our problem was that when we
           reviewed this we reviewed it late.  It came in early
           and we reviewed it late, and so there wasn't the back
           and forth that we normally get with a review.
                       So a lot of places where we would have
           resolved it as part of the review process, because we
           were trying to get it for Turkey Point and we pushed
           ourselves, we didn't get it resolved in time, and we
           made those license renewal action items.
                       They would have been open items for the
           WOG report, but because of the review process we
           couldn't do that and we turned them into license
           renewal action items.
                       DR. BONACA:  So from now on any
           Westinghouse Owners Group member that applies for a
           license renewal has to go through his applicant action
           items on a plant specific basis?
                       MR. ELLIOT:  Yes.  Right.
                       DR. ROSEN:  Mario, I have a question about
           what happens next.  Here the staff and the applicant
           have reached an agreement which will soon be
           documented in an SER about things that need to go on
           for the extended term of operation.  
                       How does the staff move those agreements
           into its inspection program?  What are the features of
           the next set of actions that can give us confidence
           that now these things have been carefully evaluated
           and identified, and in fact the staff will be making
           the requisite number of checks to be sure that the
           applicant is carrying out these actions?
                       MR. GRIMES:  This is Chris Grimes.  There
           are two features to that.  The first feature is that
           all of the program attributes for those things that
           are relied on to manage these aging effects are being
           captured and changed to the updated final safety
           analysis report.  
                       So they reflect the change in the current
           licensing basis that will become a part of the staff's
           routine inspection program as driven by the reactor
           oversight process, and to the extent that there is
           particular safety significance associated with program
           findings, we gravitate towards those things in future
                       The second piece is that like the one-time
           inspections there are a number of things for
           commitments for things that will be done prior to
           entering the period of extended operation.
                       And when the process of developing an
           inspection procedure now that will capture those
           things and provide for some future inspection to
           verify that all these commitments -- or to verify that
           not all of these commitments, but at least some of
           these commitments by sampling, as is our usual
           practice prior to entering the period of extended
                       We are struggling with that concept right
           now because the applicants make commitments day in and
           day out to do things.  Whenever they file a licensee
           event report, it has got an attachment, and it says we
           are going to do all these corrective actions.
                       We are trying to figure out right now how
           to fit in these commitments with that system so that
           the inspection program is going to effectively apply
           its sources to decide which of these things do we
           really want to verify prior to entering the period of
           extended operation.
                       But for our purpose right now, we have
           captured those two groups, and we are verifying that
           the updated safety analysis report has the requisite
           detail in it, and is a program summary that can be
           managed under 50-59 for the future.  
                       And we are tracking the commitments for
           actions to be taken prior to entering a period of
           extended operation, and we will let our normal
           regulatory process decide what to do with those list
           of things in the future. 
                       DR. ROSEN:  I wonder if we could come back
           to that subject at some point, not in regard to any
           specific application, but in a longer generic question
           for the ACRS to ask the staff to come in and maybe
           give us after having given it a little more thought,
           to come in and talk to us about their ideas about how
           they can bled this into the inspection program, and if
           there is a new manual chapter required, or what all is
                       DR. BONACA:  That is a good suggestion.
                       MR. GRIMES:  We are working on a draft
           inspection procedure that deals just with that
           specific issue.  So when it is right, we will come
           back and discuss it with ACRS.
                       DR. BONACA:  I just wanted to note
           regarding the issue we discussed before, and that is
           the form of the topical actions.  It was not a
           criticism.  I found them to be informative.  
                       Typically you get a topical report which
           tells you what is being done, period.  Here you had
           the SER in front of it, and all the points of
           disagreement with the additional licensee action,
           applicant action items.
                       In the back you had the RAIs, and it was
           helpful, because one would understand the kind of
           review that you did, and the kinds of questions that
           you asked and so on.  They were quite informative. 
           Any other questions from the members?
                       (No audible response.)
                       DR. BONACA:  Any other comments?  If not,
           I would like to thank you, and what I would like to do
           is simply brief quickly the committee in regards to
           the subcommittee meeting we had last week, and to
           provide you with a recommendation.
                       In summary, we felt that this was a good
           application, and was quite scrutable.  I mean, I know
           that the staff at the beginning had some what we
           called navigational problems in finding all the items,
           but in general I thought it was quite clear, although
           I understand that some of the forms that were on the
           table I liked, and you recommended that not be the way
           in future applications, but that's okay.  I can live
           with that.
                       We felt that there was a significant
           effort by the applicant to address the issues raised
           by the NRC.  In fact, that really converged down to
           four open items, of which I view only the first one as
           one having no clear path -- I mean, in my mind -- on
           how it is going to be closed.
                       The others are more commitments than
           anything else, and we felt that the staff performed a
           significant review.  You started with approximately
           150 requests for additional information for a pretty
           lengthy meeting and visits at the site.
                       And I believe what I see with respect to
           other SERs before is a complete discussion of the
           issues.  And because of the fact that the SER has only
           four open items, the application is scrutable, and I
           would provide the Committee with the same
           recommendation that we had for Arkansas-1, which is
           not to write an interim report right now.
                       And the key reason is because we expect to
           have closure on these open items in the very short
           term, and I think we should write the final letter at
           that time.
                       DR. ROSEN:  Does that include the closure
           of the II/I issue?
                       DR. BONACA:  Yes.
                       DR. ROSEN:  We will hear the resolution of
           that before we write our letter?
                       DR. BONACA:  That's right.  I sent you
           already about four pages in which I detail what the
           views of the subcommittee were, and I hope that I
           summarized them well, and for those of you who are on
           the subcommittee, please give me any comments if I
           mischaracterized someone's observations.
                       In general, we felt that their
           certification of components and scope was quite
           accurate.  I mean, it was good.  We raised a number of
           questions regarding specific components, and some of
           them identified by John Barton who is a consultant to
           us, that were not in scope, and we found that in all
           cases there were good reasons why they were not in
           scope, and consistent with the license renewal rule.
                       We raised some questions regarding the
           spent fuel pool, and that still puzzles me in many
           ways, because Turkey Point identified multiple
           functions that put passive components in scope, and
           the functions were pressure boundary integrity, heat
           transfer, and that brought in scope a number of
           components, including the cooling system that I did
           not see in scope for Oconee, and for other previous
           applicants, which troubled me at that time.
                       So we raised questions regarding why if we
           needed something from previous applicants, and I
           recognized that the answer was accurate, which is
           still that they can perform the functions of license
           renewal with the equipment that they have in scope,
           which is essentially an emergency make-up system
           coming from the high pressure injection system, which
           is centigrade, and the proper line item.
                       Still I am not very happy about the
           response of their coolant system is in scope, and so
           I am troubled somewhat about the narrow definitions
           provided by the rule and that set the stage for older
           plants not to have what I view as important equipment
           in scope.
                       So we discussed that issue and the answer
           that we received were adequate to not pursue it any
           further.  I thought the aging effects went quite well,
           and were well described.  
                       I think that in general that they were
           very consistent with what we see in applications, with
           the exception of those which are unique to Turkey
                       And we had quite a number of discussions
           regarding the aging management programs, one-time
           inspections, and we found them to be generally
           appropriate, although again we were lacking the level
           of understanding of some of the existing problems that
           Dr. Ford was talking about, and so therefore there was
           some frustration by some of us that from our
           perspective that unless we get back to the kind of
           level of review, we can make a judgment oftentimes.
                       We found the Westinghouse Owners Group
           topical report quite understandable because of the
           combination of SER in front of it, and applicant open
           items, and then the RAIs in the back.  
                       So you can understand what took place, and
           you can go to almost a checklist of what we believe
           has been covered and maybe what has not been covered.
                       And I could not figure out what had not
           been covered.  So I just reviewed the pressurizer, and
           the other members reviewed the other documents.
           And so I thought the documents were appropriate to
           support an application.
                       And finally we looked at the TLAAs, and
           there was a complete set, and Mr. Rosen here raised
           some concern regarding the proclivity of the RT PTS,
           which is 197 degrees Fahrenheit, to the criterion,
           which is 300, and so we had a discussion there
           regarding what does the criterion mean.
                       And the sense was that the criterion is
           really a very conservative, almost lying in the sand,
           and you don't have to go into plant specific, but
           maybe you want to rest assured, because some plants
           are closer to that criterion than others.
                       DR. ROSEN:  Well, I don't know how you
           could get any closer to that criterion than Turkey
           Point.  They are 2.6 degrees away.
                       DR. BONACA:  That's right.
                       DR. ROSEN:  And Fahrenheit degrees, and if
           you think about it in absolute terms, it is so close
           you can't get any closer.  So I was concerned and I
           started raising questions about uncertainty, which I
           expect Dr. Kress to pat me on the back for.
                       But I was assured by the other members and
           the staff that while it is true that that is very
           close, there is an enormous amount of margin in
           setting up the 300 degree fahrenheit criterion.
                       DR. SHACK:  And that is one case where
           uncertainty is explicitly included.
                       DR. ROSEN:  In the acceptance criterion,
           yes.  I didn't go away happy, but I went away.  
                       DR. BONACA:  Anyway, we will discuss
           whatever we put in our letter when we come to the
           final report.  
                       DR. KRESS:  There is still a question of
           whether the actual uncertainty in the determination of
           that value still exceeds the uncertainty you think was
           in the margin itself.
                       There is two uncertainties, and there are
           two margins, and so you really need to do the
           uncertainty --
                       DR. SHACK:  And actually the Reg Guide
           1999, you include an uncertainty in your evaluation of
           the embrittlement, as well as the -- you know, it is
           actually one of the more thought out than most of the
           limits that we have for these things.
                       DR. ROSEN:  Could I, Mario, go back to one
           of my earlier comments, and not this one, but the
           question about two over one piping, Raj, you did say
           that this matter has been resolved on the Hatch
                       MR. AULICK:  Yes.
                       DR. ROSEN:  And that that resolution is
           now being discussed with the Florida Power and Light?
                       MR. AULICK:  Well, every plant is
           different, but I think the end result is that they
           need to include all non-safety systems and components
           which could impact safety related systems, and
           structures, and components.
                       DR. ROSEN:  Well, my question is whether
           that issue still a point of contention between the
           staff and the applicant, or has there been a
                       MR. AULICK:  Between Turkey Point and the
                       DR. ROSEN:  Yes.
                       MR. AULICK:  We just started discussions
           with them, and they are going to prepare the sponsor
           and I think we are going to go again.  I don't see any
                       DR. ROSEN:  Well, we have a representative
           from Turkey Point here.  Would you want to comment on
           it?  You don't have to.
                       MS. THOMPSON:  Well, I can do that.  Liz
           Thompson again from FPL.  We met yesterday in a
           noticed meeting to go over a draft response, and
           included in that was our two-over-one response.  
                       Based on our understanding of the staff's
           considerations, and I think in our original
           application we had addressed -- if I could just round
           it off -- maybe half of the items that the staff
           expected to be included under the overall context of
           non-safety related which could affect safety related.
                       In our revised or in our draft response
           that we provided to the staff for review, we had
           gained an understanding from the Hatch interaction of
           another type of consideration that we needed to
                       And we had provided that in that proposed
           response, which after yesterdays's discussion I think
           we found out that instead of that being the other 50
           percent, that that was actually maybe another quarter,
           and that there was yet a quarter more that we needed
           to address.
                       We definitely benefited a lot I think by
           having that discussion yesterday and the staff was
           very good at going through and trying to identify the
           problem statement, and what we needed to address and
           so forth.
                       And I think we have the action right now
           to go back and revise our proposed response.  We would
           like the staff members again to take a quick look at
           it before we submit it formally so that when it
           actually does come in formally here in the short term,
           the staff members can sit down and put pen to paper
           and write it off, and the issue will be resolved.
                       But I think that we are very close, and we
           had a very good interaction yesterday with a number of
           the staff members on that particular issue.  And it is
           a matter of gaining an understanding of the issue, and
           being able to communicate that so that we understand
           really what is to be addressed.
                       DR. ROSEN:  Well, that is all very good,
           and as I said before -- and you answered in the
           affirmative, Mario, that we would have a chance when
           we write the final letter to see how those
           interactions all played out. 
                       DR. BONACA:  Yes, and in fact, in the
           review, we are going to assign reviews of all the open
           items so you can see how the closure is.
                       MR. AULICK:  And I think the schedule to
           submit all responses is at the end of this month, or
           early next month.
                       DR. BONACA:  And from what I hear from the
           presentation here, it seems to me that they are trying
           to converge the closure and not necessarily to
           challenge the basis for the decision there.  So that
           should be a reasonably easy closure.
                       And with that are there any more questions
           or comments by any of the members?  If not, I think
           the staff for the presentation, and so this part of
           the meeting is closed.  
                       And then I think we have to wait until 10
           of 11:00 to start the meeting, and we will give you a
           long break, and we will recess until 10 of 11:00.
                       (Whereupon, the meeting was recessed at
           10:07 a.m., and resumed at 10:55 a.m.)
                       DR. BONACA:  The meeting is called back to
           order.  We are scheduled to have a presentation from
           Dr. Ford regarding the report from the ACRS
           Subcommittee on Materials and Metallurgy regarding the
           results of the Steam Generator Action Plan.  Peter.
                       DR. FORD:  I am really just talking
           primarily for Steve Grimes benefit, because everybody
           else was at that meeting last week of the Materials
                       It was a half-day meeting and the topic
           was to do with the steam generator action plan, which
           had several parts to it.  But before that meeting or
           rather since that meeting Noel has kindly arranged a
           meeting or arranged for a meeting yesterday between
           myself and Ted Sullivan and his staff, just to bring
           me further up to date as to where are all these
           different parts fit together, because I was getting
           completely lost with all the various bits of
           information that were being given.
                       And so I made up this flow diagram which
           is primarily for my benefit, and I share it because I
           will be reporting on the outcome from that Materials
           Subcommittee with reference to this diagram.
                       Down on the left-hand side, I have got the
           evolution of the NEI 97-06 project or program coming
           from the utilities, and as you can see it forms three
           conjoint parts; guidelines, performance criteria, and
           then the program, which itself is based on EPRI
           inspection criteria and Board of Chemistry guidelines.
                       And I understand that you all have been --
           that ACRS has been fully informed about that 
           97-06.  Where that stands right now, and this was
           discussed at the meeting last week, is that that
           program is scheduled by April 2002 to undergo an NRR
                       Already, however, there are issues seen,
           many in the area of the performance criteria, the
           question of Pis, and the question of condition
           monitoring, and the inspection intervals.  
                       Since 1997, the NEI have come out with a
           draft generic change package, and in fact there have
           been two versions; one in February of 2000 and one in
           December of 2000.  And as far as I know, this
           committee has not seen that.  Is that correct?
                       DR. SHACK:  That's correct.
                       DR. FORD:  Well, that modification of NEI
           97-06, some of it was presented at the meeting last
           week, and in high level areas, but in talking go the
           staff, they are willing to essentially accept that in
           place of 97-06.
                       However, they say that it will take
           several years to in fact review it, are the words that
           they used at the committee meeting.  But ultimately
           the way they are seeing this package going is that
           sometime in April 2002, they will have a joint NRR-NEI
           working version of a steam generator change package,
           which could then be implemented.
                       Now, this all seems so vague to me, and I
           stress that is to me, and it may not be to you.  But
           I asked the staff that in conjunction with NEI to give
           the Materials Subcommittee a breakdown of what this
           is, and where we stand on the SER for the 97-06
           document, and the generic change document.
                       DR. SHACK:  That is the generic tech spec
           change document.
                       DR. FORD:  That is correct.  As to what it
           specifically entails, and what the current concerns
           that the staff have on those packages.  So that is
           scheduled for November of next year.  
                       I'm sorry, November of this year, with a
           presentation to the full committee at the December
           full-committee meeting, and on the right-hand side,
           you see that the whole issue emanating --
                       DR. ROSEN:  When are they going to present
           that to us?
                       DR. FORD:  They are going to present it in
           a half-day meeting; the question of the NRR and NEI --
                       DR. SHACK:  The generic tech spec change
                       DR. FORD:  Well, not only the issues that
           the NRR have on 97-06, but also the details of the
           generic change package.  They are going to discuss
           both.  Both entities are going to come to discuss both
                       DR. SHACK:  With us?
                       DR. FORD:  With us, at the end of
           November.  They are meeting at the beginning of
           November -- NEI and NRR -- to discuss those packages,
           and they are going to report to us at the end of
                       DR. ROSEN:  Meaning the subcommittee?
                       DR. FORD:  Subcommittee.  And we will
           report to the full committee in December.  The reason
           why I wanted to push this was two things.  This thing
           has been dragging on for one heck of a long time.  
                       The utilities are essentially running the
           show.  They are self-assessing themselves on the basis
           of 97-06.  There seems to be very little leadership --
           and maybe that is too powerful a word from the start
           -- and I just wanted to push the whole process
                       And at the same time to make sure that we
           were on board with this thing as it moves forward,
           rather than me coming in at the last minute with
                       DR. SHACK:  You have to realize that
           doesn't exactly put the utilities in charge, because
           they get to do 97-06, and plus they get to live with
           their current tech specs.
                       DR. FORD:  Yes.
                       DR. ROSEN:  Unless they have asked for
                       DR. SHACK:  Unless they have asked for
           modifications, and so they in fact have a double-
           regulatory package to live with.
                       DR. ROSEN:  Which many of them have.
                       DR. FORD:  Yes.
                       DR. SHACK:  Yes.
                       DR. FORD:  Well, put down that the
           regulatory guidelines --
                       DR. SHACK:  But you make it sound as if
           they are in charge.
                       DR. FORD:  No, I'm sorry, but they are
           pushing technically the whole --
                       DR. POWERS:  Well, why shouldn't they be
           the ones to do that to the ones with the problem.
                       DR. ROSEN:  Exactly.
                       DR. FORD:  Well, I am new to this, and
           where regulators come into this whole decision making
           process, but I would have thought that the regulators
           should at least have some sort of leadership role in
           this whole issue.
                       DR. POWERS:  The regulator has a
           requirement to maintain the integrity of the reactor
           coolant system, and his investigation of phenomenology
           is done simply so he can understand what the licensee
           is proposing to maintain that integrity.
                       So in this area, particularly this area,
           it has always struck me as useful for the NRC to join
           in the partnership for the research with the industry,
           but it is predominantly the industry dime that ought
           to be spent.
                       Now, it happens that we have got a lot of
           personalities leaning forward in the trenches at the
           NRC, but as far as who should be spending the bulk of
           the money and the bulk of the effort, it is an
           industry problem.
                       DR. FORD:  I am not talking about
           resources, monetary resources, or dollars spent --
                       DR. SHACK:  But they are leading them.  I
           mean, they said plug or detect on detection unless you
           can demonstrate to us that it is safe to operate some
           other way.
                       DR. ROSEN:  As far as industry leadership
           and NRC leadership, you have to understand this whole
           thing in context.  This is not a new issue.  It has
           been going on now for 20 years.
                       DR. POWERS:  Since they put the first
           steam generator in.
                       DR. ROSEN:  And the formation of the first
           steam generator owners group one, and then steam
           generator owners group two, and now it is called
           something, and now it has got 97-06.  This is the end
           of a very long trail you are seeing.
                       DR. FORD:  But is no one worried?
                       DR. ROSEN:  Well, in the sense that we
           hope that the steam generators will be replaced.
                       DR. FORD:  No, you didn't let me finish
           the sentence.  Is no one concerned that this thing
           came out in 1997, and the NRR has not even given an
           SER yet, and they don't plan to until April of next
           year?  Does that concern you?
                       DR. SHACK:  Not as long as they are
           plugging on detection.
                       DR. DUDLEY:  No, the staff has reviewed
           it, and what they are in is a negotiating phase now,
           and they are not satisfied with the ramifications of
           the present version.  
                       DR. FORD:  Because now they have
           transferred some of those things to the evaluating and
           generic change package.  NEI has come out with a
           generic change package in February and December of
                       DR. SHACK:  Well, the generic change
           package is what really let's them implement these
           alternate repair criterion.  Otherwise, they have to
           live -- I mean, the current tech specs says basically
           plug on detection.  
                       So if you are going to get away from that,
           you need a new text spec that somehow implements it,
           and the real question is how much freedom do you give
           the licensee to manage that, and how much do you
           micromanage what he is doing with that, and that
           really is the kind of arm twisting that goes on.  
                       As it is at the moment, NRR is in sort of
           complete charge.  You know, you plug on detection,
           unless you come in and make a case that we don't have
                       DR. FORD:  Maybe I am being very
           simplistic here, but I find that this is supposed to
           be a partnership, in terms of the regulators and the
           utilities working together, and arguing, and making
           their cases?
                       DR. POWERS:  No.
                       DR. FORD:  You don't think that is wrong?
                       DR. POWERS:  It shouldn't be a
                       DR. SIEBER:  It is the regulator and the
                       DR. POWERS:  This is a confrontational
                       DR. FORD:  Well, it is not a very
           constructive confrontational system.
                       DR. POWERS:  Well, that may be true.
                       DR. FORD:  Well, let me ask the question,
           do you think it is necessary that the Materials
           Subcommittee review where we stand technically on the
           review of 97-06 and the generic change package?
                       DR. POWERS:  Yes, I think so.
                       DR. SHACK:  I think it is.  It would be
           very interesting to know exactly where the hard spots
                       DR. DUDLEY:  There is one hard spot, is
           the inspection frequency.  Right now with the package
           as it is written, licensees could go to -- let me get
           this right -- 20 effective full power years between
           steam generator tube inspections.
                       DR. POWERS:  So, 20 years without
           inspecting the suckers.
                       DR. DUDLEY:  That's right, and that's why
           the staff has pause about approving it.
                       DR. SHACK:  Now, that one you sort of have
           to wonder if they are really serious.
                       DR. KRESS:  There has to be something
           wrong with that.  
                       DR. SHACK:  You must be jesting here.
                       DR. POWERS:  What we really want are two
           cycles.  So let's propose 10 and see if they will fit
           us down to only two instead of every half-cycle.
                       DR. FORD:  This report is going to be what
           happened last week, and essentially we went over the
           essences of that whole program, including the DPO
           issues.  There are no issues at all with the right-
           hand side.
                       The other issue that came up yesterday and
           today, and in talking to Joe Muscara, is that it has
           been my understanding that the outputs from the NRR
           research action plan to which we had input are going
           to be then mellowed in to various revisions of the
           generator change package as it comes out, and as it is
           used and revised.
                       DR. WALLIS:  That may delay it even
           longer, because they won't do all this stuff on the
           right-hand side in time for that to come up in April
                       DR. DUDLEY:  Well, they have been waiting
           5 years now.
                       DR. FORD:  Well, that is how long it will
           take for the action plan number three.
                       DR. WALLIS:  Well, it seems that there is
           no sense of urgency whatsoever.
                       DR. SHACK:  Well, I have no urgency to
           approve an inspection program that will let them go 20
                       DR. WALLIS:  Well, what is the problem 
           with --
                       DR. FORD:  Of course you are not going to
           approve that, but you are going to approve something.
                       DR. WALLIS:  What is the problem here if
           you go back to the beginning?  Is the problem that
           there is some threat to safety from steam generator
           tube integrity?  Is it too much of a burden on the
           industry, or what sort of bases was the problem?
                       DR. POWERS:  It is a burden on the
           industry and it is a risk dominant accident.
                       DR. DUDLEY:  It is a burden on the
           industry because with the plug criteria the way it
           presently exists, is that any defect that you find in
           a tube, you plug, and licensees were finding that they
           were running into a number of tubes that would be
           continued to be allowed to operate.
                       DR. WALLIS:  So maybe by 20 years they
           will all be plugged or not enough of them will be
                       DR. POWERS:  Some plants are already
           having to de-power right now because they are running
           out of tubes.  And the answer to that is replace your
           damn steam generators.
                       DR. DUDLEY:  And what we are seeing now is
           the voltage based criteria allows them to leave some
           of those tubes in service to get an extra year or
           year-and-a-half before they are replaced and Dr.
           Hofenfeldt said is this the safest thing to do based
           on our present knowledge base.  
                       DR. FORD:  Just to finish going down this
           diagram, my assumption was that data from the NRR
           research program would be fed into this generator
           change package as the revisions come out.
                       Based on the discussion with the staff
           yesterday, it is not at all clear that that is the
           plan.  After talking to Joe Muscara, that is also his
           perspective, but it is certainly not the stated plan
           of the NRR.
                       So that is why I am suggesting in the
           letter that Dana authored yesterday that there should
           be a specific item in there on the ACRS and that it
           would be expected that it would be part of the
           evolution of the various modifications.  
                       DR. WALLIS:  Is there something down the
           road where if you could put in a new steam generator
           that they won't have all these problems with tubes? 
           Has there been actually an advance in the technology
           of steam generators so you don't have these?
                       DR. POWERS:  Not as long as Westinghouse
           is allowed to exist on the face of the planet.
                       DR. FORD:   A technical reason is that you
           can't guarantee it.  690 will crack.
                       DR. WALLIS:  And there are so many tubes.
                       DR. FORD:  It will take longer to crack.
                       DR. SHACK:  I think the fairer statement
           is that it is an open issue.  The experience with 600
           thermally treated and 690, with 600 thermally treated,
           you have 20 years of experience that indicates that it
           is much better than 600 mill annealed, which is the
           one that solved the problem.
                       With 690, you have 10 years of experience
           and laboratory data that indicates it is much better. 
           Whether it is good for 60 years is a very different
           question.  So you have to have an inspection program
           that can detect degradation of 690 if it occurs.  So
           then you argue over what the details of that
           inspection program should be.
                       DR. FORD:  And as far as the meeting last
           week, I want to go five minutes more.  There was a lot
           of discussion on the right-hand side, and we have
           already dealt with that, with the letters going out
                       On the left-hand side, there were very
           high level discussions, and some small action items
           which haven't been completed, but they were merely in
           terms of communications items, such as workshops, and
           clarified guidance documents, et cetera, but nothing
           substantial in terms of technical discussion and
                       That is why they are having a meeting in
           November to discuss those specific items.  The other
           item that was talked about in a very full morning was
           the South Texas project.
                       DR. ROSEN:  I have to recuse myself from
           these discussions.  I can listen to generic parts, but
           I won't take part in any discussion of the South Texas
                       DR. FORD:  Remember that the problem that
           arose out of this is that at the end of Cycle 8 that
           it was observed that out of four steam generators
           there was 35 total gallons per day leakage.
                       And what surprised me was that this was
           the first domestic plan leaking from ODSCC, and I
           didn't realize that it was the first one to show
           leakage.  The unusual aspect about this particular
           plant is that it had stainless steel support plates,
           and the significance of that is that there is less
           crud in the crevice of the tube support plate, and
           allows more leakage than the carbon steel support
           plate, where there is a lot of crud.
                       However, we do know that even with the
           stainless steel tube support plate that there is crud
           in that crevice.  At the end of Cycle 8, they had
           projected that there would be 3,522 crack indications;
           whereas, there were in fact 3,579 actual indications,
           otherwise under-predicting.
                       And then when they looked at an
           examination of the actual indications of Cycles 5, 6,
           7, and 8, it indicated that there was a steadily
           increasing rate of indications.  In other words, the
           problem is accelerating.
                       Now, coincidentally at the same time, it
           had made a request for an amendment to GL 95-05 for
           Cycle 9 to increase the voltage from 1 volt to 3 volts
           for those tube support plates which had an expanded
           tube in it in order to keep the tube support plates in
           one place should there be an accident.
                       However, in view of the leakage during
           Cycle 8, they went back to an effective 1.5 volt, and
           they have not incorporated the 3 volt limit.  And at
           the end of this current cycle now there has been no
           particular change.
                       Now, there is one interesting item of
           interest which was not given out at the meeting last
           week, and that was in the memo from Travers to Meserve
           in the first CPO situation.
                       South Texas took one of those tubes and
           pressurized it.  They were getting one gallon per day
           before pressurizing, and when they pressurized it to
           simulate an accident situation, they increased it to
           one gallon from that one shoe.
                       That from my memory is the salient point
           that came out of both days.  It was a fairly brief
           presentation last week. But they are not operating at
           3 volts.  They are currently operating at 1.5.
                       DR. WALLIS:  What do you mean operating at
           a certain voltage?
                       DR. FORD:  The voltage that they would use
           during the eddy examinations.
                       DR. WALLIS:  And the higher voltage
           reduces --
                       DR. FORD:  Allows them to operate.
                       DR. SHACK:  It allows more damage in the
           tube before you have to plug it.
                       DR. WALLIS:  Is there a rule about what
           they are allowed to use?
                       DR. SHACK:  Yes.
                       DR. FORD:  95.05 is the rule for big
           quarter-inch tubes, and --
                       DR. WALLIS:  So how did they go to the 3
                       DR. SHACK:  They got an exemption.
                       DR. WALLIS:  Got an exemption, and that is
           the whole thing that we were talking about.
                       DR. SHACK:  They got an exemption because
           they went through a process to lock their tube support
           plate into place by expanding tubes
                       DR. SIEBER:  That's right, but that causes
           additional problems
                       DR. POWERS:  It probably increases short
           term cracking.
                       DR. SIEBER:  Yes.  It is a short term fix,
           and at the end of that short term, it is guaranteed
                       DR. POWERS:  And the point is that the
           plants in Texas are all falling apart anyway.
                       DR. SIEBER:  They are not unique.
                       DR. WALLIS:  What might be the ACRS role
           in all of this except to keep track of what is going
                       DR. SIEBER:  Right.  
                       DR. DUDLEY:  I would say to review and
           comment on the present version of NEI 97-06, and
           understand why the staff has not approved it.
                       DR. POWERS:  I think I was not joking when
           I said people coming in and proposing 20 year
           inspection frequencies are doing so with the objective
           of getting bid down to five.
                       And I would think that the ACRS review
           would say that this is all nonsense and you are going
           to inspect every damn time or something like that.
                       DR. FORD:  But they won't know that until
           we have a presentation.
                       DR. POWERS:  Well, you can't do that until
           you have got the facts, and what the technical bases
           is for -- well, in fact, everybody is going to go to
           a two year fuel cycle.  So you are going to go two
                       There is a substandard question in my mind
           fore the plants with known flaws, and whether two
           years is too long.  Now, those with the better
           materials, where you have an induction period that we
           know from laboratory tests do we give them the
           induction period for the inspections as well?
                       And it is a little hard to do that in the
           absence of more definitive evidence than we derive
           from laboratory tests.  But maybe if we have a lead
           plant, which we do, you can find a justification, and
           then how frequently do you do it after the induction
                       DR. FORD:  Well, it was to get that
           technical information behind the generator change
           package of 97-06, and we needed it in order to be
                       DR. POWERS:  What we can do actually if we
           thought about it carefully, we could assign colors to
           these things and have an action matrix.
                       CHAIRMAN APOSTOLAKIS:  Maybe this is a
           signal that we should close this part of the review.
                       DR. FORD:  That was my final comment.
                       CHAIRMAN APOSTOLAKIS:  Thank you, Peter. 
           Okay.  The next item is that we will hear from our
           Fellow, Jack Sorensen.  He has presented to us his
           work at least a couple of times that I remember on
           safety culture and risk-informing general design
                       The reason for the presentation is just to
           refresh our memory I understand.  You are not going to
           go back and present the whole thing.  
                       And to present the essence of the reports
           are saying, and the hope is that the committee will
           bless the reports, which we assume you have read.
                       DR. POWERS:  If you haven't read them, the
           report on safety culture especially is just superb.  
                       CHAIRMAN APOSTOLAKIS:  Yes, very good
           documents.  We want to send them up to the Commission,
           especially the safety culture report, which has been
           sitting there for a while now.
                       And the GDC as you recall was requested by
           Commissioner Diaz when he came here, and on top of
           everything else, Jack's tenure is coming to an end. 
           I understand that your employment has been extended to
           the end of December?
                       MR. SORENSEN:  I understand that is being
                       CHAIRMAN APOSTOLAKIS:  All right.  Why
           don't we let Jack go through his prepared comments,
           and then we will maybe have a discussion.
                       MR. SORENSEN:  Actually, what I thought I
           would do is focus more on where the Committee might go
           with this issue, and then with the safety culture
           report itself, the rationale being that there have
           been several presentations on the contents of the
                       CHAIRMAN APOSTOLAKIS:  But when you pose
           questions as to where the Committee should go,
           presumably there is some technical basis behind the
           argument if we can find the report.
                       MR. SORENSEN:  Presumably. 
                       CHAIRMAN APOSTOLAKIS:  Presumably.
                       MR. SORENSEN:  Starting with the safety
           culture issue first.  The three questions that were
           posed when I started out on this work a couple of
           years ago were what is safety culture, and why is it
           important, and what can the NRC do about it.
                       And a couple of possible answers to the
           latter two questions are indicated here, and that
           those came out of the work.  The perception of the
           safety culture is important as related to improving
           human performance and reducing latent errors, and
           those issues come up in a good bit of the work that
           has been done.
                       What can the NRC do about it.  Well, the
           two things that are probably non-controversial are
           fostering development of strong safety culture among
           licensees, and identifying performance indicators for
           human performance or safety culture.  With respect to
                       CHAIRMAN APOSTOLAKIS:  Well, I have a
           comment on this.  I think a very important result of
           your work that is in the report that is very relevant
           to the last question is your finding, which I think is
           from the U.K. committee, that no matter what we do
           here, we do affect the safety culture of the
                       It is not like we can sit back and say,
           no, it is their job.  I mean, if we regulate too much,
           then we have a certain influence.  If we regulate too
           little, then we have a certain influence.  
                       I think it is very important for the
           Commissioners to understand that the way we do
           business is an influence on the safety culture of the
           licensees, because that is a different perspective
           from saying as the Commission says right now that, no,
           safety culture is the exclusive domain of licensee
           management, and we don't want to get involved.
                       You are already involved de facto, and so
           the question now is how do you do your regulation to
           foster the development.  I think that is a very
           important point or message to send to the Commission.
                       MR. SORENSEN:  I would certainly agree
           with that, and as we get to the end of my remarks
           here, I had planned to highlight the fact that ny
           personal concern in looking at interactions between
           the NRC and the licensees on this issue, that the NRC
           understand that the regulator, the NRC, understand
           that it can have a negative impact on safety culture,
           and there is probably things that it should avoid
                       CHAIRMAN APOSTOLAKIS:  In fact, I remember
           your report that the British are using us as an
           example of a bad influence.  
                       MR. SORENSEN:  They regard the U.S. system
           as being overly prescriptive from that standpoint.
                       CHAIRMAN APOSTOLAKIS:  Overly
           prescriptive, and that we are having a negative impact
           on the safety culture.
                       DR. WALLIS:  Overly confrontational, too. 
                       CHAIRMAN APOSTOLAKIS:  I don't know
           whether that is a valid technical comment, or is it
           because they lost the colonies.
                       DR. WALLIS:  I think most European nations
           are less confrontational and there is more cooperation
           between the regulator and the --
                       MR. SORENSEN:  Yes, the regulatory
           structure is quite different here compared to
           virtually anyplace else you look.
                       CHAIRMAN APOSTOLAKIS:  And another factor
           that one might bring up is that the period after
           Northeast Utilities that the NRC intensified certain
           things, and if you talk to the utility people, they
           will tell you that the impact was negative on the
           cultural of the industry.
                       MR. SORENSEN:  Speaking as a non-
           practitioner of human factors in general, I would
           suspect that if you look at the historical impact of
           the NRC's enforcement program that it has had a lot of
           negative effects on licensee effectiveness in
           promoting safety culture.
                       CHAIRMAN APOSTOLAKIS:  I think that is one
           of the more important findings, because I think it may
           affect the Commissioners' thinking on the subject,
           which right now is hands off.
                       DR. BONACA:  Your report also, I thought,
           specifically under why is it important, is that it
           fosters safe decisions.  The outcomes are typically
           human performance, and actual latent errors, but there
           are also other decisions that really don't or can
           measure directly to just specific outcomes.
                       But they give a full direction to the way
           that the power plant makes its decisions regarding so
           many different issues.  I think the report talks about
                       MR. SORENSEN:  Yes, clearly one of the
           things that is not understood well is exactly how
           something called safety culture -- well, what is the
           mechanism by which it improves safety of operations.
                       DR. BONACA:  The ultimate results are
           those, of course, but I think it is an important
           intermediate step, particularly when it comes to
                       CHAIRMAN APOSTOLAKIS:  Okay.  The signs
           are not good that you will be done in 20 minutes.  
                       MR. SORENSEN:  I thought it might be
           worthwhile just to look at what formal recognition
           there is of safety culture in the current NRC
           regulatory program.  And it comes up basically in
           three places.
                       There is a policy statement on conduct of
           operations, which says among other things that utility
           management has a responsibility to foster strong
           safety culture.  
                       And that policy statement uses the INSAG
           definition of safety culture and in fact that is
           embedded in the policy statement.  There is a second
           policy statement on safety conscious work environment,
           and that very narrowly focuses on the issue of the
           freedom of employees to raise safety issues without
           fear of retaliation.
                       And the phrase "safety culture" does not
           appear in the policy statement.  I think it appears
           once in the Federal Register Notice in response to a
           question, but safety culture is not part of it.
                       And a third place where safety culture
           comes in is in the identification of cross-cutting
           issues and the reactor oversight program, and they
           identified three, and they are human performance,
           safety conscious, work environment, and problem
                       And then the staff paper makes almost a
           parenthetical reference to safety conscious, work
           environment, as also being called safety culture and
           sometimes called safety culture.
                       I think it is clear that that equation,
           equating safety conscious working environment, and
           with safety cultural, is a much, much narrower
           definition of safety culture than virtually everybody
           else uses.
                       DR. ROSEN:  And in particular I would
           point out that the INPO performance objectives and
           criteria in its most recent revision as a specific
           performance objective on safety culture, along with
           criteria, for their inspectors to look at.
                       So this issue is being dealt with head on
           by the utilities under Info leadership.  
                       MR. SORENSEN:  That is not to say that
           they don't have a role, and I will have a view on that
           separately.  But I just wanted the committee to know
           that that is a fact.
                       DR. POWERS:  It seems to me that the
           question that is going to come peculating up as we
           progress through here is closely there is a safety
           culture within the nuclear community, and the
           regulator has a role in it only if he that that safety
           culture is inadequate or is vulnerable to degradation.
                       CHAIRMAN APOSTOLAKIS:  But if a regulator
           is under the wrong impression but his actions do not
           affect safety culture, it seems to me that is an issue
                       DR. POWERS: I think the question the
           commission keep posing, I don't think they disagree
           with you.  They have their actions as a regulator of
           it, and effect on the safety and culture is do they
           want to explicitly involve themselves in safety
                       And you are saying, well, your actions
           affect the safety culture and they are going to go,
           yes, of course.  Now, that doesn't mean that I have to
           get involved explicitly.  
                       CHAIRMAN APOSTOLAKIS:  It means that I
           have to understand how I do that.
                       DR. POWERS:  No, I don't think so.  Why do
           I have to understand that?
                       CHAIRMAN APOSTOLAKIS:  Because I may be
           doing something wrong, and I don't realize it, and
           that is not a very healthy state of affairs.  
                       DR. POWERS:  But you may not be and so why
           involve a lot of --
                       CHAIRMAN APOSTOLAKIS:  I may not, that's
           true.  Now, there is a statement in a recent document
           from the reactor oversight process that there is
           evidence from the first year of publication that the
           performance indicators do indeed tell the staff
           something about the safety cultures.  
                       In other words, their regional assumption
           is that they don't have to do anything about these
           because if they are not good, we will see it in the
           performance indicators is beginning to be validated.
                       MR. SORENSEN:  I am not sure of the rating
           that you are referring to, but my own sense of it is
           that if you are using hardware performance indicators
           as a measure of human performance, those are still
           going to be lagging indicators.
                       And I think the real interest in
           indicators of human performance or safety performance
           indicators for human performance or safety culture is
           that they would -- is the hope that they would indeed
           be leading indicators, and that they would indicate
           that something is happening before you started having
           hardware failures.
                       DR. POWERS:  If you look for some results
           coming out of the reactor oversight process that are
           indicative of the level of safety culture at a plant. 
           I think we need only look at the longevity of
           corrective actions with respect to fire protection on
           the corrective action list.  
                       I think you will universally find that the
           items with the longest lifetime on corrective action
           lists are fire protection issues.  And what you know
           is that fire protection does not generate kilowatts,
           and consequently it gets the tail end of the resource
                       CHAIRMAN APOSTOLAKIS:  In general the
           whole corrective action program and whatever comes
           with that end of it is an amazing window on the health
           of safety culture in many ways, because it talks about
           the resources assigned to the program, and the
           priorities and the interests, and the willingness to
           clear the issues, the quality of the closure of
           issues, the repeats.
                       DR. ROSEN:  I would say that the fire
           protection program is one slice of it, but the most
           direct indicator that you have, the most integrated
           indicator of safety culture, is the performance of the
           corrective action system.
                       DR. BONACA:  In a global sense,
                       DR. ROSEN:  Which includes fire
                       DR. BONACA:  And I want to say that the
           NRC knows that very well.  When Millstone was in
           recovery, they had tremendous focus, and everybody at
           the company finally understood, and that is really
           where you have to look, because it told you if you had
           enough resources, and it told you where the attention
           of the management was.  
                       It told you all those things, and at the
           end you were not looking at anything else but that. 
           That was really such a focus of the whole nuclear
           review board, the whole management of the NRC,
                       DR. ROSEN:  And it told you about the
           willingness of the staff to bring issues up and the
           receptiveness of management to the fact that the staff
           has brought issues up across the board, even including
           fire protection issues.
                       So the window on the future is always the
           corrective action system.  INSAG says that the
           effectiveness of the organization safety culture
           should be reflected in the performance of the
           facility, coming back to what we talked about before,
           and that is absolutely true.
                       But it is also true that if you look at
           the performance of the facility that it is telling you
           how the corrective action system worked six months
           ago, or a year ago, or two years ago.
                       If it worked very well two years ago, the
           performance of the facility will be good today.  So
           looking at plant Pis today is a lagging indictor as
           you said of the safety culture, which includes at the
           heart of it the corrective action system, and which
           can be a leading indicator.
                       MR. SORENSEN:  If one wants to go beyond
           where we are at the moment, I think it is worth
           recognizing that outside the NRC's regulatory program
           there is a school of thought evolving and being
           articulated in a number of places that fostering
           safety culture is the third stage, or the most evolved
           way of implementing a safety management or safety
           regulation program.
                       The early view is that -- I'm sorry, but
           the initial basis for a safety program was
           concentrating on outcomes.  You prohibit outcomes or
           consequences that you think are unacceptable and
           punish people if they don't avoid those outcomes.
                       The second stage is prescribing actions
           which is basically the philosophy that is underlying
           our current regulatory scheme in the United States;
           and the third stage of evolution is fostering safety
           culture, and basically letting the licensee's do what
           they need to do to run their business as long as they
           meet whatever safety goals you set for them.
                       I would point out that with respect to the
           changes that are going in within the NRC reactor
           oversight program in particular, the underlying
           regulations have still not changed.  
                       I mean, the regulations that are being
           enforced are still basically the same regulations that
           we have had for the last number of years, and the
           issues are still compliance issues in the final
                       I guess the question that one might pose
           for the committee is whether you want to at some point
           recommend that the NRC do more with respect to
           encouraging the development of strong safety cultures,
           or evaluating that the strength or impact of licensee
           safety cultures.
                       And I suggested three possible answers
           here.  Dana came up with a fourth one.  There is
           probably as many possible answers as there are people
           in the room.  
                       The first possibility is yes, and as
           George pointed out a few moments ago it is too
           important to ignore and the agency is already dealing
           with it in some form anyway.  
                       The second, which I suspect might be an
           answer from many of our industry friends, is that
           basically the issue is too important for the regulator
           to get too closely involved in.  It comes too close to
           the heart of managing the facility.
                       And you could also decide no because we
           really don't understand how a safety culture affects
           the safety of operations, even if we believe strongly
           that it does.
                       If one starts down that path the first
           thing you will run into is the SRM --
                       DR. ROSEN:  Which path do you mean by
           "start down that path?"  
                       MR. SORENSEN:  Of doing something, sorry. 
           If you start down the path of yes, you would like to
           see the agency do more than it is doing now.  The
           first thing you run into is the staff requirements
           memo from SECY 98-059, which basically says efforts to
           develop leading indicators of performance should not
           use licensee management performance or confidency as
           an input.
                       And concludes by saying that the
           Commission approved the elimination of any Fiscal Year
           '98 funds and subsequent years as well.  Research
           expenditures specifically directed at developing a
           systematic method of inferring management performance.
                       And when you discuss the issue of safety
           culture, and particularly with the human factors
           people here at the agency, they invariably point to
           this memorandum as prohibiting them from looking into
           safety culture issues.  
                       And I think it has had a significant
           effect on the planning in the human performance area. 
           I would suggest that there in fact is room to explore
           what that memo actually says and what it was intended
           to say.
                       And what if anything you can do in terms
           of research or development without impinging on the
           Commission's intent here.  And I think it might be
           useful to view the challenge for the staff as being
           one of framing the issue of safety culture in such a
           way that they can look at it without impinging on
           licensing management prerogatives.  And I think there
           should be a way of doing that.
                       DR. WALLIS:  How would you look at it
                       MR. SORENSEN:  Well, I am not a human
           factors person.  I'm not sure, but it just seems
           possible to me.  And I am probably looking beyond the
           intent of the Commission in this SRM.  This was a
           response to a paper -- and I have forgotten the
           precise title of it, but it was options for evaluating
           the confidency of licensee management.
                       And having worked as a technical assistant
           for a Commissioner for a few years, I can assure you
           that the wording of the options in that memo were
           phrased in such a way that it would inevitably draw
           not only a no, but a hell no, from any Commissioner
           that voted on it.  And that is exactly what happened.
                       DR. POWERS:  You suspect that it was --
           that the titling was deliberate to ensure that they
           would get that response?
                       MR. SORENSEN:  I expect -- well, I can't
           put myself in the mind of the people who wrote it, but
           I would be surprised given the way the paper was
           worded if the staff expected any other outcome.
                       I think what may have been a surprise was
           this wording probably went further than the staff
           expected.  I don't think that as fallout that they
           expected that the Socrates work at Idaho National
           Engineering Laboratory would be canceled, which is
           what that last paragraph refers to.  
                       DR. POWERS:  They may have had additional
                       MR. SORENSEN:  Possibly.  So I think this
           is something that might well be worth a look.  In a
           somewhat broader sense, the areas that appear to be
           possibly interesting for additional human factors
           research are the ones that I have listed here.  
                       And independent on this paper of safety
           culture, I did a critique of the human factors program
           for Dr. Powers as input to the ACRS report on the
           research program at the end of last year.  
                       Most of you have probably not read that,
           but it is probably worth reading in conjunction with
           the safety culture paper, because if you are going to
           somehow influence the human performance agenda here at
           the agency, you need to go back to the research folks
           with some kinds of suggestions.
                       DR. ROSEN:  But with all due respect, why
           do we think we need to do more research on the issue? 
           My take is that it is as important as you suggest to
           the ultimate safety of this enterprise, but that we
           understand in some fairly good detail how safety
           culture impacts the safety of operations.
                       And we don't need to research that any
           more.  What we need to understand as a regulating
           community is how we cannot have or at least do no harm
           and potentially help.
                       MR. SORENSEN:  Well, one of the things
           that strikes you in going through the literature or
           struck me is the lack of empirical information in the
           nuclear power generation business that relates safety
           culture to safety of operations that have been good
           statistically strong studies done in transportation of
           chemicals and so forth.
                       Those have simply not be done in the
           nuclear business.  If the committee, for example, is
           willing to mentally translate the results from the
           chemical industry into the nuclear business, then I
           think the case is made if that is sufficient evidence,
           but it hasn't occurred in the nuclear business.
                       DR. ROSEN:  I will grant you that, but I
           will also say that there are some of us on the
           committee who feel they have lived this issue for the
           last 30 years of a life and have a fairly good feel
           for how it works.
                       So I don't see it personally that research
           is the issue or is needed.  I think we need to grapple
           with what we do about it.
                       DR. BONACA:  I think one of the focuses of
           the research has been to try to find the connection
           between the safety culture and equipment performance,
           for example.  That is very difficult to measure.
                       That is very difficult.  There are a lot
           of assumptions that are being made there, but there
           are areas where one could look and find some
           dependence.  The other is one area that we were
           discussing before about the impact of the regulator on
           the safety code.
                       And this is very significant.  If you look
           at right now the new ROP, the ROP has in it a
           significant examination process, and really assesses
           risk significance.  But if you look at the focus, for
           example, in some of the recovery actions for power
           plants, it drives the operator of the plant to focus
           on compliance.
                       The whole issue then becomes compliance,
           irrespective of whether or not that becomes safety
           significant, because the licensee is so worried about
           performance as measured by the regulator that he just
           looks at compliance.
                       And you go back to the guys and say wait
           a minute now.  Is this safety significant or not, and
           they say what do you mean.  Compliance becomes their
                       CHAIRMAN APOSTOLAKIS:  In that context,
           you remember that some leaders of industry wrote a
           letter to the Commission complaining about the
           initiating event performance indicator, and which
           includes all sorts of SCRAMs, and they said such a
           regulatory requirement would have a negative impact on
           the operator.
                       DR. BONACA:  So this issue is an example
           of a regulatory requirement that might have a negative
                       CHAIRMAN APOSTOLAKIS:  And this committee
           has also commented on the shutdown DIs, and where they
           said, look, it normally takes 6 hours to do this job
           and so the performance indicator would be how many
           extra hours did you spend.
                       And the industry comes back and says wait
           a minute now, we wanted to be cautious, and it was the
           right thing to do, and you are telling us that you are
           going to punish us.  So, you see, all these things
           inadvertently affect safety culture. 
                       DR. BONACA:  Well, the point you were
           making in the beginning is that would be an important
           communication point to the Commission for the
           understanding of how the staff itself and the
           Commission is influencing the safety culture.
                       CHAIRMAN APOSTOLAKIS:  And coming back to
           the point that Steve made reminded me of something,
           and that may require some research.  I don't know if
           research is the right word.  
                       I have heard from many people with
           experience in the utility business that you, and Jack,
           and Mario have, that they can walk into a plant and
           have never been there before, and in 5 or 10 minutes
           they can tell whether this is a good, well run plant,
           or not. 
                       DR. SIEBER:  A little longer than that.
                       CHAIRMAN APOSTOLAKIS:  15 minutes then.
                       DR. ROSEN:  Spend a day.
                       DR. SIEBER:  A week is better.
                       DR. ROSEN:  And it is not just about
           looking at the equipment.  It involves a lot of
           talking to people.
                       CHAIRMAN APOSTOLAKIS:  Let me complete my
           thought.  And I remember that I was also impressed
           many years ago when we were doing PRAs down in
           Southern California when one of the engineers for the
           first time, a very experienced guy, went to
           Switzerland because they had just won a contract to do
           a PRA for a Swiss plant.
                       The guy came back after a few days of
           visiting there and he was ecstatic.  I can't believe
           how these guys run their plants.  It is beautiful.  I
           said how do you know, and he says, well, you know, you
           walk in there and you talk to people, and you observe
           things, and you know that they are doing a good job.
                       Now, what is missing is capturing that
           empirical knowledge.  Now, Jack mentioned once that if
           I see Pepsi cans left here and there, and is that a
           performance indicator?  Is there something else?  What
           is it that you are looking for?
                       DR. WALLIS:  Safety culture is only part
           of the question if this is a well run plant.  You
           can't equate the two.
                       DR. SIEBER:  It is a big part though.
                       DR. BONACA:  And then it goes into every
           aspect.  When you go into a Swiss plant, and it is
           like a ghost town, and you are in the parking lot and
           where are the people, and there is like 40 cars.  It
           is in the middle of nowhere and there is nothing else. 
           What is happening in this plant.
                       Well, one-fourth of the plant is being
           down for maintenance, and you walk in the plant and
           everything is quiet, and you go in the control room
           and there are no alarms, and it's like is this plant
           running right now.  
                       I mean, there are so many quick indicators
           telling you that things are being taken care of. 
                       CHAIRMAN APOSTOLAKIS:  And how about Coca
                       DR. BONACA:  And they offer you a glass of
           wine at the end of the tour.
                       DR. ROSEN:  You posed the question,
           George, and the answer -- and it is a long answer, but
           I am reminded of being in a plant many years ago and
           asking one question, which set the tone for the rest
           of it.
                       I asked a maintenance person or manager
           how much -- what percent of your preventive
           maintenance is deferred, and he looked at me like I
           had just arrived from Mars, and he said we do
           preventive maintenance on schedule.  We don't defer
           any preventive maintenance.  
                       Preventive maintenance is something that
           you know is coming and it is on the schedule, and your
           people are trained, and your procedures are in place.
                       And the plant's condition is set so that
           you can take the components out of service, and you
           have the spare parts, and you go in and you do it.  So
           we have none, zero, point zero, and I thought to
           myself that was the right answer.
                       And yet at that time in the industry there
           was a lot of preventive maintenance being deferred.
                       DR. SIEBER:  About 10 years ago there
                       DR. BONACA:  The other issue is
           recognizing problems.  If you go inside and you see
           stuff, and it is not even being brought up as a
           problem to the corrective action program because we
           always run it that way, or that valve is that way and
           it is no problem because we always did it that way.  
                       That is an indicator that you need to look
           at, because it means that the threshold is there for
           identifying something as a problem is very high. 
           People are just used to doing things like that
                       DR. FORD:  If I could make an analogy.  At
           GE, they have a thing called GE Values.  Now, people
           laugh at it, and I bring it up in this context because
           if you are talking about something that is not easily
           quantified, the way this came about was that Jack
           Welsh wanted to introduce something new into the
           company, but he didn't know what it was.
                       So he went around and asked all his senior
           A player people what they thought had been successful,
           including safety.  And they ingested that into a
           series of 10 items, which would be non-quantifiable,
           but they were examinable.  
                       And maybe this is a way of approaching
           this, and is to have a set of experts go around and
           say what does your brain tell you is a good run plant.
                       CHAIRMAN APOSTOLAKIS:  It should be a
           combination.  I think we are getting off on a tangent
           now, but it should be a combination of smart
           questions, like the one that Steve just gave us, and
           I am sure that Jack Welsh had similar questions, plus
                       And I will give you an example of the
           wrong way of doing it.  Someone sent me a paper or a
           report several weeks ago from Europe, where they said
           we are going to do questionnaires to define the safety
                       So they go to the plant and asked are you
           putting safety first, among other things.  So the
           results come out with 99 percent certainty, yes, we
           put safety first.  
                       Then they have a meeting and they announce
           the results, and the management of the plant says this
           is the greatest study we have ever seen.  It
           represents us exactly the way we are around this
           facility.  I mean, is that a question to ask?  What
           would you expect the guy to say?  No, I don't put
           safety first?  Anyway, let's go on.
                       MR. SORENSEN:  Okay.  This is as far as I
           had planned to go with the safety culture paper. 
           These last three items are the ones that I would
           recommend attention to, as opposed to the first three.
                       CHAIRMAN APOSTOLAKIS:  Can we move on to
           the GDCs?
                       MR. SORENSEN:  Surely.
                       DR. ROSEN:  And we will come back to
           deciding what we will do with this as a committee?
                       CHAIRMAN APOSTOLAKIS:  Yes.  
                       DR. ROSEN:  We can't just leave it here. 
           We either have to say yes, no, or maybe.
                       CHAIRMAN APOSTOLAKIS:  That's right.  But
           maybe not right now.  Maybe in the afternoon sometime.
                       MR. SORENSEN:  Just to spend a couple of
           minutes on the general design criteria paper.  This
           was something that I put together at Dr. Apostolakis'
           request, which I think grew out of a conversation that
           he had with Commissioner Diaz.
                       CHAIRMAN APOSTOLAKIS:  He asked us here
           when he came here.
                       MR. SORENSEN:  Actually, I went back and
           looked at the transcript and I couldn't find it.
                       CHAIRMAN APOSTOLAKIS:  Then maybe you are
           right.  It came from Commissioner Diaz.  He was here,
           but he also talked to me privately.
                       MR. SORENSEN:  In any event, the idea was
           to take a look at the general design criteria,
           essentially in isolation and see to what degree they
           were an impediment or might be an impediment to risk
           informed regulation and how one might change them.
                       The underlying objective is clearly when
           you read them to reduce probability and consequences
           of reactor accidents.  But the regulatory standard
           that is applied is embedded in Appendix A as
           reasonable assurance that the facility can be operated
           without undue risk.
                       And this of course is an adequate
           protection standard.  It is not a risk metric.  There
           are basically three ways that one can go about
           changing the GDC to make them more risk informed.  One
           is to modify the scope. 
                       This is essentially the approach the staff
           I believe is still taking with Option 2 of the
           development of risk informed regulation.  And the idea
           here would be to change the scope from important to
           safety which is an adequate protection issue, to
           important to risk, and you can define risk however you
           want to.  
                       But that could be a fairly sweeping
           change, and change it in a couple of places and it
           would have a major impact.
                       The second way you could deal with the GDC
           is to modify individual requirements, and this is
           essentially what the staff should be doing under
           Option 3, is developing risk informed regulation.
                       I don't know where either Option 2 or
           Option 3 are going to come out on recommending changes
           to the GDC.  
                       And the third option is to replace them
           completely with safety goals or risk acceptance
           criteria, which is Dr. Kress' proposal, which is in
           the appendix to the report.
                       CHAIRMAN APOSTOLAKIS:  I remember that Dr.
           Powers had problems with that.
                       MR. SORENSEN:  Well, somebody is going to
           have to write design criteria that relate to whatever
           fundamental design goals you have, including risk
                       I think the question is whether such
           criteria should appear as part of the regulations,
           which they do now in Appendix A to Part 50; or whether
           they should be in some other document.
                       If you are dealing with light water
           reactor technology as we are right now, somebody is
           going to write down something very similar to these
           general criteria if they are going to design a new
           plant with this technology.  And I think the question
           is just where might that guidance appear.
                       CHAIRMAN APOSTOLAKIS:  Dana's question
           some time ago was if you replace a GDC with safety
           codes or risk acceptance criteria, where would you ask
           the licensees to have a negative coefficient to the
                       MR. SORENSEN:  It could be in a regulatory
                       CHAIRMAN APOSTOLAKIS:  But why?  If
           everything is safety goals oriented, how would that
           come about?  I believe that was your point, Dana,
           wasn't it?
                       DR. POWERS:  Right.
                       DR. KRESS:  Well, you don't have to make
           it exclusively saying you shall meet a risk acceptance
           criteria to give it a confidence level, and go off and
           do it.  You can say you must do it, but you must also
           pay attention to specific things.  Like you must have
           a good negative power coefficient.
                       DR. POWERS:  Yes, and you have a bunch of
           general design criteria.
                       DR. KRESS:  But they would not be so
           specific and descriptive.  It would be that you must
           have an effective and acceptable negative power
           coefficient, and you must deal with shutting down the
           reactor other than by power coefficient. 
                       You must have ways to cool it after you
           shut it down.  You could specify these kind of design
           criteria, and then say after you have met the specific
           needs of the reactor, then you could say and by the
           way you must meet our safety goal at a given
           confidence level.
                       And that would take the general design
           type areas and squeeze them down to this, and make
           them applicable to any reactor.
                       DR. POWERS:  I bet you if you sat down and
           said, okay, agency, here are the new standards and
           GDCs, but the number of GDCs you would have would be
           no smaller than the current inventory.
                       DR. KRESS:  Well, I bet you could.  How
           many have we got?
                       MR. SORENSEN:  We have 55 GDCs.
                       DR. KRESS:  I can't even envision 55 to
           capture the concept that I had in mind.
                       DR. POWERS:  Gosh, I can.
                       CHAIRMAN APOSTOLAKIS:  So maybe the word
           replace should be replaced, because I think even in
           Tom's --
                       DR. KRESS:  Yes, even in my concept, I
           would have some of this structural specification --
                       CHAIRMAN APOSTOLAKIS:  You what?  I
           thought that was on your side.
                       MR. SORENSEN:  Okay.  The next list is
           just a recounting of the kinds of changes one might
           make to make the GDC more risk informed or I phrased
           it in terms of impediments.  
                       Current scope is important to safety, and
           Appendix A includes the definition of a large break
           LOCA as the design basis accident, a double-ended
           guillotine break of the largest pipe.
                       The requirements for redundancy,
           diversity, and independence in the individual criteria
           are highly specific, and undoubtedly more specific
           than they need to be or just any in a risk metric of
           some sort.
                       Defense-in-depth requirements are not
           differentiated from reliability requirements if you
           read one of the criteria or any one criteria. 
           Sometimes it is obvious that it is defense-in-depth
           and a lot of times it is not.  Was the author looking
           for high reliability or was he looking for defense-in-
                       Requirements to provide a system or a
           function are not tied to risk reduction.  There is no
           nexus between the requirement for a particular system
           and meeting a risk metric.  And the same is true of
           the inspection and test requirements.
                       DR. WALLIS:  I guess that is what I was
           getting at with my last point, is that there has to be
           some cross-correlation or there has to be some kind of
           coefficient showing how much does this requirement
           influence risk reduction so that you can have some
           idea of the interplay between these requirements and
           what you are trying to achieve.
                       MR. SORENSEN:  From a designer standpoint,
           at some point in the design process you have got to
           allocate the risk of various scenarios against your
           total risk goal.  That allocation happens.  
                       Generally, people have tried to avoid
           specifying what the allocation is, but if the
           regulator doesn't do it, the designer is going to, and
           it will happen in the design process.  
                       And if you have a design that does not
           meet your risk metric, then you end up going back and
           changing it.
                       DR. WALLIS:  Well, I would go back to what
           I said before.  I think it is really all cost benefit. 
           I mean, requirements pose some costs and there is some
           benefit in terms of reduced risk, and that is the
           equation you would love to make if you could.
                       MR. SORENSEN:  Okay.  The final comment I
           guess on the GDCs is the conclusion that I came to,
           and --
                       DR. ROSEN:  Why did you skip the
           absolutist language?
                       MR. SORENSEN:  Oh, I'm sorry.  I keep
           trying to make sure that Dana doesn't get a chance to
           say anything about that.  This was an issue that Dana
           had raised fairly early, and I ended up not seeing it
           as not a problem, which I think he still disagrees
                       How do you decide, for example, in
           providing protection against natural phenomena, and
           how do you decide how severe that phenomena should be,
           and what time scale do you use.  
                       And his point I think was that if you look
           at something like criterion, too, that it really is
           not clear whether you have to look at a 50 year flood
           or a hundred year flood, or a flood that might have
           occurred on a geological time scale.
                       And I think that Dr. Powers saw several of
           the criteria that needed improvement in that area.  I
           didn't see a problem with the way that they are worded
           right now from that standpoint.
                       DR. POWERS:  What I see when I look at
           them is the same problem that we had with 50-59.  They
           come along and say thou shalt not create a
           vulnerability with this change.
                       Well, there is always some risk associated
           with something, and there was no way to accommodate
           can you increase the probability of an accident.  
                       Well, if I increase it from 10 to the
           minus 13th, to 10 to the minus 11th, that is a two
           orders of magnitude increase, but it is minuscule no
           matter what.  But within the languages interpreted by
           the lawyers that is still an increase and therefore a
           violation, and you couldn't do 50-59.
                       And we had to go and correct 50-59 to get
           it out of that problem.  And the problem came about
           simply because the level of precision with which we
           handle probablistic and risk language is so much
           higher now than at the time that the regulations were
                       And that things that were just not a
           problem before, and when you only calculate risk to
           within two orders of magnitude that it does not move
           you from one risk category to the next.  And now when
           you put decimal points on the risk numbers, you could
           see a change that big.  And I think the general design
           criteria suffer from those things.
                       Jack seems to be very clever at finding it
           out every time I bring one up, and says, oh, but this
           clause up here lets you out of this thing.  I persist
           in my belief that these things are going to go along
           and some day somebody is going to come along and will
           run a foul of the same language difficulties with the
           lawyers that we did with 50-59 and we are going to
           have to fix it at that point.
                       And we might as well fix them in some sort
           of a rational fashion than just to go through and fix
                       MR. SORENSEN:  And the last point, and
           sort of the overall conclusion.  I think that the GDC
           are very important and an important element in risk-
           informed Part 50, but if you change the GDC without
           changing anything else, you probably haven't gained
           very much.
                       And in particular I note that there is 129
           regulatory guides that address one or more aspects of
           the general design criteria.  Part 50 incorporates the
           ASME code, at least Sections III and XI.  And there is
           a Section VIII now, too, I think.
                       DR. POWERS:  And the truth of the matter
           is that it works the other way.  You go in risk-
           informed with Part 50 with respect to the ASME code,
           you probably are going to file other GDCs.  You can't
           change the other things without having to change
                       It always struck me that it is easiest to
           go back and risk inform the GDCs and then move to the
           regulations, rather than doing the regulations and
           then moving to the GDCs.
                       DR. ROSEN:  I think you stuck up a straw
           man and knocked him down here, Jack.  The whole idea
           is that if you risk-inform the GDCs, then you have to
           risk-inform all the Revision One regulatory guides.  
                       I mean, it is a system.  You can't just go
           in and do this, and not see what else it affects.
           You go ahead and do it, and you follow each of these
           trails down to the conforming standards or Reg Guides
           and fix them, too.
                       MR. SORENSEN:  I had understood the
           question posed by Commissioner Diaz as implying
           strongly that the GDC were a key in some sense.
                       CHAIRMAN APOSTOLAKIS:  Yes, they are an
           impediment to risk-informing Part 50. 
                       MR. SORENSEN:  I guess I had understood
           the implication to include the belief that a huge step
           forward could be made by risk-informing the general
           design criteria, and I am just saying you have to do
           all of them.
                       DR. ROSEN:  All of it. 
                       CHAIRMAN APOSTOLAKIS:  All of it meaning? 
                       MR. SORENSEN:  The GDCs, as well as the
           supporting regulations.
                       DR. POWERS:  Nobody is going to argue with
           over that.  Again, everybody is going to say you have
           to do everything, but that's not what they are doing. 
                       CHAIRMAN APOSTOLAKIS:  Okay.  Is there
           anything else?
                       MR. SORENSEN:  No, that's all I had.
                       CHAIRMAN APOSTOLAKIS:  So does the
           Committee want to decide what to do with the reports
                       DR. ROSEN:  I would like to have some time
           to discuss it with the Committee.
                       CHAIRMAN APOSTOLAKIS:  Then let's do it
           after lunch then.  We will reconvene at 1:20.
                       (Whereupon, the meeting was recessed at
           12:20 p.m.)

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