486th Meeting - October 5, 2001
Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title: Advisory Committee on Reactor Safeguards
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
NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
486TH ACRS MEETING
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OCTOBER 5, 2001
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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
Designated Federal Official
DR. JOHN T. LARKINS, Executive Director
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
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
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
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,
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
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,
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
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
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
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
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
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
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-
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
DR. BONACA: Are you accepting that this
not going to be happening again? I mean --
MR. AULICK: Well, that is an open item,
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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-
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
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,
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
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
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
DR. POWERS: It probably increases short
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
There is a policy statement on conduct of
operations, which says among other things that utility
management has a responsibility to foster strong
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
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
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
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
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
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
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
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
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,
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
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
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
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,
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
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
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
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
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,
DR. ROSEN: Why did you skip the
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
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
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
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
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