Plant License Renewal - September 23, 1999
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
***
MEETING: PLANT LICENSE RENEWAL
Room 2B-3
White Flint II
11545 Rockville Pike
Rockville, Maryland
Thursday, September 23, 1999
The subcommittee met, pursuant to notice, at 8:30 a.m.
MEMBERS PRESENT:
MARIO V. BONACA, Chairman
THOMAS S. KRESS, ACRS Member
WILLIAM J. SHACK, ACRS Member
ROBERT E. UHRIG, ACRS Member
JOHN J. BARTON, ACRS Member
JOHN D. SIEBER, ACRS Member
. P R O C E E D I N G S
[8:30 a.m.]
DR. BONACA: Good morning. The meeting will now come to
order.
This is a meeting of the ACRS Subcommittee on Plant License
Renewal. I am Mario Bonaca, Chairman of the Subcommittee.
ACRS members in attendance are John Barton, Thomas Kress,
William Shack, Robert Uhrig, and John Sieber.
The purpose of this meeting is for the subcommittee to hear
presentations from the staff concerning development of license renewal
guidance, resolution of license renewal issues, standardization,
standardizing the format for license renewal applications, the status of
the staff review of the Calvert Cliffs and Oconee applications, and
associated activities.
The subcommittee will gather information, analyze relevant
issues and facts, and formulate proposed positions and actions, as
appropriate, for deliberation by the full committee.
Mr. Noel Dudley is the cognizant ACRS staff engineer for
this meeting.
The rules for participation in today's meeting have been
announced as part of the notice of this meeting previously published in
the Federal Register September 3, 1999.
A transcript of this meeting is being kept and will be made
available as stated in the Federal Register notice. It is requested
that speakers first identify themselves and speak with sufficient
clarity and volume so that they can be readily heard.
We have received no written comments or requests for time to
make oral statements from members of the public.
The subcommittee met on April 28-29 and June 30-July 1, 1999
and heard presentations on the Calvert Cliffs and Oconee license renewal
applications.
On the basis of these meetings and the associated ACRS
committee meetings, ACRS issued interim letters on the staff
evaluation of reports related to the license renewal applications.
The subcommittee plans to use the information presented
today to develop a strategy for more efficiently reviewing staff's
evaluation reports and to establish a schedule for reviewing selected
issues.
I request that the staff, during its presentations, provide
suggestions as to when ACRS review of specific issues will add the
greatest value to the license renewal process.
We will proceed with the meeting and I call upon Mr.
Christopher Grimes, Chief of the License Renewal and Standardization
Branch, to begin.
MR. GRIMES: Thank you, Dr. Bonaca. My name is Chris
Grimes. I'm the Chief of the License Renewal and Standardization
Branch. Dave Matthews, who is the Director of the Division of
Regulatory Improvement Programs, will be joining us.
This is a very timely meeting. As many of you may know,
projection for the number of license renewal applications over the next
several years is expected to increase dramatically. We have two
applications scheduled for submittal in the near future. Arkansas is
planning on submitting its license renewal application in December of
this year and Hatch is expected to submit its license renewal
application in February.
In the subsequent years, we're expecting or we're planning
for four license renewal applications in fiscal year 2001 and four in
2002, and the information that we have is that by 2003 to 2005, we could
be working on as many as seven to ten applications at any time. So the
purpose of today's meeting is to concentrate on where we stand relative
to developing guidance for the conduct of the license renewal reviews,
to describe our plans for responding to the Commission's staff
requirements memo on credit for existing programs, to focus on areas
where programs need to be augmented for the purpose of aging management.
We're also going to reflect on how we got to this point
based on the developmental work that was derived from the nuclear plant
aging research program that began back in 1982, and then we're going to
discuss the status of the Calvert Cliffs and Oconee applications.
We intend on coming back to the committee to discuss the
resolution of the open items, but by discussing the status of those two
renewal applications, it may give you some insights into process means.
So for that reason, we can talk about where we stand
relative to the review of the first two applications in order to provide
some insights for developing ideas and strategies on how to make the
review effective, efficient and realistic using the terms from the
strategic performance measure that we feel is most appropriate at this
point to the future of license renewal.
We're going to begin the staff's presentations with a
discussion about the development of license renewal guidance and I will
ask Mr. Matthews if he has any other opening remarks, before we turn it
over to the staff presentation.
MR. MATTHEWS: No. I don't have any additional remarks this
morning. Thank you.
MR. GRIMES: With that, I'd like to introduce Sam Lee, from
the License Renewal and Standardization Branch, and Jit Vora, from the
Office of Research, and they're going to discuss the development of the
license renewal guidance.
DR. LEE: Good morning. This is the schedule, and now we
are on the development of license renewal guidance. My name is Sam Lee,
from NRR, and I have Jit Vora, from Office of Research.
The license renewal rule requires aging management of
long-lived passive structures and components. In the initial license
renewal applications, we found that most of the license renewal programs
are existing programs.
So NEI raised a question on credit for existing programs;
that is, to what extent should the staff review existing programs relied
on by an applicant to manage aging for license renewal.
This was raised as a policy issue to the Commission and the
staff prepared an options paper, SECY-99-148, and the staff made a
recommendation to do a generic evaluation of existing programs and focus
the standard review plan for license renewal on areas where existing
programs would be augmented. We briefed the ACRS and we received ACRS
endorsement.
And similar to that, the Commission also approved the
staff's recommendation and directed the staff to develop this generic
evaluation, which is called the generic aging lessons learned, the GALL
report, and to develop the SALP and the reg guide, and have stakeholder
involvement.
We plan on issuing these documents for public comment and we
are to brief the Commission on the public comments and then request the
Commission approval to publish these documents.
Also, in the SRM, the Commission indicated that after the
staff had reviewed additional license renewal applications, we should
return with our recommendation on whether we should undertake rulemaking
to provide credit for existing programs.
Now I'm going to talk about these reports, the GALL, the
SALP and the reg guide, in more detail.
GALL is a generic evaluation of existing programs to manage
aging. If the program is found adequate, the GALL will document the
basis for that determination. If certain things are needed in addition
to what people are doing today, then GALL will identify these areas, so
that they would be augmented for license renewal.
Previously, staff contractors had published a contractor
report on GALL, which is a compilation of plant aging information. I'll
get into that later. We plan on extending that study to review the
aging effects, identify existing programs, and actually evaluate the
elements of the program to determine if they're adequate to manage aging
for license renewal.
Some of the elements are the scope of the program, does it
cover the right structures and components, what kind of inspection
method are people using, is the inspection adequate to find certain
aging effects, and what kind of acceptance criteria do they have, what
kind of corrective action.
The GALL right now is being conducted by Argonne and
Brookhaven as contractors to the staff and they have prepared a draft of
the report and it is now under staff review.
We plan on involving stakeholders and, for example, we
believe the industry can provide information on existing programs that
can be evaluated by the staff in GALL, also.
This is the standard review plan for license renewal that's
in the staff recommendation and the Commission SRM. We are going to
focus the staff review on areas where existing programs should be
augmented for license renewal. This will reference GALL for the credit
for existing programs and one of the things that we are to work out is a
template in terms of how to take GALL and kind of propagate it into the
SRP. So we still have to work that out. If GALL says this program is
adequate, the reviewer has to look. If GALL says it's not adequate,
what the reviewer has to do.
Another thing is that once GALL identifies there are certain
things that need to be augmented, the SRP needs to provide guidance on
an acceptable way to augment a program. So those things needed to be
developed. Also, we need to incorporate lessons learned from the
initial license renewal application reviews and the license renewal
issues.
You will hear about license renewal issues, I guess, in a
subsequent presentation.
Another thing is to improve the efficiency of the review.
The SRP should match the format of the application and this is one of
the things that we have been working on with NEI.
So we can have the next slide.
We have been working with NEI on the standard format for an
application and this is what I guess the staff proposed to you in
August. We have a couple iterations on that, and now we have NEI's
general agreement on this format. This follows the structures of the
rule. So the first section of the application would be administrative
information, like plant ownership, plant license and proprietary
information type of statements. Section 2 is on the structures and
components for license renewal. This is on the scoping methodology to
identify these structures and components and the results of their
scoping. Three is the aging management. This is the bulk of the
application, which is aging effects, aging management programs and such.
Section 4 is the time-limited aging analysis. This is
analysis that has been performed for 40 years of plant operation and we
need to evaluate how that will continue for license renewal.
Then we have sort of an appendix here, on the FSAR
supplement to summarize the aging management programs, and the
time-limited aging analysis for license renewal.
And the intent is to have the SRP actually match the
application one for one. So hopefully we have a Section 1 of the SRP
that will address the first item, and Section 2 would match the Section
2, so on and so forth.
We also have a reg guide on license renewal. NEI previously
developed Industry Guidance 95-10. This is on the implementation of
license renewal. The staff issued a draft reg guide for public comment
to endorse this 95-10 document. Now we plan on having NEI to revise
95-10 to incorporate what is ongoing activities and then we will revise
95-10 for endorsement in a reg guide.
DR. SHACK: Do you have NEI buy-in to this process?
DR. LEE: Say that again?
DR. SHACK: Do you have NEI buy-in to this process?
DR. LEE: I believe we have, yes. Do you want to say
something, Doug?
MR. WALTERS: Doug Walters, from NEI. I'm not sure exactly
what you're referring to when you say the process, but I will tell you
we just signed a letter out and gave it to Mr. Grimes denoting our
agreement with the standard format.
DR. SHACK: And the process for essentially incorporating
the GALL into 95-10?
MR. WALTER: Yes. I think, in general, we agree with that.
Obviously, we haven't see the specifics and we're getting some of that
today, but I think, in general, yes, we would agree.
DR. LEE: Thank you, Doug. And here is the draft schedule
for some of the milestones. This has not been approved by management,
but this shows the current staff thinking.
One milestone is a workshop on the draft SRP, mostly likely
in November, and, also, the issue of the draft SRP, GALL and 95-10 reg
guide, about summer next year. Then there is a Commission briefing on
public comments and here is Commission approval of SRP. This is early
2001 and prior to that, we will brief the ACRS and request a letter to
support the Commission approval.
We will be having, I guess, meetings with ACRS to keep you
updated on the current activities. But these are just some milestones
that we need a letter from ACRS at that point.
Also, we will be briefing the Commission on the option to
have rulemaking, probably like 2001, late in 2001. By that time, we
will have, I guess, Arkansas, Hatch, and Turkey Point under review at
that time.
MR. GRIMES: Sam, I'd like to comment that when we put this
schedule together, we recognized that it's a fairly ambitious schedule,
but that's an expectation. The Commission is anxious to see the
standard review plan and GALL processed, to achieve some stability and
predictability.
So what's most important to this schedule is biting off what
we can chew. So we will be looking at taking the largest chunk of work
that can be digested in the shortest period of time, and that's one of
the things that I would set out in that first milestone, meeting with
NEI to develop a scope of effort that can be achieved in this timeframe.
The Commission also recognized in the staff requirements
memo that the guidance would likely become living documents, like the
standard review plan is today. So we're going to talk a little bit
about generic renewal issues and how we've gone through and prioritized
those and I would expect that the process would continue in the future,
where we constantly look across an inventory of recommendations and
issues to address and concentrate on getting the most bang for the buck,
getting the most work accomplished in the shortest time, in order to
achieve a maximum amount of efficiency and effectiveness in the process.
DR. LEE: Now we are going to give you the background of
GALL. This is a contractor-prepared document, I guess, back in '96.
It's called GALL and it is an extensive compilation of plant aging
information.
It is based on the Office of Research's nuclear plant aging
research program, NPAR, and Jit will explain what is NPAR in more
detail. It also consists of NUMARC, the Nuclear Management and
Resources Council, NEI's industry report on managing aging of major
plant components for license renewal, and they cover reactor vessels,
reactor vessel internals, containment, structures, piping, that kind.
It also covers operating experience, the LERs and generic
communications. But the bulk comes from the NPAR program.
And now I will turn it over to Jit, from the Office of
Research, and he'll give you more on the NPAR program.
MR. VORA: Thank you, Sam, and good morning, Mr. Chairman
and members of the committee. My name is Jit Vora and currently I'm a
team leader for the license renewal project team in the Division of
Engineering Technology of the Office of Research.
This morning I would like to present to you and discuss with
you some of the key elements and the main features of now completed
nuclear plant aging research program, or the NPAR program. The NPAR
program is a hardware-oriented engineering research program.
Early in the program, it was recognized that aging -- the
age-related degradation effects and mitigation measures should be
addressed for the renewed license or at that point in time we talk about
the life extension of the operating nuclear power plants.
At the same time, we had recognized that understanding
age-related degradation effects and managing its detrimental effects
during the renewed license period would also benefit many of the issues
for the current license term.
In this particular program, five national labs were
involved, along with the National Institute of Science and Technology
and the Wyle Laboratories. So then there were a number of staff
involved in this program, so one of the things that we tried to do is
actually have a uniform definition or understanding or the working
definition of what constitutes aging. This was actually a part of the
now completed program.
And it was defined as a cumulative change in properties or performance
which occurs over a period of time, and we mention about the properties
as primarily involving the long-lived passive components and structures
and we talk about the performance, we understood the aging associated
with the active components, such as motor-operated valves,
circuit-breakers, and relays. And if unmitigated, aging can result in
loss of function and impairment of safety.
The scoping studies for the NPAR program, many workshops and
major workshops for the age-related issues have been completed during
the 1982-84 timeframe, and the nuclear plant aging research program, a
comprehensive program plan was developed in 1984 and we had issued the
program plan in the NUREG-1144.
In 1985, I was privileged and I had the opportunity to
accompany my division director, Mr. Guy Arllato, to the Office of the
EDO, Mr. Vic Stello, and Mr. Vic Stello talked about the subject of life
extension license renewal and he asked Mr. Arllato, this time around, if
we talk about life extension going beyond 40, how we are going to put
our arms around this issue. We better have some good technical basis
when we actually go about the life extension license renewal.
And Guy immediately replied to Vic, the way I understand it,
it is going to be very important to understand the age-related
degradation effects and ways to mitigate these effects during the
renewed license period. And what he further stated is that we better do
our homework now and do it now, so ten years from now, 15 years from
now, when we're really going into the renewed license phase, we have a
good technical basis upon which we all have the confidence that, yes, we
recognize age-related degradation effects, but yet, also, it is possible
to manage the age-related degradation effects which could be
detrimental.
And at that point in time, the EDO, Mr. Stello, directed an
interoffice review group or working group, called the technical
integration review group for aging and life extension, and the members
of this review group included branch chiefs and the division directors,
Mr. Ed Jordan was involved, Mr. Brian Sheron, Mr. Larry Shao, and they
published a program plan in 1987 to integrate the age-related
degradation activities within the agency.
The purpose of this plan was actually to identify, at that
time, they called it the technical safety issues related to aging and
life extension and the regulatory issues, which we should visit or
evaluate for the extended life considerations.
The other part was to actually evaluate the effectiveness of
the ongoing programs to manage age-related degradation, and the third
objective of the plan was to actually provide the future direction to
the Office of NRR and Office of Research.
Also, during the 1987 timeframe, Chairman Zech, Mr. Stello,
Mr. Arllato and myself had the opportunity to actually go to the
Congressional hearing on the safety implications of the aging of nuclear
power plants, before Mr. Sharp's subcommittee, and the purpose of this
hearing was to see actually how the NRC and the industry is doing to
ensure that the plants -- as the plants get older and the equipment
wears out, they continue to operate safely.
Then actually in 1993, my current division director, Mr.
Craig, also briefed the Commission on the overall aging research
program. This hardware-oriented engineering research program or the
NPAR program was completed in 1995. It involved, as I mentioned
earlier, the five national labs, PNL, Brookhaven, Argonne, INEL, and
Sandia. It also involved the NIST and the Wyle Laboratories.
Upon completion of this program, by 1993, actually, we had
issued 141 technical reports on various components, systems and
structures. We studied the PWR and BWR systems and components. We had
completed the study on 22 components, 13 systems, and ten special
topics. The results of these reports and the studies have been
summarized in a bibliography and abstract in NUREG-1377, which is widely
distributed and is now also being used throughout the country, as well
as outside the agency and overseas.
The overall scope of the aging-related program included
primary system pressure boundary components, reactor pressure vessel,
the steam generator, the piping NDE. It also involved electrical and
mechanical components, such as motor-operated valves, check valves,
pumps, circuit-breakers, relays, cables, transmitters, batteries,
battery chargers and inverters, RTD, et cetera.
With regard to the safety systems and support systems, we
have the reactor protection systems, relief water system, active feed
water system. We also had an aging-related program on the containment
and civil structures.
And a part of this NPAR program, and this is a very
important element of the program, we did some special topic studies. It
includes the residual lifetime evaluation of long-lived passive
components and structures. It includes a program about the
record-keeping needs and data trending for an effective aging
management.
It also included to evaluate inspection integration
activities. We did a study on the degradation modeling. We reviewed
the effectiveness to manage aging and other regulatory interments. And
one of my primary responsibilities was to integrate all these research
activities with five national labs, the other contractors, within the
Office of Research, and within the agency and also outside the agency.
Domestically, we integrated this program with the Department
of Energy, Electric Power Research Institute. I had an opportunity to
go to NASA at the Langley Center to see some of their diagnostic and
condition monitoring methods. I had the opportunity after the Aloha
incident to visit the FAA, because they wanted to start a comprehensive
aging program to manage aging in the older jet aircraft.
We also had interactions with IEEE and ASME and also the
Department of Defense, that I was privileged to evaluate the maintenance
effectiveness to manage aging in nuclear power submarines, and, through
that effective program, they are actually able to increase the overall
time from X years to 2X years.
I think this is actually some of the key elements of the
overall program. Because we had five national labs, we started with
something like 40 components recommended by the Tirgalex review
committee. We had different project managers. But what we wanted to do
is streamline and make sure that we have a clear understanding of how we
go about understanding and manage aging in the operating nuclear power
plants that involve systems, structures and components.
So one of the key elements of the program was to understand
aging. So whether a component is a motor-operated valve or check valve
or a cable or a water system or a reactor pressure vessel for internal,
we defined the component or system boundary of interest.
Once we do that, let's identify how well we know the
materials which are used in the design, construction, fabrication of
that component and system, and when it is installed, what other
materials might have been used for the lifetime of the components,
systems and structures. The more we know about the types of materials
which are used for that component, that will be very useful information
to understand the age-related degradation effects.
We also want to identify for that component what are the
operating environments within its application for the -- talking about
the temperature, radiation, humidity, et cetera.
We also identify what are the stressors which might be
associated with that component during its operation. We talk about
electrical stressors, the mechanical, the thermal, which are actually
the operating stressors for that given component over its lifetime.
And most importantly, the materials, the stressors, the
environment, and their interaction over time would give us the insight
to understand the age-related degradation or the aging effects and to
identify what are the key aging mechanisms and, more importantly, to
identify what are the degradation sites, where these aging mechanisms
are operative.
So we identify aging mechanisms and also try to identify
where within that component boundary those key aging mechanisms which
could be detrimental are within the site of the component boundary. So
we identify the degradation sites, and this is true for -- if you look
into any of these component reports within NPAR, whether it's MOVs or
we're talking about the reactor internals or a cable or containment
structure, the contractor involved and the project manager involved
would have a section on the understanding aging.
For that component, they will identify the mechanisms, its
effects, and what are the degradation sites.
Some of the key aging mechanisms that we have identified as
part of the program are very straightforward. We are addressing the
fatigue, erosion and corrosion, radiation embrittlement, thermal
embrittlement, chemical and biological effects, creep, and operational
and environmental effects.
The creep became actually an issue when it involved the
polymer and insulating materials, if they're subjected to high
temperature and if you have pressure and vibration, there is a
possibility that insulating materials or epoxies could creep over time.
Then came the next phase of the program. Once we identified
the age-related degradation effects with materials, stressors,
environment and where the degradation sites are, what are the effective
aging mitigation methods for those specific age-related degradation
mechanisms at those sites.
We looked into part of the program for every component,
system and structure, how effective are inspections, surveillance,
condition monitoring. The record-keeping and trending is a very
important part of actually tracking the age-related degradation over
time, the refurbishment, replacement, general maintenance, or when you
can actually change your stressor and environmental conditions to manage
age-related degradations to mitigate.
For every component, system and structure, we use a phased
approach to research. Once we selected components, systems and
structures, the Tirgalex identified 40 components, systems and
structures. The selection of components and systems was a hybrid
approach. We had over 35-40 years of design experience, with 25 years
of operating experience. We had an expert panel. We also looked into
from the risk insight and we put all these things together and we had a
report actually called the prioritization of the Tirgalex components,
where we brought all this information, we did our selection of
components and systems and structures.
And once we did that thing, as I stated earlier, for
understanding and managing aging, we ran systematically for that
component, system and structure to evaluate the age-related degradation
and its mitigation method. An important part is question, everybody was
sensitized to ask the question what happens with time. I think that was
the baseline actually, where we look into the inspections or maintenance
effectiveness or we're talking about ISI, IST or tech spec requirements.
We're sensitized to ask the question what happens with time as a part of
the NPAR program.
We identified the functional indicators and parameters.
This is very important, in my mind. Every component, system and
structure has certain indicators or parameters. By trending those
things over time will give us an indication of results throughout the
operability life. For MOVs or for cables, we identify what we should
check, what we should monitor, what we should trend, which will give us
an indication of the degradation effects over time.
Then actually we can establish the criteria that when it
exceeds above those points, that we need to do some mitigative research.
But for each of these components, systems and structures we
studied, we did identify those indicators and parameters, and we
reviewed inspection condition, monitoring methods, and we reviewed
applicable regulatory requirements, codes and standards.
This is phase one, which is primarily a paper study. We
looked into the NPRDS, we looked into the LERs, IPRDS, other programs,
the industry program, the code standards. Talked to the designers, to
the vendors, and brought this information.
And for many components, we find out that there are no
significant age-related degradation effects which are not being managed
today. And for that, those components, systems and structures, we did
not have to do the phase two study as a part of the NPAR program.
For certain components, systems and structures, we did some
studies on those things as part of the phase two program, was primarily
to do some confirmatory in situ condition monitoring. Once we identify
the age-related degradation effects, identify the indicators or
parameters which will give us the health of the component over time.
Sometimes we were actually provided an opportunity to do
some in situ monitoring and checking of the naturally aged component
versus a new component. We were able to actually monitor, for example,
the cables in a given plant where we had the new cables, with the same
vintage of cable with ten years, 15 years, or if you can monitor the R
factor or power factor, or the testing or modulus, would that give us an
indication of health of the component over time and to see whether
diagnostic and condition monitoring method is effective indeed to detect
the age-related degradation.
And then the final phase of the program was the utilization
of the research results.
Based on the experience gained from the NPAR program, we
have actually provided the technical basis to support the initial
license renewal rulemaking, the first one. Actually, also develop the
reg guide on the format and content. This is the earlier version of
this one.
We also provide the support on the development of codes and
standards, like, for instance, IEEE Standard 1205, which talks about
understanding and managing aging in the electrical components in
operating nuclear power plants.
We also provide the support for the development of bulletins
and information notices, the resolution of generic issues which involve
primarily the mechanical components, and we also, in many instances,
what we heard from the regions on certain issues about the aging of
water systems or the chlorine release from the cable, that we are able
to provide some of the technical input and insight and some references
which were useful also to the regions.
And we are continuing to support the current activities of
license renewal and many of the current activities for license renewal
include the development of the GALL report, the development of the
standard review plan, and many of the license renewal technical issues
which have been assigned to the Office of Research.
And currently, as a part of my responsibility, I am
integrating the various activities of the Office of Research within NRR
and Research. I have the opportunity and they were very grateful to
invite me to every week on the two-step interface meetings and then I
take that information and data and try to get it to the right people in
the Office of Research, so that the programs are totally integrated, and
try to do the effective job to support NRR in everything.
I think the important thing is that the NPAR program, the
reason Mr. Stello and Mr. Arllato had, in the early '80s and mid '80s,
and last ten to 15 years of work on the nuclear plant aging research
program has provided some good sound technical bases and much more
confidence to make our decisions that as we go from 40 to 60 for
extended life, that, okay, we do have the technical bases, we have the
approach, and we can bring all this information together for the next
step.
So this is the part of my presentation, and thank you very
much, Mr. Chairman.
DR. BONACA: Thank you.
DR. SHACK: Do you feel that those results were captured in
the standard review plan? Would that be the real document that really
puts this to use for the license renewal process?
DR. LEE: Yes. These are in the real document, but the
thing is GALL is like the basis document or SRP. You provide a basis
why some of the programs are adequate.
DR. SHACK: It just seems to me, as I think about it, the
standard review plan sort of stops at the -- it's selecting components,
it's looking at some of the designs and characterizing the aging
mechanisms, but it really kind of stops short of identifying parameters.
It really didn't incorporate that part of the information,
did it?
DR. LEE: It will.
DR. SHACK: It will.
DR. LEE: It's in some of the -- the draft SRP has some of
that information already, but it doesn't cover all the parameters. It
doesn't cover all the programs.
MR. VORA: Also, information of the GALL report, as we go
through it, talking about mechanisms, the effects, and we're going
through the evaluation and the references, at that point in time, we
also integrate the others to identify -- when we do the evaluation,
we'll identify the parameters.
DR. SHACK: Okay. I felt the SRP was better at raising
questions than it was at answering them.
MR. VORA: Yes. The GALL report we integrate into the next
version of the SRP. It should be an integrated approach.
DR. LEE: I guess the draft SRP raised a lot of questions
and we have to case-by-case, we will. As we move on, we'll learn more
and then we'll be able to put in some acceptable methods to address it.
DR. BONACA: I had a question regarding the GALL report. I
didn't understand. Is the GALL report going to be a living document?
What I mean is that it seems to be the results of the review of 550
different documents and so it really reflects past experience. And as
we go forward and we have more information about aging, will it be
updated on a routine basis? Is that the plan for it?
DR. LEE: Yes. The GALL and SRP will be updated. We are
just looking backwards now, because we are moving on to GALL, also.
MR. VORA: The GALL was reported, was published in December
1986 and it took the information up to that point and the draft of the
GALL-2 report now has the information to 1998. We are reviewing, for
instance, as we said, program, too, that we are going to bring in some
of the work that was done since 1993 to date. So I think hopefully we
will keep it up-to-date.
DR. BONACA: You also showed, in your last overhead, under
license renewal, three bullets. One of them is the GALL report,
standard review plan, then you have license renewal issues.
I imagine that by the time that we get to a finalized
process, those will be all closed, those issues.
DR. LEE: Well, as people identify issues, we will address
them. Hopefully, the inventory will go down. We have like 100 license
renewal issues right now. I guess that's the next presentation. We are
trying to work in the Office of Research to contribute significantly to
the effort.
But as industry or the staff or the stakeholders identify
issues, we're going to use that process to continue to address it.
MR. VORA: I think some of them are for process issues, some
of them are technical issues. So the technical issues are being
narrowed down and Research and NRR together will try to address them.
DR. BONACA: I understand. Because some of the issues
really would be dealt with as we learn more in the future. So some of
the determinations would be long-range. Okay.
MR. GRIMES: This is Chris Grimes. I'd like to comment that
the vision that I have of the generic license renewal issues is that we
would hope to work off a large quantity of them early in the process,
but I think we are going to always have to deal with the existing
process, suggestions and issues that need to be addressed.
We're going to continue to learn from events and develop
generic communications that contribute to maintaining plant safety. I
would expect that we're going to continue to have opportunities to
improve our understanding of how aging can be managed.
So I think that there is always going to be some generic
renewal issues that are pending and I think what's most important to the
process is that the process clearly identify which of those things need
to be done for the purpose of improving the decision process for the
licensing as clearly distinguished from technical issues that need to be
dealt with in the arena of conducting research for the purpose of
improving knowledge.
We always need to focus on distinguishing the generic
renewal issues just like we distinguish the safety issues for present
license requirements.
DR. BONACA: I guess my question was trying to understand
how their closure will affect individual applications and approval of
the applications. I understand how some of them can be dealt with by
commitment for future closure or future inspections maybe, but I'm
trying to understand how, as issues are being raised, they're going to
be dealt with with the plants that already received an approval for life
extension.
MR. GRIMES: I would expect that they're going to have to be
dealt with in the same way, that we would have to impose the same rigor
that we do on the development of new requirements, as they relate to
existing licenses, and when we make future decisions about changing the
decision criteria on what constitutes an acceptable aging management
program or what constitutes an applicable aging effect, we're going to
have to reflect back and see whether or not that affects previous
decisions in license renewal.
That's why, as I mentioned before, we have such an
aggressive schedule to try and get through the bulk of the generic
renewal issues as early as possible in order to minimize the potential
impact on these initial license renewal decisions.
DR. BONACA: Thank you.
MR. GRIMES: Are there any other questions about the
development of license renewal guidance?
DR. SHACK: I guess it's still not clear to me -- it seems
to me a large part of the guidance is actually the existing license --
the application from the last guy. I mean, if I was writing my license
application, my chief guidance would be the one that made it through the
process.
I'm not sure how that gets captured here and maybe it
shouldn't be. There's sort of a precedence, a common law kind of -- you
know, if it worked for this guy, it's going to work for me thing, but
you seem to be reluctant to give those generic blessing, but, in fact, I
suspect they will turn out to be generic, because, again, if it worked
for this guy, why won't it work for the next one.
MR. GRIMES: And that's the part of the struggle that we
have, is that we deal with issues on a plant-specific basis, but then
the community as a whole, all of our stakeholders don't necessarily
agree that that's the right answer that's going to apply for everybody.
So what you see in the standard review plan today is
basically our best guess at what would constitute the decision basis
upon which we do the first two applications. Well, the first two
applications didn't turn out exactly that way. We discovered, first and
foremost, this opportunity to reformat the standard review plan so that
the decisions are made more consistently with the structure of the rule,
in terms of scoping methodology, identifying systems, structures and
components that are passive and long-lived, identifying aging effects,
and then going into the aging management programs.
So you're going to see a large move towards having the
standard review plan more consistent with the decision basis that we
came to for these first two applicants, but then there are still going
to be these minor details that we're going to sort out. And as we talk
about how we're going to address generic renewal issues, a lot of the
questions that were left unanswered in the standard -- the first draft
of the standard review plan, we've now dealt with and we can go through
and learn from that experience and focus on, as the Commission pointed
out, focus on those areas where we believe that there is a firm
foundation for a need to augment existing programs.
So the approach that Sam and Jit have described is basically to take our
collective experience now and to re-craft the standard review plan so it
looks more like the decision basis that we used for Calvert Cliffs and
Oconee, or will use.
So we're moving in the direction of having the process, keep
the standard review plan in conformance with the decision process.
DR. UHRIG: The two applicants to date, Oconee and Calvert
Cliffs, have different structures. One has been characterized as being
a vertical structure and one has been characterized as sort of a
horizontal structure in terms of the approach that they've made.
Has there been any preference, from the staff's standpoint,
as to which approach they would prefer or is this an issue that is
strictly left up to the utilities?
MR. GRIMES: This issue is being resolved in the context of
the standard format and it ends up being more of a horizontal than a
vertical structure, because even for the staff, we find that it's more
efficient to deal with programs that cut across a large body of systems,
structures and components and evaluate them once, rather than evaluating
them on each individual structure or component.
But we still find that in the context of better
understanding the methodology for scoping, that there be a little bit
more vertical in terms of making clear what is the scope that these
programs apply to. I think that we're headed towards an agreement with
the industry that we can find some efficiencies in packaging that will
basically address the major programs and then smaller commodity groups
in a more efficient way.
DR. UHRIG: Will this be included in the standard review
plan?
MR. GRIMES: We would intend to reformat the standard review
plan to follow the standard format. We would expect the standard review
plan to talk about the review process in that way.
DR. UHRIG: What is the time scale on that? It was here, I
think.
MR. GRIMES: Actually, we'll start with the letter that was
just handed to me, which is NEI's agreement on an approach to the
standard format, and then we would expect, in accordance with the draft
schedule that Sam put up, to have a revised standard review plan worked
out by next summer.
DR. UHRIG: So that really won't affect the two anticipated
applications.
MR. GRIMES: Arkansas and Hatch have been very closely
following the dialogue on the standard format and both of them are going
to -- have indicated a desire to comport, to the extent that it's
practical for them to do that.
Are there any other questions?
[No response.]
MR. GRIMES: Okay. If you are ready, we'll move on to the
next presentation, by Jake Zimmerman. He is going to describe where we
stand with respect to sorting out and managing the generic license
renewal issues.
MR. ZIMMERMAN: Good morning. My name is Jake Zimmerman.
I'm a project manager in the License Renewal and Standardization Branch.
Today I'd like to cover with you the license renewal issues,
the process and the status. We've recently gone through and
re-categorized all of the license renewal issues. We've done away with
the priority scheme. I'd also like to discuss plans for resolving the
issues and what our schedules are.
Let me just put this up first, but I'm sure many of you are wondering
why are we re-categorizing it this time. Categorization was done
because the old prioritization system was originally established with
the concept that selected issues would be resolved to support the staff
review of the first license renewal applications.
Since Calvert Cliffs and Oconee reviews are proceeding
through issuance of a new license, with plant-specific resolution to
these issues, and the generic resolutions have not been established at
this time for most of these issues, we felt that it was time to go back
and reevaluate all of the issues and categorize them to, one, better
focus our efforts to resolve the generic issues, to separate them by
their complexity, to allow better identification of our resources needed
and the schedules to complete those reviews, and, also, to identify
those issues which are impacted by outside influences and thus cannot be
resolved until action is completed.
What I'm referring to there is a Commission decision or a
plant-specific resolution that we're still currently working on.
Therefore, we developed these four categories. Number one,
resolution pending management, Commission or plant-specific action. The
next two categories, high technical complexity, medium technical
complexity; subjective decision as to where an issue would fall.
Basically, it's a value judgment between NRC and industry,
based on the issue's technical complexity, the value-added of that
resolution being completed and then also the resources that we're going
to need to resolve that particular issue.
DR. KRESS: Excuse me. What exactly will you do with this
information? Will you assign different categories to different people
to work on or put more resources on the ones that are higher technical
complexity?
MR. ZIMMERMAN: What we are planning to do, and I will cover
that a little bit later, is we're going to try to develop a top ten like
list and it won't necessarily be ten. Currently, it appears that
there's going to be 19 items on that list, and that list will be
developed between NRC and the industry and the list will be a mix of
category one, two, three's and four's.
Category four's are easier, editorial in nature and there's
45 items that NEI has categorized as category four. So we feel that we
might direct some resources in that area because there's more bang for
the buck, so to speak, that we could close out.
Category one issues, there's currently three that NEI has
identified, and I keep referring to what NEI has identified. The letter
that we gave to you this morning is a letter that we just received from
NEI, where they went through and re-categorized all the issues. They
took the first cut at re-categorizing them.
We are in the process of evaluating their re-categorization. Some of
them we might not agree with and we still need to work that out. So
that's where we stand with the re-categorization.
DR. SHACK: You sort of half answered my question. This
categorization still doesn't solve your prioritization problem.
MR. GRIMES: No. And I'd like to add, it doesn't solve the
prioritization problem, but it does help us to understand better how to
manage the workload. Just the categorization itself gives us some
insights into where we're having communication problems or where we've
got some underlying conceptual disagreements. So it's helpful in that
respect and it also is helpful from the standpoint of trying to assign
resources.
If both we and the industry agree that we've got one that's
a high technical complexity, then that's one that's going to be very
resource-intensive or demanding. So we'll be -- I would be more
reluctant to dive into commitments on resolving something that we and
the industry both think is a very complex technical issue.
Whereas for all those things that we and the industry agree
that it's easier, editorial in nature, then maybe with just a little
investment, I can get a lot of stuff out of the way.
So that's why we felt that the categorization would be
useful for the purpose of allocating resources and committing resources
to start working these issues off.
MR. ZIMMERMAN: That letter that you have, there are three
issues in category one, there are 18 in category two, 40 in category
three, and 44 editorial style changes that are in category four.
So just looking at the total number of issues, we have 106
issues. If we could handle some of those editorial type issues, we
could basically cut the list in half. We currently have approximately
25 issues that are under review. So we'd be basically down to 25
percent of the list that still needs to be planned and scheduled.
So what are our plans for resolving the issues? We're
currently working on a revision to Office Letter 805, that's NRR Office
Letter, which is our license renewal application review process. What
we're doing is we're going to incorporate a guide for processing license
renewal issues and a formal appeals process for identifying and
elevating disagreements on NRC staff positions, and those are
disagreements that the NRC staff and the industry have on those
positions.
The guide for processing the license renewal issues will
describe the overall process and the individual steps that will be taken
for identifying, documenting, tracking, and developing the technical
basis for resolving the license renewal issues.
The appeals process is a multi-step process that elevates in
management involvement as disagreements remain unresolved. After each
step in the process, the originator and/or stakeholders have the option
to appeal the disagreement to the next level of NRC management.
We're planning to also use that appeals process for
plant-specific issues that come up during an application's review. And
if necessary, issues related to policy decisions will be raised to the
Commission.
As I said, this is under development. We plan to -- I had
hoped to have it out before this meeting, but we're scheduled to have a
license renewal steering committee meeting with NEI next week on the
29th and we're hoping to have it issued by then, and once we do have it
issued, we'll certainly get copies of that provided to the members of
the ACRS.
MR. GRIMES: I would like to add that the topic was
discussed at the last steering committee meeting as it related to the
concerns that the industry expressed in relation to credit for existing
programs, relative to the industry concern that license renewal reviews
were going to continually have an accretion of requirements or what's
also referred to as a regulatory creep; as we get smarter, we become
more demanding in the requirements.
And underlying that concern was basically to what extent
would the NRC rigorously hold to the scope of the review and a set of
predictable requirements that would be fulfilled. This is not unique to
license renewal. This is a similar concern that was raised relative to
how license amendments are processed, how many rounds of questions are
there, how do you stick to the standard review plan or the applicable
guidance.
So we're attempting to address it by having a very formal
stylized appeal process that basically would permit disagreements to,
first, be recognized and revealed; that is, to stop dialogue and
recognize that there is a fundamental disagreement that needs to be
resolved, and then have that disagreement work very formally through a
process of decision-making and appeals, depending on whether or not
either party, the NRC staff or the industry or the applicant, isn't
satisfied that the decision was appropriate.
It's the same concept that we use to deal with differing
professional views and differing professional opinions, and that is to
take the personalities out of it by simply saying, well, if we have a
disagreement, here's what you do, here are the steps, here are the
responsible individuals who have to make decisions and stand by those
decisions.
So that is the concept that Jake is now attempting to
implement by adding an appeal process to our procedures.
MR. ZIMMERMAN: Next, I'd like to talk about our plans for
involving stakeholders. We do plan to encourage stakeholders' input
during the resolution of our license renewal issues. Our first step in
this process will be to identify all of our stakeholders, and those
could be interested applicants, the public, and professional
organizations.
We must develop a means to notify them and I guess that's
one of the things that we're going to ask the ACRS to provide us
feedback on, is how we go about doing that. One of the ideas that we're
discussing is putting these issues on the license renewal web site so
that the public will have that information available to them and that
they could, either through, we would hope, a formal letter documenting
their concern and perhaps a proposed resolution for the issue, that
would be something that would be acceptable. But I guess we're looking
for some feedback from the ACRS on that.
MR. GRIMES: I would also mention that I have contacted Dave
Lochbaum and Dave Lochbaum has agreed to serve as a focal point for
public interest groups and public advocates and we need to negotiate
through him some way to try and get some more public advocates involved
in the comment and review process.
As Jake mentioned, the first step in trying to get more
exposure would be to put the proposed issue resolution -- put the issues
and the proposed resolutions out on the web and see if we could
stimulate some more feedback from a broader range of stakeholders.
We also need to figure out whether there is some way that we
can get contacts in the ASME, the IEEE and the other professional
organizations to participate in some kind of dialogue on the resolution
of generic renewal issues.
DR. SHACK: Somewhere, is there a more complete description
of the issues than we seem to have in the tables that we get in the
list?
MR. ZIMMERMAN: That is the most complete description that
we have in our database. Early on, we identified that some of these
issues were not very clear as to what specifically the problem was and
rather than go back and try to re-clarify all of the issues, there were
meetings and conference calls to discuss specific issues and as these
issues were worked, the clarification was developed and the issue
proceeded to resolution.
I guess that's something that we could look into is going
back and making a better definition of what the particular issue is.
DR. SHACK: When I see something like risk-informed license
renewal, it seems to be something that bets for a little more
explanation.
MR. GRIMES: We discovered that as we were going through
some of these issues. A number of them are simply comments that NEI
gave us on the standard review plan and some of them are like credit for
existing programs to illustrate the process, we spent almost six months
just trying to define what is the problem we're trying to address, and
credit for IWE/IWL, we spent several meetings and phone calls and
exchanged correspondence just to get a problem statement to work on.
So part of the review process, the first part of the review
process is to define a problem that's going to be addressed and in
relation to the risk-informed license renewal, we're in the process now
of getting assistance from the Idaho National Environmental Engineering
Lab to talk about conceptually where could risk insights serve license
renewal, including the question that Dr. Apostolakis raised about how do
you quantify renewal risk.
DR. BONACA: I still have a -- I feel uneasy about a
strategy that you have to deal with these license renewal issues. The
reason that I feel uneasy is that I'm thinking about a strategy that we,
as the ACRS, will have to deal with in looking at those.
What I mean by that is that a number of these issues --
well, first of all, if I had to have a definition of a license renewal
issue, aren't they issues where the staff disagrees with industry on
what the -- how to deal with them?
MR. GRIMES: It's a potential disagreement. In many cases,
we have found, for example, on the position on fuses, we started off
with a potential disagreement. We eventually reached an agreement. So
these are areas where there are questions for which either the industry
wants to know more about what the NRC's view is or the NRC has put a
view out there and the industry is challenging it.
So we need to clarify, well, what is the nature of the
potential disagreement and then if we do disagree, what are we going to
do about it.
That's part of the process, is clarifying where we
misunderstand each other and distinguishing that from where we just
fundamentally disagree.
For example, we put a position out on consumables and NEI
wrote a letter back and said that they understood part of it, but
disagreed with part it, and now we need to confront that disagreement
and decide what we're going to do about it.
DR. BONACA: But I'm saying that still I would like to have
a definition of what is a license renewal issue. Then it seems to me
that those are issues that have to do with disagreements between the
industry and the staff on how to deal with an issue or if the issue
exists or things of that nature.
Am I correct?
MR. HOFFMAN: This is Steve Hoffman, License Renewal Branch.
Some of these are just area where additional guidance was recognized as
being needed in either the Reg Guide 9510 or the SRP. The comment about
the one in there right now on risk, in 9510, there is a brief statement
about use of risk in developing your aging management programs.
A comment came in on the 1996 draft reg guide that says can
we get more guidance on how to apply that. So some of these are just --
they're actually items that need to be addressed in the SRP, reg guide,
or 9510. Some are disagreements, some are just development of
additional guidance.
MR. GRIMES: I'd like to play off Steve's comment and
clarify that we view generic renewal issues as any area where there is a
question for which somebody deserves an answer, because our fundamental
responsibility is to make our expectations about the regulatory
requirements very clear.
DR. BONACA: Good. So that's at least trying to understand
exactly what's in this hopper here.
The second issue is it seems to me that many have to do with
the process and not only those which are called administrative, but even
others which are classified here as highly technical. For example, I'm
looking at 98-0033, primary water SSC of high nickel alloy components.
The industry here would like to do something and the staff
would like to do something else with the inspection. At some point,
there will be a resolution of that and I expect that the resolution will
be in the SRP.
What I'm trying to understand, the question I had originally
was how do we get to the stability that you were talking about before,
where you do have still a hopper of generic issues, because in
particular, in aging, things will come up that we'd never seen before;
therefore, you've got to have that hopper there. It will be a limited
one, because most of the process issues would be dealt with, as a
minimum, there will be commitments.
That's really what I would like to understand, what is the
strategy to get there, because by that point, I would expect then you
will have a much more stable license renewal process.
MR. GRIMES: And that was part of the strategy behind the
categorization, because by sorting these generic renewal issues into the
categories, Jake pointed out that more than half of them really get down
to just clarifying editorially what we were trying to communicate and
then there are a smaller subset of those that have underlying technical
dialogue going on.
And the staff's expectations with respect to how to deal
with fatigue in the absence of a resolution of GSI-190, for example, and
even after GSI-190 is resolved, whatever outgrowth there is in terms of
the future activities to try and improve fatigue management techniques.
Reactor vessel internals is still an area that's very
unstable. Technically speaking. I mean, there's a lot of development
work that's going on. There's a lot of effort that the industry is
putting into improving the inspection strategies for reactor vessel
internals and identifying areas where IASCC vulnerabilities need to be
concentrated in improved inspection techniques.
But what we can do for license renewal is to carve those out
and focus those and where there is a particular benchmark or reference,
to highlight that in the review guidance in order to make sure that
everyone understands there is an area where there is plant-specific or
industry work going on.
I think that's what the Commission envisioned when they
instructed the staff to concentrate on areas where programs may need to
be augmented, because the stability is going to come from documenting
the evaluation basis for how environmental qualification is managed.
We had a long dialogue on that on the first two applicants
and we learned that there are some basic precepts of EQ that are common
to all plants, that constitute an agreeable expectation in terms of how
the process works.
We need to collect the rest of that experience from the
first two applicants and also recognize the areas where we had one
applicant say that there is a big new program to manage aging effects
for buried piping and the other applicant said that, no, that's just
piping is piping, one's in air, one's in water, and one's in dirt, so
what's the difference.
We need to reconcile some of the different industry views
and say, well, buried piping is going to be dealt with uniquely perhaps.
But by cataloging what areas there was substantial agreement, where
there wasn't a lot of controversy, that in and of itself is going to
achieve a lot of stability and predictability and then it will boil down
to some subset for which there will probably never be complete
agreement, but at least we and the industry will understand the extent
to which there might be plant-specific approaches or there is a need for
further work on a generic basis beyond the process, outside this
process.
That's why I mentioned the importance of distinguishing
between criteria that will be used for decision-making from the
constructive tension that exists between the regulator and the industry
in terms of area where more research needs to be conducted to improve
the techniques.
MR. ZIMMERMAN: In the area of ACRS involvement, we plan to
provide the ACRS with the new list of license renewal issues based on
the new categories. Again, the letter that you have is NEI's first cut
at that. We're going to evaluate that list and we'll work out any of
the changes that we feel are necessary with NEI and once that has
happened, we will issue a final list with the new categories and we will
provide you with a copy of that.
In addition, we will continue to provide you with copies of
proposed resolutions as they are issued. The staff will also keep ACRS
informed of any significant issues that are being appealed or are in our
appeals process that we're going to lay out.
We also would like that if ACRS would inform us of any of
the issues that we're going to have on our top ten like list, and,
again, we will provide you that list once it's developed. If there are
any particular issues on that list that you would like us to brief you
on, we'd be glad to do that.
Our schedules for license renewal issue resolution is based
on those new categories and now that we have NEI's input, we'll once
again reevaluate those categories. We'll develop a top ten like list
with NEI. Currently, it looks like we're going to have 19 issues.
What we've done is we're going to carry over the old
priority one issues and add additional issues that we both agree on to
that list.
Also, if we receive any stakeholder issues, they will be
factored into that top ten like issues list, and that could be a new
issue or that could be an issue that a stakeholder is particularly
interested in that is not on the list, but they feel should be on the
list and attention should be given to that issue.
DR. KRESS: Does this mean that those items that aren't on
the list wouldn't get any attention until they make it to the list?
MR. ZIMMERMAN: No, sir. What we plan to do is focus our
attention and our resources primarily to those items on the list. I've
proposed that as one is completed, we add an additional item to the
list.
What we're trying to do here is focus our efforts and NEI's
efforts on a set number of issues, develop a detailed schedule, and work
the issue till resolution and finally implementation, which would
include possibly being incorporated into the SRP, the reg guide, the
GALL, or NEI-9510.
There is staff review going on right now on other issues
that are not on the top ten like list, but, again, we want to focus our
efforts on that particular list and drive them to completion.
DR. KRESS: What are the criteria, again, for making it on
the list?
MR. ZIMMERMAN: Well, the list originally just included the
priority one items and we've carried those over. We've added three
additional items that NEI felt we needed to devote some attention to
that were high priority items on their list that we had not previously
characterized as high priority.
DR. KRESS: So you will maintain some sort of prioritization
within the categories.
MR. ZIMMERMAN: Yes, so to speak.
MR. GRIMES: But the prioritization is active or not. What
it boils down to is, as Jake mentioned before, the real criteria for
getting on the list is basically what do we and the industry both agree
to are going to -- are things that we're prepared to work on and we're
prepared to dedicate resources to, that we're prepared to commit
schedules, prepared to commit to schedules.
So it's a very simple criteria and it's one of making a
commitment to take an action. We haven't made a whole lot of progress
up until this point, because almost all of our resources have been
fulfilling the commitments to meet the milestones for the first two
applicants. And now we've just revealed today that we're preparing to
start making a commitment to meet milestones and apply resources towards
a substantial generic activity to develop GALL, to develop the standard
review plan, and in order for those things to be successful, it's also
important that we make progress on some of these generic renewal
questions.
To do that, we're going to need a commitment and an
agreement from our stakeholders that they're prepared to support
applying their time and energies first, but then beyond that, to follow
a practice and a procedure that's basically going to identify agreements
and elevate disagreements.
DR. BONACA: I understand that for the pilots, at least the
one underway, there may be some supplemental SERs coming in the near
future.
How have they dealt with these open generic issues? They
must have dealt in a way that you feel satisfactory for closure?
MR. GRIMES: As a matter of fact, we're in the process right
now of trying to come to closure on the open items for Calvert Cliffs
and Oconee and in doing so, the generic renewal issues are actually
embedded in our safety evaluation. So they're treating them on a
plant-specific basis.
DR. BONACA: So essentially they're pointing out to possible
solutions of some of the issues.
MR. GRIMES: Yes. But we promised not to -- we've promised
the first two renewal applicants that we weren't going to abuse them by
saying, well, you know, Oconee promised to do this, so Calvert Cliffs
ought to do that.
Similarly, we're not going to abuse the generic resolution
by saying, well, we managed to get the first two applicants to cave in
with this approach. So we consciously set out on a path that said,
well, the first two renewal applicants will do whatever they need to do
in order for us to get to an acceptable solution, but that does not
foreclose the opportunity that we might pursue a broader range of
alternatives on a generic basis.
I realize that that doesn't lend to stability and
predictability, but it's very important to get industry buy-in that the
review guidance and the review approach is one that allows them
sufficient opportunity and flexibility to make the process efficient,
from their perspective.
DR. BONACA: I think we've come to a point where it would be
appropriate to take a break. I think we're running slightly ahead of
schedule, so let's take a break now and start the meeting again at 20
after 10:00.
[Recess.]
DR. BONACA: The meeting is called to order again, and we
have now a presentation of the staff activities on the pilot
applications.
MR. SOLORIO: That's correct. Good morning. My name is
David Solorio. I'm the NRC project manager assigned responsibility for
managing Baltimore Gas & Electric's license renewal application for
Calvert Cliffs.
As Chris Grimes said earlier, we intend to come back to you
all to give you a full briefing regarding how we closed out the open and
confirmatory items in the safety evaluation report written for BG&E's
LRA.
Today I'm going to provide you with a status of the staff's
review and give you a highlight of what matters the staff is in the
process of closing out with BG&E. Thus far, all our milestones have
been met.
The next major milestones that we're looking at here,
actually a few have passed, are that the BG&E responded to the open and
confirmatory items in the staff safety evaluation, by letters dated 7/2
and 7/16 of '99. If you recall, there were 28 open items and 20
confirmatory items.
On August 12, the staff provided Baltimore Gas & Electric
with a status as to what open and confirmatory items we were able to
close based on those initial responses from Baltimore Gas & Electric.
There was roughly, I believe, ten items that we still needed additional
interaction on.
The staff plans to issue the final SER in about a little
less than two months from now, on the 16th of November, and expect the
Commission decision for the Calvert Cliffs renewal application around
May of next year. Between then and now, we also intend to come back to
you all to provide a briefing on how we closed out the open and
confirmatory items.
What I want to go over next are some of the items with which
the staff and BG&E are in the process of closing out. Essentially,
there are five open items that we're working on with BG&E to try to
close out.
The first one deals with stress corrosion cracking in the
reactor coolant system and what the staff is trying to work on with BG&E
is discussing the possibility of this and what aging management programs
would be necessary if it was found to be agreed upon to be plausible by
both parties.
DR. SHACK: Can you tell me how they treated this
differently than Oconee, so it's an open issue for them and a closed
issue for Oconee?
MR. SOLORIO: I would have to ask Joe to see if he remembers
how Oconee dealt with that, because I'm not familiar with Oconee's
particulars.
MR. SEBROSKY: Recognize that I'm not the expert on this,
Dr. Shack, but I think the issue for stress corrosion cracking in the
RCS piping deals with CAST.
DR. LEE: This is Sam Lee, from the License Renewal and
Standardization Branch, NRR. The way Oconee -- the way they address it
in the B&W owner's group topical report and their SCC or the RCS piping
is susceptible to aging effects and they rely on Section 11 and such
programs for Oconee.
MR. GRIMES: This is Chris Grimes. For Calvert Cliffs,
they're treating it as an issue that they don't consider a plausible
aging.
DR. SHACK: But they would have the same aging management
program then that Oconee does. They would have Section 11.
MR. GRIMES: If they admitted that it was an aging effects
that needs to be managed.
MR. SOLORIO: Just to clarify for you, Dr. Shack, we did,
when we wrote the safety evaluation, we considered that while there was
a disagreement with BG&E on whether or not the aging effect was
plausible, we considered it if they used -- if they committed to
continue to perform the ASME Section 11, their tech spec leakage
requirement, and programs based on Bulletin 82-02 and their primary
water stress corrosion programs, that we would find that an acceptable
way to manage the aging effect.
These were existing programs they already do, because they
don't agree that the aging effect is plausible, they weren't willing to
commit to those programs for managing that aging effect.
We're continuing to discuss it with them and we're getting
pretty close, actually, to closing this out.
The next item that the staff is working with BG&E to close
out is on small bore piping. The staff believes the applicant should
perform an augmented inspection of small bore piping to determine if
cracking is occurring on the interior surface. BG&E currently has a
program that looks on the exterior surface.
BG&E initially responded that inspections they intend to
perform on their chemical and volume control system as part of their
age-related degradation inspections would bound small bore piping on the
RCS and the staff initially had trouble accepting that response without
knowing about the similarities of the material, construction of the
piping and such.
So the staff is trying to get that information from BG&E and
to work towards closure on this, to see if, in fact, they can bound it.
DR. SHACK: That's another one where it seemed like a sample
inspection is not terribly useful, because then that problem arises
because of a very specific sort of circumstance. If your sample
includes small bore piping with those conditions, then you may find it.
If it doesn't, it doesn't, but that doesn't really give you any
assurance that it isn't a problem somewhere else.
It would seem to me that that somehow has to be a more
specific review of the particular design and geometry rather than an
inspection program, a sample inspection program.
I mean, the Oconee people look in particular places because
they had a history, they know sort of what they're looking for.
MR. SOLORIO: Right, correct. You're probably more of an
expert on this than I ever will be, but it's my understanding, because
of that history, Oconee did commit to a certain amount of program checks
and BG&E hasn't -- I guess there are some differences with CE plants
that don't automatically just allow you to --
DR. SHACK: They're arguing that it's not a real problem.
MR. SOLORIO: Right. But the staff is still trying to work
with them to come up with the right solution. Someone is going to
comment.
MR. GRIMES: Bob Herman from the Division of Engineering
would like to add a comment.
MR. HERMAN: Yes. The only comment that I would provide is
that I think the thing that they're looking at in terms of the
comparison between portions of the CVCS and the RCS may not be in terms
of a thermal fatigue damage mechanism. It may be in terms of some other
damage mechanism and it might be IGSCC, but I'm not sure.
But I don't think that particular -- and I may be wrong on
this -- but I don't think that particular location is trying to make
bounding arguments on thermal fatigue. I think they're looking at that
somewhere else. At least that's what Keith said a little while ago.
MR. SOLORIO: I'm not going to disagree with you.
MR. HERMAN: But anyway, that issue is open and they're
working on it.
DR. SHACK: I guess my comment was that inspection didn't
strike me as the way to really -- the best way to resolve it, probably.
MR. HERMAN: I don't think I'd argue with you.
MR. SOLORIO: One of the next items we're working with BG&E
to close out regards the reactor vessel flange leak-off line. The staff
believes that because BG&E has seen cracking in the line before that
it's an aging effect warranting an aging management program. BG&E
initially responded that they rely on RCS leakage detection procedures
that are performed daily to let them know if they've got a problem with
that line.
The staff is working with BG&E to understand some additional
details about how -- other ways they might detect problems with that
line, and that's kind of where that stands right now.
The next item involves cracking in the pressurizer cladding.
Staff believes that industry experience -- i.e., Haddam Neck -- has
shown that cladding in the cracking is a plausible ARDM and that in
itself is not the worst concern. The worst concern would be whether or
not that would crack or propagate into the base metal.
BG&E doesn't believe it's an aging-related mechanism. They
believe it's related to some initial fabrication or initial startup
testing operations that would have caused these problems at Haddam Neck.
DR. UHRIG: Is Haddam Neck the only plant that had this?
MR. SOLORIO: That I'm aware of. I don't know if there are
others. But BG&E -- nevertheless, BG&E agreed to inspect. What the
staff is doing is now trying to discuss with BG&E what might be the most
appropriate location to look. So that's kind of where that one stands.
The last open item that the staff and BG&E are working on is
the final safety analysis report supplement that was submitted with the
LRA. There's kind of two parts to this. First was whether or not it
needed to be updated prior to issuing a license to reflect the staff's
review and the commitments made by BG&E as a result of the staff's
review, and, also, what level of staff information that was -- what
level of information the staff relied on in making the safety evaluation
conclusions needed to end up in FSAR.
We've had a couple public meetings with BG&E back on 8/20
and 8/27 to talk about this. BG&E, we provided BG&E with some options
on how to resolve this, so we could proceed towards closure. They chose
an option by which they would take a cut at coming up with a list of
information they believed should be included in the -- ultimately the
FSAR, once it's updated, because that's the whole intention of
submitting the FSAR supplement with the LRA, is to have a set of
information that gets put in the FSAR that comes to the -- is the
licensing basis from there forward.
Basically, the staff is working with BG&E to try to reach
closure on this based on their option. I'm not sure I explained the
option correctly. They provide the list of what they believe and the
staff will take a look at that and try to make sure that it's what we
would think was necessary to gain the regulatory control we're looking
for by putting information in the UFSAR.
What I didn't put on this slide, there are two other
confirmatory items the staff is working with BG&E to close. One of them
involves cast, cast austinetic stainless steel. BG&E has had and the
staff has had a lot of discussions on this.
MR. BARTON: What is the issue?
MR. SOLORIO: It has to do with inspections of cast
austinetic stainless steel. BG&E and the staff had come together and
talked about a criteria by which the components that had a certain
amount of cast or certain amount of ferrite were determined to be
subject to an inspection, and that's discussed in the safety evaluation
report.
DR. SHACK: And you've agreed on that, the screening
criteria.
MR. SOLORIO: We've agreed on that. What the staff needed
to go a little bit farther and talk about what do you do once you've
come up with a sample and how do you evaluate it by analysis, do you
evaluate it by a certain kind of inspection, what do you do next.
We're waiting for some additional information from BG&E to
help the staff disposition that issue.
And the last one is the control element assembly shroud
bolts. This was initially a confirmatory item. What the staff has
done, based on BG&E's response, is tried to look at the potential
failure mechanism of these bolts, whether or not it would be a localized
or a dispersed failure mechanism and whether or not -- you know, what
appropriate steps might need to be taken if it was concluded to be a
localized potential failure mechanism.
We're still waiting for additional information from BG&E. I
think they're working with CE to try to get that for us.
DR. SHACK: Is this one of these arguments of how many bolts
do you need to actually make the thing work?
MR. SOLORIO: That is part of the --
DR. SHACK: Discussion.
MR. SOLORIO: -- discussion. Before there is a safety
impact. I mean, there can be a certain number of failures that can
occur.
DR. SHACK: And it's not a problem.
MR. SOLORIO: And it's not a problem. It's just whether or
not you assume localized or dispersed random. And that's all I have
regarding the status of the Calvert Cliffs LRA.
If there aren't any other questions, I'll turn it over to
Joe.
MR. SEBROSKY: My name is Joe Sebrosky. I'm the project
manager for Oconee license renewal. I'm going to follow the same format
that Dave did and just go over the schedule adherence and open items of
interest.
As far as the schedule adherence goes, all the milestones
have been met to date. The next major milestones that we're working
towards is Duke is to respond to all the SER open items by October 15.
We're to issue our final SER February 12 and the Commission is to reach
its decision in August of 2000.
The open items of interest are basically the list is similar
to the one that we presented to the full committee on September 1. I
deleted some things and made some -- have some additional information
for you.
Regarding the first issue, the scoping issue, that was the
subject of recommendation in the letter that the full committee gave us
on the 13th, as you are aware.
Where that issue stands right now is the staff visited the
site the week of August 16 through 18 to have a discussion with Duke.
As a result of that discussion, things were clarified and discussed
further in a management meeting that we had with Duke in late August.
It was decided at that management meeting in late August
that the ball is in the staff's court. We are to -- the action item
that the staff currently has is to develop a plan for the resolution of
this issue and send it to Duke. We're currently working on a letter to
transmit that plan to Duke. We have not done that yet.
As far as -- so that's where the scoping issue stands right
now.
As far as the complex assemblies issue --
DR. BONACA: Before you move out of that. I read this
August 5 letter on license renewal issues, scoping guidance, and in
reading through, clearly there is a discussion of the difference in the
definition of what the set of events is, but it's not clear what the
staff proposes to use as the set of events per -- for the license
renewal rule.
Is it the set of events which is used in the SRP?
MR. SEBROSKY: I'll turn that over to Chris.
MR. GRIMES: I'll respond to that. We're going to feed back
the experience from the Oconee review into improving that guidance on
scoping. It was our intent with that guidance to link the set of events
to whatever the licensing basis relied upon as design basis events.
What we discovered with Oconee was they used a different
definition of the term design basis events. We viewed it as something
that was fairly broad and expansive and they have a much narrower view
of a design basis event as distinguished from design conditions, like
earthquakes.
And so we had to overcome that language barrier first in
order to understand how to get to this question about a broader event
set. I would expect that we would include a typical event set in the
standard review plan as a starting point, but we're still going to
relate it back to the events for which the plant is designed and
licensed, and some plants may have different design basis events than
others.
That's why it's very difficult for us to try and be very
specific about what are design basis events.
DR. BONACA: But ultimately you are going to address
functionality of systems that are required to provide for safe shutdown
and --
MR. GRIMES: Yes.
DR. BONACA: Okay.
MR. GRIMES: As a matter of fact, I would argue that we've
spent a lot of time talking about what a design basis event is. We
haven't spent enough time yet concentrating on what are the underlying
safety functions.
DR. BONACA: Exactly.
MR. GRIMES: That are relied upon in order to prevent and
mitigate events. And in some cases, what we found when we were going
through the Oconee scoping evaluation is that they relied on some
structures and components to perform functions that aren't analyzed
events in their licensing basis, but ended up being enhancements to the
plant over time as the licensing basis has been maintained.
So that's why it's been somewhat difficult, because we need
to clarify that the interest that we have is in the functions that the
systems, structures and components perform and not necessarily whether
it's officially an analyzed event for the purpose of a design basis
event in the final safety analysis report.
It also gets us back to the problematic aspect of the
definition of what is a current licensing basis, which is still somewhat
controversial.
DR. BONACA: But I think that the focus should be function
and the question I have is, is there any consideration of looking at
IPEs or to look at some of those components which, in fact, are pointed
to be important functionally.
MR. GRIMES: In the review guidance and the inspection
guidance, we look at the IPE in order to identify those areas of
particular concern and so we use that as a pointer to test the process.
And in developing or -- excuse me. During our review of the
scoping guidance, we went to the functions and pursued the functions as
a way of revealing this issue. And some of the functions are important
in the IPE and we confirmed that those components are -- we hope to
confirm that all those components are within the scope of an aging
management review.
So that we use the risk insights, but we expect that in the
future you will see, as risk-informed requirements mature, that we'll be
able to do that in a more methodical way. Right now we do it based on
engineering judgment.
DR. BONACA: I have just one more question that comes
regarding that. In the scope issues, there are proposals on the table
for risk information of Part 50 and there is an option two that is being
pursued, I think, expeditiously, which has the potential for changing
significantly the number components that are under, for example, a
quality assurance program.
How would that affect implementation of this rule? That
would be a major change or shift in it. And I guess the question I'm
pursuing is really the use of risk information is becoming part of
supporting Part 50 and I don't see as much movement in the direction in
the license renewal area.
MR. GRIMES: And the reason that you don't see much in
license renewal is because we are primarily approaching this from a
deterministic perspective in terms of what functions are relied upon in
the licensing basis.
We expect that risk-informing Part 50 will change the
licensing basis and then there would be a comporting change in the scope
for license renewal.
But we rely heavily on maintaining the current licensing
basis and extending it into the period of license renewal and as we gain
experience in how Part 50 can change, we would expect that Part 54 --
let me say -- theoretically, Part 54 can naturally evolve from that.
But as I stated at the Commission meeting on the proposed
changes to the maintenance rule, I would suspect that as the industry
moves forward to risk-inform the licensing basis, it's going to cause
some confusion in scoping for license renewal because we go to the
traditional Q list as a starting point. We go to the licensing basis as
the starting point and say, well, what are the safety-related structures
and components.
So when you start changing the definition of safety-related,
when the definition is already as fuzzy as it is in terms of how the
licensing basis maintains it over time, and I think Oconee was
particularly advantageous for us because they have maintained their
original concept of safety-related and added to it by having different
layers of quality assurance.
So that approach basically has revealed how the evolution
effects what is designated as a safety-related structure or component.
So it's been very useful for us in understanding the underlying process
implications. But in the end, I think license renewal can naturally
follow from risk-informing Part 50 and to making changes to what safety
functions are relied upon for the purpose of licensing.
DR. BONACA: I think as you seem to be focusing the SRP
guidance on functionality of systems, maybe put into -- you know, put in
words that would allow, if things change, in fact -- well, again,
functional -- focusing on functionality would allow that to happen.
MR. GRIMES: I'll keep that in mind when we're trying to
update and focus the scoping guidance. But there were -- we did put
some thoughts in it that related back to as the CLB changes. We didn't
distinguish on what basis, but we could add a clarification that says
including risk-informing the functions.
DR. BONACA: Thank you.
MR. SEBROSKY: The next open item of interest I have is
complex assemblies. For that issue, the staff does not agree with Duke
that passive long-lived skid-mounted equipment should be excluded from
an AMR. This issue was brought to the staff's attention during a review
of the diesel generator, the supporting equipment for the diesel
generator.
We have since -- since the September 1 meeting, we've since
gotten an indication from Duke that they're rethinking their position on
complex assemblies and they may scope in additional portions of the
skid-mounted equipment.
And Mr. Westman, during the break, reminded me that this
issue, along with some other things that we're discussing with Duke, has
the potential to add additional workload to the staff that we had not
necessarily budgeted.
Specifically, Duke has indicated, like I said, verbally,
that for the diesel generator, they may scope in additional portions.
They have also indicated that the chilled water system, we had an open
item on the chilled water for the control room, why was that not within
scope, and Duke has since told us that they have rethought their
position and now consider that to be within scope.
The problem with those two issues and then as part of their
license renewal application update, they have identified two changes
that were made to -- at the site after their license renewal application
was provided. That was an emergency vacuum system was installed and
they did an updated Chapter 15 analysis on their steam generator tube
rupture.
So the short story is they're going to be adding systems,
structures and components, either because of changes at the site or
because they've rethought their positions. From a resource standpoint,
we're going to have to review, once you determine that that system is
now within scope, it doesn't end there. You have to determine if the
aging management review was done appropriately.
So the issue with complex assemblies, although we may reach
agreement on that, the problem then becomes how are we going to review
that in a sufficient amount of time to make our next major milestone,
which is February 12 to issue the FSAR.
So that's a little more background on that issue.
Continuing on with the items of interest, again, the content
of the FSAR, there was mention of that in -- the updating of the FSAR
was mentioned in the ACRS letter. Dave also had this item noted.
Duke may be taking a different course than Calvert in
resolution of this. They may provide us with an updated FSAR. That has
not been determined yet.
MR. GRIMES: If I could clarify. Duke has talked about
providing an updated supplement and just to make it clear that we're not
trying to get the whole FSAR updated before a Commission decision,
because that's a much larger job.
But we still have, in both cases, a question to resolve in
terms of what's the appropriate level of detail in the characterization
of the commitments that have been made on managing aging that are
appropriate for the FSAR.
So that's a common theme for both plants, although Calvert
is approaching it from a listing perspective and Duke is approaching it
from the standpoint of revising the supplement.
Both of them are going to have to deal with this question
about how the commitments are going to be treated for the purpose of the
license decision.
Sorry, Joe.
MR. SOLORIO: That's fine. I appreciate the clarification.
The next two items provide the basis that void swelling is not an issue
or provide an aging management program and resolution of reactor vessel
internals issues.
When we presented that to the full committee, those issues
were lumped into a Section 3.4 of our SER open items. We have several
open items in 3.4 that relate to these issues.
As far as the status of these items go, we have a meeting
scheduled with Duke on the 29th of September to give them feedback on
the responses that we've gotten from the owner's group and the
plant-specific responses that we've gotten from Duke on if they hit the
mark or not.
The reason that we need to do that, we're doing that in a
meeting, is we will not have the final safety evaluation out for 2248
probably until the end of October and if you go back to the milestones
schedule, Duke has to have all their responses in by October 15. So
we're giving them verbal feedback in order for them to meet the
schedule.
The last item that I have under open items of interest are
fatigue-related issues and the status of that really hasn't changed
since we briefed the full committee. We had a meeting with Duke and we
told them, we gave them some feedback, which they said they would
consider and give us an updated response by October 15.
DR. KRESS: Was there an open item on the need for
inspecting the dam, providing auxiliary power?
MR. SOLORIO: There were some open items related to Kiwi,
which is the hydroelectric station itself. But as far as the aging
management program for the dam, Duke relies on FERC criteria, the
Federal -- I don't remember what FERC stands for, but --
MR. GRIMES: Federal Energy Regulatory Commission.
MR. SOLORIO: Yes. They have an existing program that
they're required to inspect those structures under FERC requirements and
we found that acceptable in our SER. We also have a -- there was a
generic license renewal position on that that we issued. Was that your
question about the dam itself?
DR. KRESS: yes. I didn't realize you resolved it.
DR. SHACK: Just to get back to the fatigue-related issues,
as I recall, the resolution of that was not to resolve it now, but to
wait, basically.
MR. SOLORIO: Yes. What the -- if you go back to the
meeting that we had in August, basically, the pitch that the staff gave
to Duke was we think that there is enough information out there now that
you can resolve this on a plant-specific basis, and that's what Calvert
did.
And otherwise, if you rely on a process that takes into
account all the research that is being done and, at a later date, will
implement that process that falls out of the research that's going on,
there's some regulatory uncertainty associated with that.
So the feedback that the staff -- Duke's proposal was
basically we're going to rely on a process and the staff's feedback was
that may be acceptable, but if you take the plant-specific tack that
Calvert did, we can write off on that and we think that there is enough
information out there that you can do that.
Duke told us in August that they would consider that and let
us know by October 15 which tact they would take.
The next item was not discussed with the full committee, and
that's the inspection report item. The section -- the second inspection
report for Oconee was just issued. It was issued on September 21. One
of the findings in that inspection report, it states that the NRC does
not agree that no aging management programs are warranted for electrical
cables and connectors.
We have -- if you go to our SER, our SER found the scoping
and what Duke did for an aging management review for the cables
acceptable. So there was no open item. But the reviewer that was
involved with that said I'm concerned about aging effects and I
understand from the application that Duke determined that there were no
aging effects, but I'd like to be part of the inspection team that goes
down and reviews the site documentation.
As a result of that, they determined that there are some moisture
radiation and heat aging effects that are going on at the site that were
revealed to them during walk-downs and also through a look at Duke's
problem investigation process.
The reason that I put that as a separate item, again, we do
not have an open item for the electrical cables, but we are going to,
based on the results of that inspection report, we're probably going to
have to take a look at the aging management review again for the cables.
It becomes a scheduler issue. That's all the items I have
for Oconee.
MR. MATTHEWS: I'd like to make an additional comment for
the members' benefit, given that this is a discussion of generic
activities affecting license renewal.
The other half of my organization would feel slighted if I
didn't discuss where we are with regard to the environmental review and
the fact that we had a critical path item that the members may recall
relative to Part 51 and its treatment of environmental impacts of
transportation of spent fuel to and from an ultimate repository; in this
case, Yucca Mountain.
We did publish in the Federal Register a final rule approved
by the Commission indicating that those transportation impacts would
indeed be treated on a generic basis and it provided that generic basis,
supported by an addendum to the generic environmental impact statement
for license renewal.
However, we do have some tight schedules yet to meet in this
regard, given that the addendum to the generic environmental impact
statement has to be submitted to EPA and subjected to interagency and
potentially CEQ review before it can be viewed as being effective.
That comment period will be over on the 4th of October, at
which point the two subsequent supplemental EIS's for Calvert Cliffs and
for Oconee will then themselves be subjected to an interagency review,
since they rely on that addendum to the GEIS, and those time periods
toll 30 days after they're submitted to EPA.
In terms of timing, this works out such that we expect to
issue the Calvert Cliffs supplemental impact statement in support of
license renewal on November 16. That's dependent upon this EPA review
being completed by November 15.
In a similar way, we expect the Oconee supplemental
environmental impact statement to be subjected to EPA review and
interagency examination and if all goes according to schedule, we will
be issuing it on schedule on February 12, along with the SER.
So there's still some critical dates that need to be met for
this all to fall into place. As you can tell, the staff has been
managing these milestones down to almost the hourly basis. But I wanted
to indicate to you that we are on a path to success here. The
Commission did approve the rule and did approve the supplemental
environmental impact statement.
So that major hurdle I think is, for the most part, past.
By the way, this is David Matthews. I'm the Director of the Division
for Regulatory Improvement Programs in NRR.
MR. GRIMES: And I will add to Mr. Matthews' explanation.
We're now looking at all the milestones leading to a Commission decision
for Calvert Cliffs in order to determine exactly how much more time is
needed in order to complete the license renewal review. We're going to
be working with the committee to develop a schedule to get the earliest
possible ACRS conclusion.
The regional activities are going to be concluded with a one
week inspection in December that's going to look into open items and
whatever other aspects of the renewal evaluation Hub Miller wants to
have explored in order to make his recommendation to the Commission.
So we'll be setting up detailed schedules in terms of the
milestones to closure that we'll be sharing with Baltimore Gas &
Electric at the management meeting on the 29th of September, and we're
going to identify all of those actions that need to be taken in order to
get to a Commission decision and then determine whether or not we can
improve on the May 2000 completion schedule that we're continuing to
work towards.
I will say that I don't see any way that we can improve on
the November 16 date to complete the safety evaluation. We've basically
used the time that's necessary to develop final safety evaluation inputs
with ongoing dialogue on some of these controversial topics.
I think the status for both Calvert Cliffs and Oconee that
Mr. Solorio and Mr. Sebrosky just described illustrates to you the kinds
of controversies and questions that are coming up as we try and finalize
the safety evaluation, and they are in areas where the technology is
evolving pretty fast.
So it will give you some idea about, from a process
perspective, the kinds of things that you're going to be faced with,
that we are faced with, and you'll get to share with us.
DR. BONACA: Again, we're trying to support your schedule.
On the other hand, one strategy -- we're developing a strategy right now
for our review of the process and the applications and one of the
recommendations that we're going to make most likely is that we will
have a subcommittee meeting before to review the supplemental SER.
Probably that's one of the important points for us to give
some perspectives and to support a December letter, we will need to have
material in hand sometime in October for us to be able to then support
that kind of ACRS report.
MR. GRIMES: In order to be able to work the milestones, and
I would propose that we would bring to the -- we would work with the
committee to describe the resolution of the open items in parallel with
developing the final safety evaluation by November 16, and then however
many ever meetings it takes or whatever ends up being the most efficient
way for us to communicate with you, but we'll continue to work with you
towards trying to support some activity in October and then the earliest
possible final safety evaluation that we can share with the committee,
the subcommittee.
DR. BONACA: One thing the subcommittee will be interested
in seeing, at least I will be interested in seeing is not only the
specific closures that you have on open issues right now, but at some
point, to understand how the specific applications dealt with all the
license renewal issues.
That may not be -- I don't want you to go to a new project
now or having to pull out the information and do that, but certainly,
for some of the issues, I remember, there's some, and I think it would
be worthwhile for us to understand what kind of modalities were
presented and that were acceptable to the staff.
MR. GRIMES: We did explain the relevance of generic renewal
issues when we presented the original safety evaluation conclusions to
the subcommittee. So the material exists and it can be updated for that
purpose.
DR. BONACA: Right. In looking at the longer schedule here,
I'm looking at the overhead number six that you presented at the
beginning. In that schedule, you have identified an ACRS meeting on
GALL, SRP and reg guide based on NEI 95-10, that is supposed to be in
February 2001, and we certainly would support that. But I would expect
we would have to have at least one more meeting, if not --
MR. GRIMES: That was in order to make sure that there was a
stake put in the ground for you, in terms of where we felt we'd need
some ACRS action, but that didn't mean that we wouldn't expect to have
ongoing contact with you up until that point. We would expect to keep
the subcommittee informed as we progress along this schedule.
But we did want to let you know where we felt it would be
important to have an ACRS decision point.
DR. BONACA: Sure, and we will support that. But certainly
in the next year, I think it would be important to have at least one
meeting where we would like to see some progress, what kind of progress
is being made on the license renewal issues and how they're coming
together. Again, the objective would be to understand how we get to the
stability we were discussing before and what issues are really the hard
spot after we go through the license renewal of the first two
applicants.
MR. GRIMES: We'll do that. We'll continue to work with the
subcommittee on scheduling periodic meetings like this to discuss the
status of generic renewal activities.
DR. BONACA: We also need to have from you information
whenever some issues appear, like the credit for existing programs, that
you may require from us a review and we will attempt to support that.
MR. GRIMES: As we mentioned before, at this point, we
haven't identified any other policy issues. As soon as we identify a
policy issue, we'll let you know. In the meantime, we'll leave it to
the subcommittee to choose amongst the proposed resolutions of generic
renewal issues, those which you'd like to be briefed on. Otherwise,
we'll just plan on some periodic meetings with the subcommittee to
discuss the overall activities.
DR. BONACA: Any other questions from members?
MR. SOLORIO: We have the last two slides to present.
DR. BONACA: Sure. Okay.
MR. ANAND: Good morning. My name is Raj Anand. I'm the
project manager in the License Renewal and Standardization Branch. The
industry's last approach to license renewal was to submit plant-specific
and owner's group technical reports on particular topics for staff
review, instead of submitting a complete license renewal application.
Let me briefly present to you the status of review of the
owner's group generic technical reports, the Babcock and Wilcox owner's
group, representing five B&W units, have formulated a generic license
renewal program. The B&W owner's group submitted generic license
renewal reports on the reactor coolant system piping, the pressurizer,
the reactor vessel and the reactor vessel internals.
The staff has issued the final safety evaluation report on
all the B&W owner's group report except one, which we intend to issue
sometime the end of next month.
The Duke Power Oconee has used these license renewal reports
by reference in their license renewal application. The Westinghouse
owner's group also has a program for license renewal and has submitted
technical reports on the aging management activities on the reactor
coolant system supports, the pressurizer, the Class I piping, the
containment structure, and the reactor vessel internals.
The first Westinghouse plant license renewal application is
for Turkey Point, which is not scheduled to NRC sometime till December
2000.
The boiling water reactor owner's group is currently
concentrating their efforts on reports related to vessel internal
programs for license renewal. So far, BWR VIP group has submitted 11
license renewal appendices and the staff has issued a final safety
evaluation report on BWR VIP-49, the instrument penetration. The staff
plans to issue the final safety evaluation report on BWR VIP-27, which
is the liquid standby control system, sometime next month.
The first BWR plant license renewal application is for
Hatch, which is due in March 2000.
DR. UHRIG: Is there one for the CE owner's group?
MR. ANAND: No. CE has not announced any kind of
involvement.
MR. GRIMES: Let me comment, though. I understand that an
outgrowth of the Calvert Cliffs application, that the CE owner's group
is now going to pursue some of the experience that Calvert Cliffs had
and that the new company that evolved from the Calvert Cliffs efforts,
the Constellation Energy Services is going to be working with the CE
owner's group and they may be developing some topical reports that will
at least be developing some shared experience that the CE plants will
draw on.
But they still have not specifically identified any
schedules for submitting topical reports.
MR. ANAND: The second slide is the announced future renewal
application. In the opening remarks by Mr. Chris Grimes, he has briefly
stated the future announced license renewal applications. For the
budget purposes, we will have two applications in FY-2000, which is
Arkansas Unit 1 and Hatch Unit 1 and 2, and we might have four
applications in FY-2001 from Turkey Point Unit 3 and 4, Catawba Unit 1
and 2, and McGuire Unit 1 and 2.
DR. UHRIG: What do you mean if the exemption request is
approved?
MR. BARTON: They're not 20-year-old plants yet.
MR. ANAND: The Duke Power's McGuire has submitted a request
for exemption. The rule requires that the utility or the plant will not
submit an application until it has experience of 20 years. McGuire unit
will be a -- Unit 1 will be the earliest plant which will be completed,
it's 20 years in June 2001, which will be followed by Catawba, which
will be followed by McGuire Unit 2, which is 18 years old, and will be
followed by Catawba Unit 1, which will be 16 and a half years, and Unit
2, 15 years.
Our evaluation of this exemption request is in process and will be
issued pretty soon.
DR. UHRIG: Is the purpose simply to keep the team in place
from -- that's been working on the Oconee?
MR. HOFFMAN: This Duke -- that is one of the primary
purposes. When they had the team together to experience, they're going
to shift it over to the McGuire/Catawba, but they're also looking for
efficiencies, they believe, on their side, as well as the staff's
review, because of the similarity between the design, maintenance
operation, the common programs between the two sites.
Once we kind of get through Oconee, they're going to start
focusing, we're going to start a dialogue on where -- how actually to
package that application and to see where efficiencies might be achieved
and it's actually going to tie in with -- Virginia Power has indicated
they want to send in their North Anna and Surry applications at the same
time and look at -- because they've got some common aging management
programs and such.
So that's an effort that we're going to be taking up in the
near future, is looking at those combined -- I won't say combined
applications, but the applications coming in concurrently.
MR. GRIMES: That completes the staff's presentations and
we're prepared to respond to any other questions you might have.
DR. BONACA: Any other questions from members of the
subcommittee? If not, then we want to thank you for a real informative
presentation. We need to, again, as we've stated before, to be staying
in touch as we develop our own strategy to review and support your
process.
MR. MATTHEWS: We would like to thank the subcommittee and
the full committee members, of course, for your continued support in
this process.
I wanted to state that from the NRR's management
perspective, with regard to the timeliness and resources to be dedicated
to license renewal reviews, that we intend to hold to the schedule
template that we had established at the beginning of this effort
relative to the 24 to 30 month schedule associated with site-specific
individual applications.
We intend to utilize our planning, budgeting and performance
management process to adjust internal assignment of resources to sustain
those schedules and so, therefore, the limitations on any future
improvements of those schedules will not be as a result of any absence
or lack of NRC resources to be applied to them.
The limitations exist primarily as a result of limitations
of what I would call process driven. As you know, there are established
schedules for public comment on environmental impact statements and for
their noticing. We have limitations on our stakeholders, of course, the
applications themselves have their own constraints associated with
timeframes for response. NEI has its limitations in terms of its
ability to respond on generic issues.
So we recognize there are some constraints on further
improvements in those schedules from the process standpoint, but NRR's
management is committed to the principal that for the foreseeable
future, we're going to adjust and apply resources as necessary to
maintain the schedules that we've advertised.
We appreciate that the ACRS has appreciated the sensitivity
we have to these milestone schedules and are doing everything they can
to facilitate it, and we will continue to apply the resources necessary
to ensure you have the information and support that you need from the
staff in order to do that.
So with that, the staff's presentation is concluded. Thank
you.
DR. BONACA: Do we have any other presentations before?
With that, thank you, again, and we're going to move into the last item
on the agenda, which is a discussion of the ACRS review strategy. And
this is going to be on the record, right?
Here I would like to say that we are scheduled next week to
talk about strategy, the ACRS. So in order to support that process, we
put together a first draft of a five-page -- what I'm referring to is
the document that says revision one, Rev. 1. Rev. 1 really is equal to
the first document we had before, plus those additions which we have
marked on the side to give a little support to logic that I'm presenting
here for the number of review meetings we should have in support of
every application.
This document will require additions, for example, on the
second page, under evaluation of effectiveness of license renewal
process, we have to identify possible additional meetings that we need
with the staff, as we had today, and they're not identified here.
But what I would like to do is simply walk through it very
briefly and get your feelings about the proposed approach, as well as
modifications of these documents we need to make for us to have a
document next week.
This five-page document essentially goes, the first page,
where we've just stated that the ACRS should review a report on each
license renewal application. That was an issue that we discussed at the
ACRS. Some people felt that maybe we had to continue our involvement
through the establishment of the process, but we feel that because of a
number of reasons which are presented here, we should be involved in
review of each license renewal application, even after the process is
established.
On the second page --
MR. BARTON: Mario, on the first page, the only comment I
got is item three, evaluation of policy issues in light of the recent
SRM. Is this still something we ought to be involved in?
DR. BONACA: I'm sorry?
MR. BARTON: Evaluation of policy issues, item three.
DR. BONACA: That's --
MR. BARTON: Is this something we still are chartered to or
want to be involved in based on the recent SRM that said the ACRS should
not be delving in policy issues?
DR. BONACA: Yes.
DR. KRESS: If they involve safety matters, we still can.
Clearly, we would limit it to that.
DR. BONACA: See, if you look there, John, on page two, at
the end of those four bullets, I put a statement that says discussion of
evaluation of policy issues by the full committee. I feel that
everybody should be involved and I think that next week, when we meet to
discuss, we can touch on those.
DR. KRESS: We can probably do that as we go along and it
won't take extra meetings.
DR. BONACA: I agree with that. One could even propose that
we leave them open and we learn from the experience in the application
and see where they go.
For example, the issue of grandfathered plants I think is
falling off as we address the functionality of components that should be
included in the rule and we're looking at scope.
DR. KRESS: I have more concern about the evaluation and the
effectiveness, why actually are we doing that.
DR. BONACA: The effectiveness?
MR. BARTON: How are we going to measure that?
DR. KRESS: Yes, how we're going to measure that, that's the
problem I have with it.
DR. UHRIG: Is that also outside the domain of --
DR. KRESS: And is it in our domain. Those are the two
questions I have.
DR. UHRIG: It's not safety, per se.
DR. KRESS: So I had more issue with that one.
DR. BONACA: That's a good point. If you remember the
presentation we had, that's a good point you're making here. Here, more
the evaluation of the effectiveness really is contribution to the
process.
MR. GRIMES: This is Chris Grimes. Just as a point of --
maybe this is a linguistic detail that you're not concerned about, but I
would point out that the criteria that the staff is trying to achieve is
the phrase in Part 54.421 on aging management programs, says that the
staff is supposed to find whether there is demonstrably effective
programs.
So from that standpoint, our focus is on the effectiveness
of the programs and we would be seeking ACRS endorsement of our finding.
DR. KRESS: Clearly, that's a safety issue and we didn't
talk about that one.
MR. BARTON: As opposed to the effectiveness of the whole
process.
DR. KRESS: Of the process.
DR. BONACA: So here we're talking about evaluation of the
effectiveness.
MR. BARTON: We probably want to narrow it to what Chris has
described.
DR. KRESS: That would be part of our review of the SER and
the application.
DR. BONACA: That's right. So the effectiveness
demonstration. Again, under item two, we expand it to recognize that we
will have meetings to deal with those. And the focus of the ACRS
reviews, here is a tentative list of items that I felt some of the
members should focus some attention on and this is open to be expanded.
MR. BARTON: I didn't have any problem with the list as it
currently stands. I don't think there is anything on there that would
take --
DR. UHRIG: Just a question. Are you going to assign teams
to different plants? Are you going to assign a particular area to
individuals for the review for all plants or how do you --
DR. BONACA: The last section, subcommittee review process,
one recommendation there was that we would keep an individual looking at
certain portions, because he's becoming an expert in those, most of all
by comparing how different applicants are doing the same thing.
You really become much more capable of repeating. So the
thought was -- and, also, it would facilitate, I think it would
facilitate the review process for us. So we might want, at some point,
to change that, but my recommendation would be that individual assigned
for specific topic already on the plant or issue, they could review the
same topics or issues.
DR. KRESS: I didn't notice in here factored in the need to
review any technical reports. Are we through with those?
DR. BONACA: No. You mean like --
DR. KRESS: Would they show up in here as -- where would I
find those?
MR. BARTON: The topics, you're talking about?
DR. KRESS: This list we were just given that --
MR. BARTON: The list of topicals.
DR. KRESS: The topical reports that are referenced, those
things. So are we going to review all those?
DR. BONACA: Yes, but typically we review those as part of
the applications.
DR. KRESS: As they're referenced in an application, we
would try to review them.
DR. BONACA: That's right. The way we did it for Oconee,
for example.
DR. DUDLEY: The problem with reviewing them at the time
that they appear in the application is that they are already final. If
the committee wants to review the contents and have comments and
recommendations on the contents of the topical reports, it really needs
to review those topical reports in a draft stage.
DR. BONACA: But that would be almost participating in the
process, in the review process of the applicants or actually the owners'
groups, and I don't think we want to be involved in that.
My feeling is that we should be looking at what the staff
has concluded with respect to what they are proposing.
MR. DUDLEY: Then the appropriate time would be when the
staff's safety evaluation report on a topical report is in a draft
stage. That would be the appropriate time for the ACRS then to review
the topical report, which, in some cases, will be before there is even
an application for that vendor type plant.
DR. BONACA: But it seems to me that if you disconnect that
topical report from a specific application, you are missing some
elements. I guess we could do it, but --
DR. SHACK: Clearly, we can't review all of those reports.
That has to be on a selective kind of basis. I'm kind of inclined to
agree that we probably -- you know, what Noel says is desirable, in
general, but as a practical matter, I really think it's going to have to
come as they are referenced and you sort of have to take into account
their importance to the process.
DR. KRESS: I think maybe we -- my thought was we might want
to look at them and prioritize them and select a few of them to look at.
That's what I thought.
DR. SHACK: I mean, even for Oconee, we didn't review them
all.
DR. BONACA: That's right. But, again, it seems to me that
it would be more appropriate to make the selection in the context of
applications. For example, because, you know, hypothetically, somebody
could submit all these topicals and nobody uses them for license
renewal, so they are sitting there --
DR. KRESS: They waste their time.
DR. SHACK: I wouldn't lose too much sleep over that one.
DR. BONACA: That's right. But then I think it would be
good to verbalize this in the strategy.
DR. KRESS: Yes, that's what I thought. Some mention of it
somewhere.
DR. SHACK: This is actually the first time I've seen this
list.
DR. BONACA: Right.
DR. KRESS: That's a good question. Is this a complete list
or are there others that haven't showed up yet? I presume this is a
complete list.
DR. SHACK: I know this isn't a complete list of the VIP
projects.
MR. GRIMES: This is a complete list of the topical reports
that will be relied upon for aging management for license renewal. This
is all that -- let me put it in a more pragmatic way. This is all I'm
prepared to commit resources to.
DR. SHACK: But 14 in VIP-59, you don't think they'd be
referring to those for their aging management for various --
MR. GRIMES: They're captured in other VIPs that -- the BWR
vessels internals program is a huge, complex matrix of interrelated
work. That's the most polite way I can put it.
We went through, with the assistance of the BWR VIP folks,
and they're pointing at specific things that they want to rely on for
license renewal.
So with the assistance of Mr. Strosnider and his staff,
we're looking to these things as the ones that we need to track.
DR. SHACK: I see. So they pulled this 38 for the shroud
support out even though the relevant technical information is in 59, for
example.
DR. KRESS: I guess it would be helpful if, when the staff
reviews these and they come up with some issue that they disagree with,
look at specific issues, that would be nice. That would help give our
opinion on how to resolve it.
MR. GRIMES: But as Dr. Bonaca mentioned before, they're
revealed during the course of the staff's -- in the referencing of the
reports, in B&W's case, but like generic renewal issues, as we stumble
across any controversies in the topical reports, we notify the
subcommittee.
DR. KRESS: That, I think, would be particularly
interesting. Kind of like your four-step and two-step process, that's
practically about the best way to do it.
DR. BONACA: That's why I was concerned about the issue of
the issue list, where there are those. My feeling is still once we have
an SRP, that it captures most of the process, we should not have a lot
of objections to the SER, that we should generate an interim letter. We
could wait for a supplemental SER for us to have an ACRS meeting and
then a letter.
DR. KRESS: I think that SRP is going to have a lot of that.
That's fine.
DR. BONACA: Because many of the issues I see right now, the
license renewal issues, really have to do with decisions on what's an
acceptable process. I would expect the majority of the list to be
closed. I mean, there will always be a list.
DR. SHACK: Okay. So we don't need interim letters in all
circumstances.
DR. BONACA: That's right. There is a provision here, I
think, on page four.
MR. BARTON: The top of page four.
DR. BONACA: Third paragraph, there may be some instance
where the SER has significant comments on the SER that may effect the
SER and the resolution of open items, and then in that case, we would
schedule an interim full committee meeting to review the SER and to
write an interim report.
DR. KRESS: Do we have enough time associated with full ACRS
meetings to review an SER? We generally -- maximum is generally a
couple hours. Sometimes we squeeze it in in two and a half hours. Is
that enough?
DR. BONACA: To look at the closure, you mean?
DR. KRESS: To look at an SER.
DR. BONACA: You mean to the supplemental SER.
DR. KRESS: Yes.
DR. BONACA: Well, I wanted to add some words here that the
burden will fall on the Chairman to communicate. So there will be maybe
some interim meeting. I don't think that we should -- unless there is a
need, I don't think we should cycle the whole committee, but bringing
closure and then the Chairman could summarize for the full committee
some information before the full committee meeting takes place.
DR. KRESS: How many members do we have, subcommittee?
DR. BONACA: That's the whole thing. It's the majority of
the committee.
MR. BARTON: Dana is missing.
MR. DUDLEY: It's seven members.
DR. BONACA: Seven members.
DR. KRESS: We probably ought to expand that to the full
committee.
MR. BARTON: Just like we do with the new reactor designs.
Put it out and every member of the committee gets a piece.
DR. BONACA: I thought about it, too, because for the
license of new plants, I believe that that's a way to operate it, isn't
it?
DR. KRESS: A subcommittee of the whole or something.
DR. BONACA: I didn't have a proposal either, so I thought I
would just float it there.
DR. KRESS: I think that's something we can discuss.
DR. BONACA: I believe that particular -- I mean, we have to
find a way to be efficient enough in that process that we can do it with
two meetings.
DR. KRESS: On these focus items.
DR. BONACA: Yes.
DR. KRESS: Which is a good idea. Do you have in mind
taking specific members and say this is yours and from now on, on every
issue, so that they get more --
DR. BONACA: That's right. Yes. My sense is that that
would be the right way to do it. I realized after we wrote this that we
really had an issue list here, but we didn't have any owners. So I
think that we should assign some owners so that the issues don't get
dropped.
Now, it may result from application that you always end up
with the same issue anyway. For example, the guy who reviews scoping
issues is going to end up with the scoping issues.
DR. KRESS: Right.
DR. BONACA: But there are others that may -- you know, you
still want to have some people that are owning the issue.
DR. KRESS: Yes. I think that's an efficient way to do it.
DR. BONACA: Okay. I'll put some words in the back and we
will develop a process for that. At some point, I want to go back to
page two and item two. I agree, evaluation of the effectiveness of
license renewal process is not the right characterization, but I would
like to agree on the words here.
We're talking about the effectiveness of the demonstration.
DR. SHACK: Well, no, I really thought you were talking
about the effectiveness of the process here. I mean, the effectiveness
of the demonstration I thought was really an item one issue.
DR. BONACA: Evaluation of the -- you're right.
DR. SHACK: There is a question of whether that is in our
purview or not.
DR. KRESS: If we were looking to cut down on what we have
to do, that looks like an area that would be --
DR. SHACK: But it seems to me that the Commission seems to
ask us about that question.
DR. KRESS: I think that's something that the staff will
definitely have on their agenda. I don't know why -- I don't know if
they're much more efficient and effective in evaluating that sort of
thing than we are.
DR. SHACK: I really thought this was almost a somewhat
larger scope issue, for example, what risk information would do to the
whole process.
DR. KRESS: That may be a different subject.
DR. SHACK: It's effectiveness in kind of an upper case.
DR. KRESS: That one may be a better one to add in. My own
feeling is that's trying to close the barn door.
DR. SHACK: Yes. That's a --
DR. BONACA: When we wrote this, I had in mind, for example,
the scoping issue. The scoping issue could be the debate of what's the
licensing basis for this plant. The issue is --
DR. KRESS: That's exactly where you would probably have --
that's where you -- if you're going to do any risk-based part of this
whole thing, I think that's where it is, the scoping issues.
DR. BONACA: But to me, when I hear that they are going to
look at the functionality of the systems --
DR. KRESS: It's basically a risk --
DR. BONACA: That means that the effectiveness -- the
license renewal process for scoping is effective. So in that case,
these words would be acceptable, because we are performing an evaluation
that says, yes, they're effective or they're not effective.
DR. KRESS: I think there is a real issue of what functions
they include in that.
DR. BONACA: Of course.
DR. SHACK: I think they're constrained by legal
requirements there.
DR. BONACA: But it's broad enough. We're talking about --
DR. KRESS: How are they legally constrained there? By Part
54, you mean?
DR. SHACK: By the current licensing basis. Now, it's a
question of how you interpret the current licensing basis.
DR. KRESS: The current licensing basis is in almost
everything. You could lump almost everything in that.
DR. SHACK: I'm not sure that everybody would agree with
that.
DR. KRESS: But I don't think that's much of a limitation.
DR. SHACK: I think that's a considerable limitation.
MR. GRIMES: Our experience on Oconee is it's a limitation
most of the time. Some of the times, it's just total confusion. Let me
illustrate it by, we attempted to explore the licensing basis for Oconee
as it relates to spent fuel pool cooling and we ended up with that half
of the loaf that relates to the integrity of the pool boundary, because
the boundary is clearly relied upon in the licensing basis to perform a
function. It holds the water.
But the cooling function is not safety-related. It's not
described in the licensing basis as being relied upon. There is a pool
temperature limit that's not characterized as a safety limit. It's not
in the tech specs. That's my fault, too. We specifically said that
maintaining the spent fuel pool below 105 or 150 or whatever, that
that's not a safety function.
So we got the boundary, we didn't get the cooling loop, so
we settled -- we were constrained to that extent, that we thought it
would be appropriate that the cooling function be included. But we
couldn't get there.
Now, in hindsight, though, that seems to be a sexier issue
than perhaps it needed to be simply because of reflections on Millstone.
But we're going to run into those kinds of questions on scoping as we go
through and the statements of consideration for Part 54 says the
Commission concludes that the current licensing basis does not need to
be reconstituted to perform license renewal.
But I want to tell you, it would be a hell of a lot easier
if it was.
DR. KRESS: That would make your life a lot easier.
MR. GRIMES: Yes, it would. Otherwise, it's just fun.
DR. KRESS: It's too bad we didn't comment on that to the
Commission.
DR. SHACK: I mean, there is rulemaking somewhere up here
ahead and that's another battle.
DR. KRESS: You're going to change Part 54, are you?
MR. GRIMES: I will share, personally, I've been there three
times now. I was there in 1978, when the Commission said that we did
not need to reconstitute the design basis for the purpose of the impact
of new regulatory requirements. That's when we moved into the generic
issues process that made backfitting decisions.
Up until then, the rules that evolved in licensing basis
just sort of trailed on behind it. Then the Commission had to address
it again somewhere between '81 and --
DR. SHACK: Early '80s.
MR. GRIMES: In '81 to '84 somewhere, the Commission again
had an opportunity to require that the design basis be reconstituted and
they concluded, no, it's just a paper exercise.
The process manages the design basis and then with license
renewal, the Commission again was confronted with the question about do
you have to reconstitute the licensing basis and Mr. Riccio will
constantly point out that there is all this anecdotal evidence about how
we don't know what the licensing basis is, and he points dramatically to
the Millstone.
So we ride that fine line a lot.
DR. KRESS: You think there is an opportunity to do
something when we risk-inform all of Part 50, you think that would be --
MR. GRIMES: That was an opportunity because I remember that
this same issue came up when we were talking about the PRA quality and
completeness aspect and there was a question about to what extent do you
have a clear reflection of the licensing basis, the design basis within
your PRA, said how do you know that you've done that.
It was more a reliance on the practitioners going out and
checking to see whether or not the systems were actually configured and
operated properly than there was on the underlying design basis and
underlying engineering, which still is characterized by many as simply
the paperwork.
So we continue to struggle with that enigma about what is a
good knowledge base and I think most utilities have recognized that with
the growing -- with the aging workforce, that they're losing corporate
knowledge and that there is an advantage to taking the design basis
information and pulling it up and getting it in electronic and
retrievable form.
So a lot of that is going on, but not to the extent that
there is a systematic approach that the NRC could refer to so require an
upgrading of the design basis and underlying licensing basis.
DR. BONACA: I've got some discomfort from some things you
said before, about really the licensing basis of the plant. The fact is
that Oconee doesn't have main steam isolation valves, it doesn't have
main feedwater isolation valves. Yet, those are two essential functions
in certain events.
MR. GRIMES: For certain plants.
DR. BONACA: Certain plants. But since you rely on stop
valves in the plant and on governor valves on feedwater systems, you
want to include those, as they did, and, in fact, they took some events
that are not in their FSAR and evaluated those. I think the main
feedwater -- was it main feedwater?
MR. GRIMES: Actually, I thought that was one of the ones
that we questioned them on.
DR. BONACA: Well, but they did some, added a couple of
events. And the question we had, as an ACRS, was why not other events.
I mean, to the degree to which those events define possible
functionality for which you have to demonstrate that you will
effectively perform certain safety functions, and what limits the
process right now from doing -- from questioning and including those
components.
MR. GRIMES: And that's the legal question that we run into
in terms of -- we can explore any potential event for which there might
be an underlying safety function in the licensing basis, but when we get
down to a point where we ask about a system capability, and the example
that I used was loss of spent fuel pool cooling, if the licensing basis
does not require that that be an analyzed capability and otherwise have
some kind of regulatory control on that capability, then we can ask, but
if we get into a challenge, we're challenging the current licensing
basis.
DR. KRESS: Can't you challenge it on the basis of adequate
protection?
MR. GRIMES: Yes, but when we do --
DR. KRESS: It's not exactly the same.
MR. GRIMES: We can and should challenge it on the basis of
adequate protection, but then it ends up being an existing license
issue. Then we go into backfit space and that's what -- that's the --
from the NRC staff's perspective, we say, well, that's the chilling
effect. Not really, because whenever we challenge the licensing basis,
whether it's with respect to the scope of Part 54 of the adequate
protection standard, we have to rise to a level of justifiable need and
be able to defend it in either case.
So that ends up being a subtle distinction in terms of if we
find something that we think is just fundamentally wrong, the answer is
we fix it. But it ends up being something that you don't -- you don't
fix it in Part 54, you don't fix it in the renewed license.
MR. BARTON: You fix it in the current.
MR. GRIMES: Right.
DR. BONACA: But it makes it a struggle for you, and I
understand and that's okay.
MR. GRIMES: If this were easy, then they wouldn't be paying
us this much money.
DR. BONACA: But we, as a subcommittee, as the ACRS, we're
going to evaluate the adequacy of this process. I'm trying to, again,
look at what we do here as far as reviewing the process and maybe --
DR. KRESS: Adequacy from the standpoint of protecting
health and safety.
DR. BONACA: So maybe I could rephrase two as that and that
would -- because really, I mean, we certainly want to question these
kinds of issues. They really are the center of -- you may have a
component out there that is very important and you're not going to
monitor it, no, I don't believe that any licensee would be so
irresponsible at presenting their position, but if you have to negotiate
that kind of activity on every single item, you're going to have
possibly a lot of items which are not included and they should be
included.
If you have any additional comments on this draft --
MR. BARTON: The only question I've got, Mario, is you've
got down here, after the pilots, we might go into a two-step review.
The only question I've got there is do you want to limit it to after the
pilots or do you want to limit it after there is an application for each
different reactor design, or doesn't it matter?
Because you've got the CE and B&W. We haven't seen any
Westinghouse or GE at this point. Does it make any difference on
reactor design here or is it strictly the pilot versus everybody else
that comes down the pike? That's just a question.
DR. BONACA: That's a good comment.
MR. GRIMES: I'd like to offer, you should be careful about
the use of the terms, too, because Calvert Cliffs and Oconee we've
typically referred to in our official correspondence as the initial
applicants. We haven't --
MR. BARTON: As opposed to pilots.
MR. GRIMES: Yes. We don't have a formal pilot program.
MR. BARTON: That's true.
DR. UHRIG: We didn't use the word pilot, did we?
MR. BARTON: Yes, we do. We used it throughout this
document. We'd better fix that. We might want to look at each reactor
design and after that go to reduced review schedule.
DR. BONACA: That's a good point.
MR. SIEBER: It's based now on the issuance of a final
standard review plan, right? It should be adequate, because once you do
that, you fix the process.
MR. GRIMES: The only difference would be that we're hoping
to finish the standard review plan and get it out at about the same time
that Turkey Point would be coming in and they're the first Westinghouse.
MR. BARTON: The first Westinghouse unit. That's something
to think about, Mario.
DR. BONACA: Yes, but that's a good point. I mean, that was
the thought process, John, that I had saying once the SRP is in place,
most of the processes are going to be established, and there's going to
be -- probably the main comments we're going to have is when an
applicant proposes something different from the SRP and various issues
of adequacy and so on and so forth.
But certainly we want to look at the other designs, too.
So, okay, let me think about it and I will propose something there.
MR. SIEBER: I guess if you go back to page two and
evaluation of the effectiveness of the process, really what you're
trying to determine is whether the process is effective in ensuring the
goals of the protection of the public health and safety, identification
of all the aging mechanisms, as opposed to evaluating the efficiency.
DR. BONACA: No. In fact --
MR. SIEBER: So if you clean that up, then it becomes a
safety issue, which we should be involved in.
DR. BONACA: We changed the title to evaluation of the
adequacy of the license renewal process and below that we'll put the
words that say that we're evaluating whether the process is adequate to
provide adequate protection of the public.
MR. GRIMES: Excuse me. There might be some language that
you want to draw from the reactor arena strategic plan, because there
was some language that was put in there that speaks to the objective of
license renewal as it relates to maintaining plant safety, as
distinguished from the goal that speaks to effective, efficient and
realistic decision process.
And if you have any suggestions for metrics for any of those
performance goals, I'd be -- I'm ready, willing and able to take some
suggestions. I don't know whether to get my yardstick or my micrometer
out.
DR. BONACA: Okay. If you have any additional comments next
week, just bring them to us before -- even by Thursday and we will put
them inside this document. Again, we'll call it draft anyway until we
discuss it with the full ACRS meeting.
DR. SHACK: Again, that revisit to item two really turns
into an item three, doesn't it? It becomes a policy issue then.
I understood Jack's suggestion was almost is the current
rule sufficient and that clearly is policy.
MR. SIEBER: No, it's the process as by the requirements of
the rule. The Commission has issued the policy statement that says this
is what the rule is supposed to do and there is a process behind that
that ultimately ends up as the standard review plan and the
effectiveness of that is it says by the requirements of the rule.
So it's a mechanical kind of a thing as opposed to a policy
type thing.
DR. KRESS: I think it's too late to take that on as a
fourth issue.
DR. BONACA: Okay. We will put in some words here and then
see what you think.
One last item I'd like to touch on. These are just two
tentative slides that actually I hadn't seen them, but Noel and I talked
about the presentation to the Commissioners, the fact that we'd like to
keep it in two pages. These are not the actual slides, but these are
the thoughts. If this seems to be on the right track, then we're going
to work on this and develop a couple of slides that will convey these
thoughts.
DR. UHRIG: What do you mean greatest contribution will be
to the process?
DR. BONACA: It means that we expect our greatest
contribution will be to the process. What that means is that when we
look at individual applications, that we're not attempting to reproduce
the review of the staff. We won't even come close to their ability to
contribute there.
I think where we can contribute the most is in the
development of the process. We had some examples, like credit for
existing programs.
What about this bullet, beneficial changes to Part 54?
That's like a trap for a presenter.
DR. KRESS: In red letters.
DR. BONACA: I don't feel comfortable with that.
DR. KRESS: I think we ought to stay away from that one.
DR. BONACA: Yes. I think that's like a trap. Anyway, we
will use some of thoughts to generate a couple of slides and then --
DR. KRESS: I hope you've got something for bullet three.
That sounds like a real winner.
MR. BARTON: What was that, Tom?
DR. BONACA: Denial of application.
DR. KRESS: Bullet three, I hope he's got something in mind
there, because it's a real winner.
DR. BONACA: Any thoughts? Have you had a chance to discuss
this with Sam?
MR. DUDLEY: No, I haven't. This was just to stimulate
discussion.
DR. KRESS: I think it looks like a good outline.
MR. DUDLEY: And hopefully generate comments back, and it
would shorten the amount of time we spent with the full committee on the
same issues.
DR. BONACA: This, again, is another trap, because the
question comes can you give me an example and that's tough to do, after
having the whole staff review.
DR. KRESS: I would be a little tempted to go easy on bullet
three on the first page, also. I don't know if I'd mark it out all
together, but.
DR. BONACA: Well, I think we need to go back and develop a
couple of --
DR. KRESS: Clearly, if we thought the staff was doing a lousy job, we
would say something. But at this point in the game, that's not a very
likely thing to come down on. Clearly, they are doing a good job. We
can make that -- we already make that decision, so it's not much of a
bullet.
DR. BONACA: We'll put together a couple of slides and then
--
MR. BARTON: Do we have an SRM or as a part of charter, is
there something -- what gets us into this process to begin with? And do
those bullets line up with --
DR. KRESS: That's a good question.
MR. BARTON: -- what we're supposed to be doing for this
process?
DR. KRESS: Good question. I don't know. I think the SRM
just says we will review it.
MR. DUDLEY: It comes out of Part 54 itself, which states
that the staff will provide the ACRS with the final SER. Well, they
don't even say that, but with the report and that any ACRS report will
be included in the final license package.
DR. KRESS: I think that's about all it says.
MR. DUDLEY: That's about all it says. So that's --
MR. BARTON: That's about all we want to say, too. We're
responding to what's required in the rule.
MR. DUDLEY: The question to try to answer is how is the
ACRS going to do those two things.
MR. BARTON: Then you have a couple sub-bullets.
MR. SIEBER: And going with that, once you get through the
-- from the four-step process to the two-step process, the contribution
will not be to the process anymore. It will be to the quality of the
SER and the acceptability of the licensee's application.
MR. BARTON: That's a good point, Jack.
MR. SIEBER: So I'd be careful about that, too, because we
defined this two-step process or this two-stage process.
DR. BONACA: Okay.
MR. DUDLEY: Is that it?
DR. BONACA: Yes. I think we are done. We will clean up
the stuff and prepare a couple of overheads for review by the policy and
procedure next week and then I think we are done.
Any other comments from the members?
MR. BARTON: Not at this time.
DR. BONACA: If not, then this meeting is adjourned.
[Whereupon, at 12:03 p.m., the meeting was concluded.]
Page Last Reviewed/Updated Tuesday, July 12, 2016
Page Last Reviewed/Updated Tuesday, July 12, 2016