Plant License Renewal - September 23, 1999

                       UNITED STATES OF AMERICA
                             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.
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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.
         DR. BONACA:  The meeting is called to order again, and we
     have now a presentation of the staff activities on the pilot
         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
         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
         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
         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
         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
         DR. SHACK:  And you've agreed on that, the screening
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         DR. KRESS:  Of the process.
         DR. BONACA:  So here we're talking about evaluation of the
         MR. BARTON:  We probably want to narrow it to what Chris has
         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
         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
         DR. SHACK:  This is actually the first time I've seen this
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         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
         DR. KRESS:  Can't you challenge it on the basis of adequate
         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
         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
         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
         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
         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
         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
         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