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Plant License Renewal - November 18, 1999

                       UNITED STATES OF AMERICA
                        Conference Room 28-1
                        Two White Flint North
                        11545 Rockville Pike
                        Rockville, Maryland
                        Thursday, November 18, 1999
         The committee met, pursuant to notice, at 1:01 p.m.
         MARIO V. BONACA, Chairman
         DANA A. POWERS, ACRS Chairman
         THOMAS S. KRESS
         JOHN J. BARTON
         JOHN D. SIEBER
         ROBERT E. UHRIG
         ROBERT L. SEALE.                         P R O C E E D I N G S
                                                      [1:01 p.m.]
         DR. BONACA:  Okay; this meeting will now come to order. 
     This is a meeting of the ACRS Subcommittee on Plant License Renewal.  I
     am Mario Bonaca, the chairman of the subcommittee.  ACRS members in
     attendance are Bob Seale, George Apostolakis, Thomas Kress, Dana Powers,
     William Shack, Jack Sieber and Robert Uhrig.
         The purpose of this meeting is to review the resolution of
     the open and confirmatory items identified in the safety evaluation
     report related to the license renewal of Calvert Cliffs Nuclear Power
     Plants I and II and the status for activities associated with the
     standardization of the license renewal process.  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 on October 25, 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.  We will now proceed
     with the meeting, and I call upon Mr. Christopher Grimes to begin.
         MR. GRIMES:  Thank you, Dr. Bonaca.
         I would like to start off by explaining that the purpose of
     this meeting is for the staff to describe how we address the resolution
     of the open and confirmatory items in the Calvert Cliffs license renewal
     safety evaluation report.  As you know, one of those open items, 3.0-1,
     related to the treatment of FSAR changes to incorporate the committees
     from BG&E to manage aging effects.  We have been tracking that issue
         BG&E submitted by letter dated November 12 a proposed list
     which was one of the four options that we described to BG&E at the
     management meeting in August.  The staff is in the process of verifying
     that that list captures the commitments that were relied upon by the
     staff to establish reasonable assurance that aging effects will be
     adequately managed and that we would incorporate those into the safety
     evaluation and then reference them in a license condition.
         We have scheduled a meeting with Baltimore Gas and Electric
     on Monday, November 22 to continue a dialogue on how the mechanics of
     that process would work and also to discuss the results of our initial
     review of the list, but it shouldn't affect the explanation about how
     we've addressed the resolution of open and confirmatory items otherwise,
     and we still need to work out some of the details about the construction
     of a renewed license and the preparation of a commission paper that
     would incorporate the results of all of the renewal activities.
         For the balance of our presentation, we're going to have the
     staff explain the balance of the open and confirmatory items and how
     they've been addressed in the final safety evaluation, which was issued
     -- what day is this? -- the 18th, two days ago.  My, how time flies.
         But as requested by the ACRS, we are also prepared today to
     discuss a number of other generic renewal activities and how we're
     proceeding with those issues, and we're prepared to discuss a comparison
     of the treatment of particular issues of interest between Calvert Cliffs
     and Oconee; in particular, cast austenitic stainless steel fatigue and
     one-time inspections, and I would ask that as a plan for the outcome of
     this meeting, you also think about what particular aspects of these
     presentations you would like us to prepare for the full committee
     meeting on December 2.
         And unless there are any general questions about our
     objective today, I'll turn it over to David Solorio, the project
         DR. BONACA:  Just one question I have which I may raise
     later on, but as you know, one interest that I have expressed was in the
     process that the staff will use to participate in changes to those
     commitments that you received as a supplemental ACR, and we can discuss
     it later on, probably when we come to the one-time inspections.
         MR. GRIMES:  Well, as a prelude to that, I'll mention that
     it was our vision that the age-related degradation inspections, like the
     rest of the commitments that BG&E has offered in this application are
     intended to be incorporated into the final safety analysis report, and
     we would expect that for the age-related degradation inspections, there
     is also a feature in the proposed license condition that provides a
     mechanism for delays in the commitments; that is, a time factor that is
     not presently addressed by 50.59.  But otherwise, we would expect that
     50.59 processes would control changes to the commitments.
         It's conceivable that in the future, some of the one-time
     inspections proposed for ARDI, the acronym for age-related degradation
     inspections, might change.  If the substance changes, then 50.59 would
     evaluate whether that substance change warrants a license amendment.  If
     there are delays, then, the license condition provides that any delays
     in specific schedule commitments would also be subject to a license
     amendment, so that's the staff involvement that we anticipated in
     changes to these commitments.
         DR. BONACA:  And we can discuss it.  One of the reasons why
     I raised the question before is because I look for the -- and I'm not
     sure that the recently-developed guidance on 10 CFR 50.59 contains all
     of the elements that you need to perform evaluation of commitments in
     the license renewal area.  It may contain them all, but I'm not so
     comfortable or confident, and I wonder if you are going to perform a
     review of that guidance and see if it accommodates all of the possible
     situations that you may face in -- when changes are made to the
         MR. GRIMES:  I understand the issue, and we are going to put
     -- we are going to continue a dialogue with the industry in terms of
     whether or not the 57.1(e) guidance and the 50.59 guidance --
         DR. BONACA:  Yes.
         MR. GRIMES:  -- are sufficient for the purpose of aging
     management programs.
         DR. BONACA:  Yes.
         MR. GRIMES:  But very simplistically, we view these
     commitments to be proposed changes in procedures and practices that are
     comparable to maintenance activities for active components but
     specifically designed for passive components.
         DR. BONACA:  Yes.
         MR. GRIMES:  So that we don't view the resolution of that
     guidance as being critical to proceeding with license renewal reviews.
         DR. BONACA:  And I agree with that, but I just -- I think
     that realizing that it took 40 years to get a guidance in place for
     50.59 for the standards for the FSAR, I mean, I think it may be
     worthwhile to spend a bit of time just reviewing to make sure that all
     that you need to participate meaningfully in changes to the possible
     commitments for license renewal is in place.  I mean, just a thought.
         With that, I would like to proceed with the presentation.
         MR. SOLORIO:  Good morning or afternoon.  My name is Dave
     Solorio, and I just want to inform you all of kind of how we're going to
     run this.  I'm going to ask different reviewers from different branches
     to come up as we're going through to sit back over here on the side so
     that if any specific questions come up beyond my general knowledge,
     they're right here to be able to answer them for you.  So please forgive
     the moving around that might occur.
         So, with that, I'll get started.  Today, I'm going to be
     making the presentation throughout, but I'm going to have
     representatives from the Division of Engineering, Safety Systems
     Analysis, my division, and Inspection Program Management.  These are the
     divisions who worked with us here at the NRC to review this license
     application, renewal application, and to come up with the safety
     evaluation which we issued on the 16th.
         The culmination of this safety evaluation report has been
     the result of a significant amount of staff and applicant resources. 
     It's been a lot of hard work to get this thing done, and we appreciate
     you all trying to accommodate our schedule of trying to get your review. 
     Back on November 3, we provided you all with a summary report of the
     closure of the open and confirmatory items.  That was predecisional
     information at that time because we hadn't completed all of the
     management and legal reviews.  We obviously have, since we've issued the
     SER now, but I need to ask you that that's still -- there were some
     minor changes, so that represents predecisional information that you
     need to keep, you know, to yourselves and not distribute.
         But there was really no significant changes, so the content
     of the technical information that -- what you have there is essentially
     what is in the published SER, which I'm going to get some copies for you
     all as soon as I get done burning them at the copy center, so you'll
     have them probably when you get back to where you are going.  And again,
     we issued two days ago the safety evaluation report.
         I'm going to skip the next slide.  It's just a summary of
     the different divisions that are going to be speaking and kind of the
     order.  I tore these apart, and they stuck back together again.  This is
     a little bit out of order, and the reason I'm putting this up first is
     because it kind of sets the prelude for a lot of the other things we'll
     be talking about.  It's a chapter tree type item, and you, Dr. Bonaca
     and Chris Grimes were just talking about that.  This was an open item we
     had.  We wanted the licensee to commit to selective elements of their
     Appendix B program to be applicable to the non-safety related components
     that they were determining were in the scope of an aging management
     review.  We asked for that commitment, and they agreed to either put it
     in their UFSAR or their site corrective action document, and because of
     that, we were able to close that item.
         DR. APOSTOLAKIS:  Now, what do these non-safety related
     components do?
         MR. SOLORIO:  Well, remember there are three reasons why --
     or there are two reasons why you can get non-safety related components
     subject to an AMR:  if their failure could affect a safety-related
     component or if they are perhaps part of one of the things that's
     necessary to meet one of the regulated events under criterion
     50.4.4(a)(3), so it could be -- it's an example of what would be perhaps
     some feed water components.  They might determine within the scope of an
     aging management review, so they're going to -- and they committed in
     their license renewal application to do this, to apply these specific
     Appendix B requirements to those components.
         DR. UHRIG:  Well, the components specifically mentioned here
     are those subject to aging management review.
         MR. SOLORIO:  Yes.
         DR. UHRIG:  Isn't that the primary criterion?
         MR. SOLORIO:  That's the primary criterion; I'm sorry; I
     didn't make it clear.
         DR. APOSTOLAKIS:  Why aren't they, then, safety-related if
     their failure can affect the function of a safety-related SSC?  Why are
     they not safety-related?
         MR. SOLORIO:  Well, under current operating space, you can
     call it, there are safety-related and there are non-safety related. 
     We're talking about managing aging effects for, in this case, non-safety
     related components, and they're managing them.  The rule doesn't have us
     reclassify stuff as safety-related because it could affect a
     safety-related component.  It just asks for us to make sure that they're
     managing it, and that's what they've done through their -- you know,
     they've explained to us that scope of stuff that they're going to manage
     that's not safety-related.
         DR. KRESS:  Part of the leftover from the way you've always
     done things.
         DR. APOSTOLAKIS:  I know, but it makes sense in some things,
     and it doesn't make sense in others.
         MR. GRIMES:  Dr. Apostolakis, the construction of the
     license renewal review recognizes that there are non-safety related
     structures and components that are relied upon in the regulatory regime. 
     I think a good example is fire protection or station blackout.  Those
     are two of the regulated event.  And to the extent that they're
     non-safety related, but we still rely on them to perform a safety
     function.  In this case, fire protection and station blackout are
     related to risk insights.
         DR. APOSTOLAKIS:  Yes, I'm not questioning why you're doing
     it.  I'm just questioning why they are declared as non-safety related in
     the current regulations.  And the next thing I'm curious about is we've
     heard that the South Texas project has identified 366 non-safety related
     components that are risk significant, and I'm curious now how many of
     those are part of the same ones that you are reviewing.  But that's not
     for you to answer.
         MR. SOLORIO:  Thank you.
         DR. APOSTOLAKIS:  That would be what?  You are very welcome.
         DR. BONACA:  Just the question I have regarding the
     resolution of incorporating the non-safety related components into
     Appendix B, is it going to be a general approach to how this issue is
     going to be dealt with with NEI, or has it been discussed or --
         MR. SOLORIO:  Well, I want to clarify one thing.  We're not
     asking them for a commitment for all of the criteria for the Appendix B
     program but three specific ones:  corrective actions, administrative
     controls and confirmatory processes.
         MR. GRIMES:  And the answer to the broader, generic issue is
     yes, I would expect to engage NEI as one of the lessons learned to
     develop guidance that could be incorporated either into the application
     guidance or into the review guidance.
         DR. APOSTOLAKIS:  Okay.
         MR. SOLORIO:  Now, we're moving into chapter 2.  It dealt
     with scoping, and we had a number of open items and confirmatory items,
     the first being the station blackout building, diesel building.  We were
     -- during our review, we had determined that there was a potential based
     on what we read in their UFSAR that there was an implication that this
     building could affect the diesel generator building, so we wanted to --
     we asked the applicant, you know, why isn't it in the scope of license
     renewal?  We've worked with them on this quite a bit, and we also issued
     a scoping position in order to help get closer to a resolution on this
     item, and based on our interactions with the applicant, BG&E, they
     agreed that this part of the building, the part that could affect this
     diesel generator building, should be subject to an AMR.
         They should be within scope and therefore subject to an AMR,
     and so, they've scoped it in, and actually, they've given us information
     related to the aging management review that we've also incorporated into
     the final SER.
         DR. APOSTOLAKIS:  Isn't this an example of what you've just
         MR. SOLORIO:  Non-safety related?
         DR. APOSTOLAKIS:  DIPM.  Is that a safety-related building?
         MR. SOLORIO:  It is, it is a safety-related building.
         MR. ELLIOT:  It's an example of a non-safety related.
         DR. APOSTOLAKIS:  Yes, so, it's an example of what we were
     just discussing; okay.
         MR. SOLORIO:  The other next open item here is a non-safety
     related service water turbine building header.  There was a part of the
     service water piping that the applicant was not -- had not considered as
     scoping within the license renewal scope, and we asked some questions,
     and we had a lot of good interactions, and they determined that it was
     -- they agreed with us that it should be, and it was already very easy
     for them to incorporate the aging management review, because they were
     already looking to other parts of the system.  They just added it.
         And the next item there is the -- had to do with some spray
     nozzles and some charcoal filter beds, and we had questions whether or
     not those nozzles should be within the scope of license renewal.  It was
     based on an understanding that we had had related to more or less other
     plants, where there might be an implication they should have been, but
     in this case, BG&E explained to us that they didn't perform any design
     basis function for putting out a fire in these charcoal beds, so we
     determined that they were not within the scope of license renewal based
     on that additional information that BG&E provided us.
         And then, there was another non-safety related HVAC ducting
     area that was providing some air to some of the reactor cavity areas,
     and we initially thought perhaps that should be within the scope of
     license renewal.  However, the applicant explained to us that it wasn't
     relied upon for meeting any design basis, and this is also tied into a
     scoping position that we issued on how to deal with considering things
     that aren't non-safety related and how far do you go before you say
     that's enough in terms of what are the effects on, you know, how far do
     you cascade down before you say look, we need to draw the line and say
     that's probably not a problem with that and let's stop.
         DR. APOSTOLAKIS:  So how far down do you go?
         MR. SOLORIO:  Well, it really is kind of a case-by-case
     situation.  You've got to look at what the design of the -- you know,
     what's it serving?  Is it providing normal operating error, and during
     an accident, it's not needed, so therefore, that's not -- you don't need
     to go that far; it's not needed for the accident.
         I didn't answer your question.
         DR. APOSTOLAKIS:  No.
         MR. GRIMES:  Let me try.  In this particular question, it
     was whether or not having ventilation to maintain the environment is
     necessary in order to ensure that the equipment remains qualifying.  We
     faced a similar issue in technical specification, and we determined that
     there is sufficient basis for environmental qualification that we do not
     have to establish regulatory controls on how the environment is
     maintained.  Plants can deal with environmental changes to determine
     what their impact is on the qualification of particular equipment, as in
     a degraded or a nonconforming condition in the event that they lose
     ventilation, or they lose environmental controls related to high
     humidity, things like that.
         So in this case, we concluded that there was no need to
     cascade to the ventilation system in order to ensure that equipment's EQ
     is maintained.
         DR. BONACA:  In this specific case, it doesn't mean that in
     other cases, you may not find it in the cascading, right?  If the
     function really was affected.
         MR. GRIMES:  It depends on the way in which the function
     will be affected and the time and the kind of response that we would
     expect.  You know, for supporting systems, like cooling water for diesel
     generators, you know, it's got to be there when you ask it to be there. 
     It is essentially a case-by-case review in terms of how far you cascade. 
     For our purpose, it was sufficient and simple to simply look back to the
     licensing base and determine whether or not those functions were relied
     upon in order to demonstrate the licensing basis.
         DR. APOSTOLAKIS:  I guess there is a lot of room for
     interpretation there when you say relied upon.
         MR. GRIMES:  That's really at the heart of the cascading
         DR. APOSTOLAKIS:  Right.
         MR. GRIMES:  What does relied upon mean?
         DR. APOSTOLAKIS:  Exactly.
         DR. SEALE:  There is a problem that recurs when you start
     examining any fixed array of topics to see whether or not you meet
     certain criteria, and that is that you always wonder and indeed suspect
     that you really aren't complete when you do the first run-through, and I
     guess from what you guys said, that's sort of the way it worked out,
     that the applicant submitted a list, and you suggested maybe one or two
     or three other things that ought to be added to the list and negotiated,
     and you got the answer or you got an answer.
         But it's not clear that that is, in fact, the complete list. 
     I mean, it may well be that there is another item or two that should
     have been added on, and you may find those as you go through and look at
     subsequent applications from other people.  Is there a vehicle by which
     you can remedy this particular situation without getting egg all over
     your face?
         MR. SOLORIO:  I guess my first answer would be we also have
     an inspection program.  We've made three inspections, or we're going to
     make the third one, but we've made two at Calvert Cliffs and two at
     Oconee.  We're getting ready to do a third one at Calvert Cliffs.  But
     it's my understanding also that the region is going to revise their
     inspection program to, on a continuing basis, kind of factor in the
     license renewal aspects into their core activities.  So that's another
     look-see that we will have.
         DR. BONACA:  One good example of what Professor Seale brings
     up is the alternative stainless steel and how, at the beginning in the
     first pass, it was not addressed in the context of Calvert Cliffs and
     then was picked up for Oconee and now also was raised for Calvert
     Cliffs.  Now, there may be issues of this nature that will come up, and
     so, the issue that is being raised that I think is significant is how do
     you go back and capture these at a later time?
         MR. GRIMES:  I've been advised by counsel that there is a
     provision in the regulation that says that there is an obligation on the
     utility to maintain the plant consistent with the evaluation.  If they
     discover later that they should have been something that was subject to
     an aging management review or if they modify the plant design in such a
     way as to now change the nature of what should be subject to an aging
     management review, they have an obligation to fix it, and, of course, if
     we discover that we've made a mistake, there are means for us to go back
     and correct our mistakes or to decide on how to back-fit any license
     when there is sufficient cause.
         DR. SEALE:  So there are provisions to do that, and you
     don't have to stand around arguing about whether or not you have the
     power to do it.  You can.
         MR. GRIMES:  That is correct.
         DR. SEALE:  Okay; that's fine.
         DR. BONACA:  Okay.
         MR. SOLORIO:  And the other thing I want to mention here is
     -- I didn't mention it when I started out.  What I'd like to do is kind
     of from each group, give some top issues, like I just went over some top
     issues for the scoping area.  These are a couple more issues, and this
     list is real short, so I can go over this, but the lists are going to
     get longer in some of the other branches; you know, we'll have some top
     issues, then, I'll put up a list like this, and I guess I would ask you
     all if you have any other burning desires to talk about the specifics of
     the longer list, you can ask, and then, we can try to field that.
         In this case, electrical commodities, there was a question
     about a table in chapter 6.2 of the LRA pointing to different locations
     of the LRA for incorporating some of the components in those other
     systems, and there was confusion, and the staff asked, and the applicant
     clarified the confusion for us.  There were some few pointers that
     needed to be tied up.
         The last item deals with the solenoid valves, and we were
     asking in the safety injection system, why weren't they within scope,
     and the applicant clarified for us that they weren't relied upon for
     process flow; they were relied upon for an error system that was a
     non-safety related system which whose failure did not impact the
     safety-related function or other systems, so it didn't affect it; it
     wouldn't be an affect on the SI system, because the valves that it was
     working with were in the fail-safe type valves.
         Okay; now, I'm going to ask for EMCB people who are here
     today to come up here and sit over here in case there are any more
     specific questions that you can quickly get to a mike.  Barry, Allen;
     I'm going to -- yes, I'm going to have them walk over to a mike or
     something.  Can I put one of these away so they can just pass it up and
         COURT REPORTER:  It doesn't amplify.
         MR. SOLORIO:  Okay; guys, I'll hand you this if you need to
     talk.  Just make sure you talk loud enough so everyone else can hear.
         MR. SOLORIO:  Some of the more significant items we dealt
     with for the materials area had to do with casts and small bore piping. 
     Initially, we had done a lot of work with the applicant on this one. 
     Prior to issuing the SER, we even went to the site to talk a lot about
     how to deal with this.  In issuing the final safety evaluation, we just
     needed to work out some more details with the applicant agree what kind
     of once they determined what was going to meet the screening criteria,
     you know, what was the next step after that?  What would be the approach
     for evaluating those components that met the screening criteria?  And
     with respect to small bore piping -- sure.
         DR. SHACK:  You have a stress screening when it's subject to
     thermal and neutron approval and if it's going to allow -- the stress is
     just going to be subject to thermal.  That's the rationale.
         MR. SOLORIO:  First, state your name.
         MR. HISER:  This is Allen Hiser.  I'm with NRR.  Actually,
     that was not something that ever came up in our discussions with them. 
     I think the cast components that are in the internals will have
     significant -- well, they'll have significant fluence, so they probably
     will not screen out into that sort of a condition.
         MR. ELLIOT:  This is Barry Elliot.  I think the piping
     material --
         DR. SHACK:  Is it going to screen out by stress?
         MR. ELLIOT:  No, I was thinking that it's valve bodies and
     pump casings which might.  You know, it may well -- internals, yes, it
     probably will stress just like anything else.
         DR. SHACK:  That's why they went down that path.  They
     figured that internals have very low stresses, and they could buy
     something from that.  They didn't think they could buy anything from
     doing that for the piping.  We allow them, though, on the pump casings
     to use code case 481, which gives you a fractural mechanics evaluation
     to eliminate the inspections.
         MR. SOLORIO:  The next item on this slide -- just go ahead
     and hold onto that, would you?  The next item on this slide, small bore
     piping, we had initially asked some questions on this part in the draft
     or the SER with open items, and the remaining questions we had in trying
     to close this issue out were that because of the potential for cracking,
     we thought that a one-time inspection wouldn't be appropriate.  We had a
     lot of interactions with the licensee on this one, and eventually, we
     were able to understand each other, and they agreed that it would be
     something they could do a one-time inspection for selected piping,
     small-bore piping, and we were able to close this item.
         DR. BONACA:  Okay; now, I have a couple of questions.  First
     of all, so, you have agreed to have a one-time inspection, and you have
     agreed to that for a number of systems outside of the small bore piping;
     for example, the external components of the feed water system and CVCS
     system and then SRWS, okay, a number of component systems.
         MR. SOLORIO:  Yes, sir.
         DR. BONACA:  And now, again, if I understand it, the
     presumption is you have accepted one-time inspection because this
     degradation mechanism or the effects of it are not expected to happen. 
     Therefore, you're looking at it once to confirm it, right?
         MR. GRIMES:  We've accepted the concept of one-time
     inspections in a process way to confirm or deny whether or not there is
     an effect that has risen to a level -- not that it won't happen, but has
     it happened to an extent that it needs to be managed, and we're relying
     on the process, which includes an Appendix B review of the results and a
     determination of whether or not the results warrant some further action
     to preclude a condition from occurring.
         DR. BONACA:  Yes; but I've seen the words not plausible, and
     I believe that's the basis for -- I mean, you go, and you accept
     one-time inspection because you don't believe that the effects are going
     to be either present or significant.
         MR. GRIMES:  Right.
         DR. BONACA:  Now, you may be disappointed by their
     inspection, okay, at that time, and if I understand it, you do have a
     process by which, then, should you find that the effects are
     significant, then, you would go and allow for additional inspections or
     a full new program.  Now, this would be deemed by the applicant?  I
     mean, who would determine that program at that time?
         MR. GRIMES:  The applicant makes the initial determination
     on any findings associated with inspection activities.  We perform
     inspections to monitor how those processes work.
         DR. BONACA:  Okay.
         MR. GRIMES:  Whenever our inspection activities or our event
     evaluations identify conditions that we believe warrant some action,
     regardless of whether or not the utility has taken an action or not, we
     have a mechanism in order to pursue that and develop generic safety
     issues or to develop bulletins or orders or whatever it is that we need
     to do.
         DR. BONACA:  And again, as you said before, you can exercise
     50.59, or the licensee would exercise that?
         MR. GRIMES:  The licensee would exercise 50.59 to make
     changes to their procedures and their programs and to -- and if that
     change rises to a level that warrants a license amendment under the
     criterion 50.59, then, they have to submit a license amendment.
         DR. BONACA:  But you will have access to this information as
     the inspections take place.
         MR. GRIMES:  That is correct.
         DR. BONACA:  Because I think that for license renewal, it
     seems to me that the collation of information, dissemination of
     information to the industry is going to be a key issue.  So you want to
     have a vehicle there that is fully open to learning and disseminating
         MR. GRIMES:  You have to be very careful there, because we
     also struggle under a requirement that says that reporting burdens by
     licensees have to be justified because we do something with the
     particular reports.  So, and we also have a new oversight process that
     says that we have targets that we -- targets of opportunity that we use
     in order to perform our inspections.
         So we rely on the process to tell us about the results of
     these activities when they rise to a level of significance, and we'll
     also have inspection activities that are going to go out and look for
     experience and pursue this experience and try to develop a feedback
     mechanism, but like the issues that have been raised with equipment
     reliability data, you know, there is still a struggle that we go through
     there in terms of whether or not there is a means to report and collate
     and trend and that sort of thing.
         DR. BONACA:  Now, in some cases, it seems to me that
     one-time inspection were proposed because of the locations which were
     not very easily accessible or some of that, and you did not accept that
     in most cases as a basis for just going with one time inspection.  For
     example, I noticed that you asked the certain components of the spent
     fuel pool cooling system go into the BACI program, which is the boron,
         So, what I'm trying to understand is that this criterion of
     accessibility is not the basis for one-time inspection ever, is it?
         MR. GRIMES:  No; we rely on a process that says that they
     find results from accessible inspections, and then, they have to
     evaluate the implications for unaccessible components that could be
     similarly affected.  So there, again, we're relying on a process to
     perform an evaluation to determine whether or not buried components or
     embedded components are implicated by the results of inspection
         DR. BONACA:  Okay.
         MR. GRIMES:  The one-time inspections are to verify the lack
     of something that needs to be managed.
         DR. BONACA:  Okay; and I agree with that philosophy.
         MR. GRIMES:  Feeling all that Stephanie is under, because
     we're going to go into some more detail on one-time inspections.
         DR. BONACA:  Just I had one more question, and that's just
     for my education.  I'm not a mechanical engineer.  The question that I
     have is that there is a lot of reliance throughout the application on
     volumetric inspections, okay, ISI for ASME Section 11, and, of course,
     there is the periodicity attached to that, which is 10 years.  Is the
     periodicity in any way tied to the original license of these plants,
     which was 40 years, or would you expect that, you know, a volumetric
     inspection every 10 years would be good as a period of time,
     irrespective of the aging of the plant?
         So if you go to 200 years, I'm not proposing they will do
     that.  Would it still be that you think that a 10-year interval is
     adequate?  I don't know; I mean --
         MR. GRIMES:  Yes; I'll take an initial shot, and then, I'll
     ask Keith to comment.
         DR. BONACA:  Okay.
         MR. GRIMES:  The evaluation basis reflects back on how --
     in-service inspections and how Section 11 of the ASME code, how it has
     performed in terms of finding and fixing things.  You're correct in that
     ASME code originally set up 10-year cycles with an anticipation that
     everything would get inspected during the life of a plant, and so, there
     is a loose relationship there, but I would also point out that through
     some other mysterious way, the international community has decided that
     a 10-year cycle is appropriate for periodic safety review, so there is
     something mystically magic about 10 years seems to be a good cycle
     number for inspections.
         DR. APOSTOLAKIS:  That's not surprising, though.  We're
     talking about non-risk informed regulations.  They are mystic and
         MR. WICHMAN:  Keith Wichman, NRR.  There's nothing
     particularly magic about that extra 20 years, okay?  And in our review,
     it really hasn't been established that there is a need for reducing that
     10-year interval, okay?  There are supplementary inspections like you
     hear today, like the ARDIs and other things that seem to take care of
     the questionable areas, okay?  But we have not established a need for
     reducing that inspection interval.
         DR. BONACA:  I just asked the question because I didn't know
     exactly where the 10 years came from, and that's true that we have no
     experience that would suggest that you have to step up that interval,
     but, you know, we are learning things; for example, I know about this
     environmentally-assisted fatigue issue that we'll be discussing later on
     that shows that things change between 40 years and 60 years of life, and
     that's why I asked the question.  But you feel that you have sufficient
     additional inspections with the ARDI to justify to stay simply with the
     volumetric inspection of the Section 11 of the ASME?
         MR. WICHMAN:  Yes.
         DR. BONACA:  Okay; why don't we proceed?  Go ahead.
         MR. SOLORIO:  Oh; do I need that mike here?
         MR. SOLORIO:  Another area that we were -- spent a lot of
     time dealing or discussing an issue with BG&E was in the reactor vessel
     head closure seal leakage detection line.  Initially, more probably
     because of not having a complete understanding of the system
     configuration, we were looking at asking the applicant to propose an
     aging management program, but we determined that if they took credit for
     -- after further discussion, we determined if they took credit for their
     existing walkdowns to the extent possible and that that would probably
     be an appropriate way to manage this aging of this line, because that's
     how they had found a problem in the past and also the -- as a result of
     the past action, they started blowing down the line to keep the
     contaminants out of there that were leading to a corrosive environment,
     and there was also an orifice to limit flow should the line break for a
     reason that, you know, we couldn't foresee.  We figured that that was an
     appropriate way to manage that line, so we closed out that item.
         And the next slide is what I meant earlier when I talked
     about how -- if I try to go through all of these, I could probably not
     get much further than a couple more slides today, so since I have the
     people from the branch also here, these were all EMCB-related items, and
     if there were any particular ones that you were interested in, you could
     let us try to answer some questions on these.
         DR. BONACA:  We've all reviewed the package, and does any
     member have questions?
         SPEAKER:  Calvert Cliffs was going to replace their steam
     generator.  When is that going to happen?
         MS. COFFIN:  2001, 2003.  Stephanie Coffin, NRR; 2001 and
     2003, I think.  Soon.
         DR. SHACK:  Then, all their egg crates will be stainless
     steel by that time, right?
         MS. COFFIN:  That is right.
         DR. BONACA:  Okay; it was a point.  It wasn't clear in the
     -- okay.
         DR. POWERS:  I guess I was fascinated by the forecasted
     corrosion and especially the boric acid up so high if you go to extended
     -- the fuel production, is that considered when you think about the
     aging of these plants?
         MR. SOLORIO:  I'm going to need you to ask that question
     again:  standard burnup of the boron control rods?
         DR. POWERS:  The amount of boric acid you need to have for
     reactivity control for high burnup fuel was high.  It's how much boric
     acid you can get in.
         DR. SIEBER:  Well, when you use very high burnup fuels,
     don't you put in burnable poisons that are not boric acid?
         DR. POWERS:  We're taking the boric acid right up there, and
     they take these so much; you get absorption in the upper part of the
     fuel pushing in the stem.  Interesting things happen.
         SPEAKER:  Now, how many tons of boric acid crystals are you
     going to deposit once you have the leak come in?
         DR. SHACK:  You evaporate everything anyway once you have
     the leak, and so, I mean, it's a highly concentrated boric acid now no
     matter what you're putting in the reactor coolant system.  It's really
     the concentration you get to by leaking it out and boiling it off.  And
     you get to the same concentration in either case.
         MS. COFFIN:  It might just happen a little sooner.
         DR. SHACK:  Yes.
         MS. COFFIN:  I mean, you're still doing the walkdowns every
     refueling outage, so, I mean, the time at which you're starting to
     corrode your carbon surfaces might still happen, you know, a minute --
     it's not very easy to quantify.
         DR. POWERS:  It's your boric acid paste that's the corroding
         DR. SHACK:  Well, it might affect how many pounds of boric
     acid you see on the walkdown.  It might make it easier.
         MS. COFFIN:  It might help.
         MR. DAVIS:  Jim Davis.  Westinghouse did an analysis on that
     for the vessel head penetrations, and they found that you could have a
     gallon a minute for 8 years and still not go past your design margins on
     the head, and we concluded that they would find 450,000 pounds of boric
     acid crystals.
         DR. POWERS:  It depends on whether they did it by entering
     the fracture.
         DR. SEALE:  We might have a waste disposal problem then.
         MR. GRIMES:  We just don't want to leave the impression --
     we are not encouraging high burnup fuels so aging effects will
     accelerate.  It's not our intent.
         DR. POWERS:  I was asking the other question around.  In
     thinking about pure aging inspections, did the evolution toward higher
     burnup fuels have some impact on your thinking?
         MR. GRIMES:  I don't really think so.  I don't recall the
     concerns.  Is there anyone on the staff who knows whether or not high
     burnup fuel ever came up in the course of a discussion about the aging
     management programs?
         [No response.]
         MR. GRIMES:  I don't recall that it ever came up during our
         DR. POWERS:  At plant levels, there have been some
     interesting things happen with the reactor internals because of a high
     burnup fuel:  control rod sticking as well as this flux shifting, things
     like that.
         MR. GRIMES:  I'll go back and consult on what kinds of
     considerations high burnup fuel might have on the evaluation criteria
         DR. POWERS:  You might just ask Margaret Chatterly.  She has
     her finger on that pulse very closely, and she could certainly go
     through the things that they've thought about, and I guess the areas
     that you're going to be interested in, they're going to do anything in
     the management of the high burnup fuel that would change fluences on the
     vessel, I presume that the control rod drive mechanisms, things like
     that, don't fall under your scope of work.
         MR. GRIMES:  Not to the extent that the concerns about
     things like fuel boiling and sticking at control rods, those sorts of
     things are expected to be manifest in other programs, not in aging
         DR. POWERS:  Presumably, they would manifest themselves
     during normal operations.
         MR. GRIMES:  That is correct.
         DR. POWERS:  And then just the normal testing.  So you're
     most interested on is the fuel management scheme going to change any of
     the fluences to the vessels, especially in those plants where you don't
     have a lot of material that you can use for monitoring.
         MR. ELLIOT:  We do that.  If they change the fuel management
     in the fuel, they change their fluence, they evaluate the fluence, give
     it to us, and we review it.  That is a continuous process if the fuel
     management changes.  If they go to a higher rated, you know, power
     ratings, they have to come in here and tell us what the impact is of the
     higher power ratings on the neutron fluence are received by the vessel
     and the impact on the vessel.  We do this all the time, and we did it in
     this case in the sense that they project at the end of 60 years what
     fuel management they're going to have, and from that fuel management,
     they determine the neutron fluence.
         If they change that fuel management on the next 30 or 40
     years, whatever that is, then, they would be required to tell us how
     that impacted their previous analysis.  It's all built into the process.
         MR. GRIMES:  But to the extent that you've raised the
     question in terms of whether or not there are some subtle implications
     for aging management programs beyond the ones that we obviously
     addressed in terms of the vessel materials and internals properties and
     those things, we'll go back and look at that.
         DR. SEALE:  It's clear to them that any changes like that
     will be assessed, and clearly, they must have evaluated what they would
     expect any change or how any changes they might make down the road with
     respect to operational schemes, extended burnup fuels and so forth, how
     they would influence the credibility of the license renewal process that
     they've already gone through.  It's kind of like playing in the middle
     of the freeway if you haven't done that.
         DR. POWERS:  Well, it's also true that unless the plants
     actually experience some of these things through fairly subtle events.
         DR. SEALE:  Yes.
         DR. POWERS:  And anticipating them might not really be
         DR. SEALE:  Yes, but clearly, you know, if you're going to
     change your fuel burnup scheme, you probably have thought about what
     that means.  Yes.
         DR. BONACA:  Okay; let's move on to the other confirmatory
         MR. SOLORIO:  Yes; these are confirmatory items, and for the
     most part, you know, we understand -- when we wrote these down, it was
     pretty clear to both sides that what we knew what to do, it was a matter
     of just getting a commitment from BG&E to agree to basically that most
     of these are just incorporating additional components into existing
     programs, the first one, modify BACI to inspect a particular part of the
     reactor vessel's cooling shroud to look for water pockets; using an
     enhanced VT-1 in some cases for reactor vessel surveillance program;
     including some more CDM components in the scope of BACI, et cetera.
         So, once again, if you have any specific questions, but --
         DR. BONACA:  Let's go to the next overhead you have, and the
     data you're talking about, GSI 190.
         MR. SOLORIO:  Yes.
         Okay; well, in that case, we're done with the EMCB portion,
     so I need at least two chairs cleared so I can bring up the --
         DR. SHACK:  Swelling wasn't an issue here?
         MR. SOLORIO:  Well, it wasn't an open item, but we did --
         MR. DAVIS:  Well, actually, swelling came out after the
     draft SER was issued, so it was sort of handled outside of the open item
     issue list.
         MR. SOLORIO:  But it is in the safety evaluation report. 
     You will find it.
         DR. BONACA:  Will you discuss it at some point later?
         MR. SOLORIO:  We can discuss it now, because these guys are
     it so -- yes, you're right; let's just be clear:  there was never an
     open item or confirmatory item on swelling, like Mr. Hiser said here, it
     came up during the review, trying to finalize this SER.
         DR. BONACA:  But I see in the agenda here under item five in
     the agenda, there is a discussion of the way the steel was treated to
     cover at least --
         MR. SOLORIO:  Oh, you're right so -- that's different.
         DR. BONACA:  Oh, yes, I'm sorry.
         MR. SOLORIO:  But I was going to say we could have talked
     about it then, too.
         DR. BONACA:  Okay.
         MR. SOLORIO:  They're going to be back for that part so now
     or then.  All right.
         DR. BONACA:  We'll pick it up then.
         MR. SOLORIO:  All right.
         DR. SHACK:  That is -- let me just talk about Calvert Cliffs
     and high burnup fuel and all of that.  What is the projected end of life
     fluence for these internal, considering that people are going to high
     burnup fuels, and they've gone to low leakage cores?  Maybe -- I don't
     know if the staff or the Calvert Cliffs people can just tell me, you
     know, what are the end of life fluencies we're talking about for
         MR. SOLORIO:  Well, Mr. Hiser is going to try to answer
         MR. HISER:  One number that sticks in my mind for B&W plants
     from an internals topical report is on the order of 1022 for baffle bolt
     region, and I don't know if that's on the high end of the spectrum or if
     that's on the low end.
         DR. POWERS:  I think just about everything is 2 x 1022.
         DR. SHACK:  Right; it's just a question of how many times --
         DR. POWERS:  A few times; what a few is that's --
         DR. SHACK:  I believe the 1022.  The question is --
         MR. WHITEHEAD:  If I remember, and again, I don't remember
     the conversion to DPA, but the DPAs were on the order of 60 to 100 so
     that's -- I'm not sure what the conversion is.
         DR. SHACK:  That would come to quite a few times 1022.
         MR. WHITEHEAD:  That might be about 7 x 1022, something like
         DR. SHACK:  Okay; so, even with low leakage cores, people
     are still talking about DPAs of that order.  I thought to protect the
     vessel, and I just never knew when these DPAs were calculated on what
         MR. WHITEHEAD:  Just to reinforce, that was a number out of
     a B&W topical, which I assume is somewhat of a bounding value for B&W
     plants.  I don't know about the other vendors or any impact of fuel
         MR. GRIMES:  Dr. Shack, would you like us to research that
     further and get the numbers?
         DR. SHACK:  Yes; I'd be interested in knowing what those
     numbers are.
         MR. GRIMES:  Okay; the end of life fluence and whether or
     not that reflects a low leakage practice.
         DR. SHACK:  Yes; I just -- what an updated version of that
     would be, and I've heard the numbers 60 to 100 quoted before, but I was
     never quite sure whether that really took into account what I think
     they're really doing in terms of modern fuel management.
         DR. BONACA:  All right; DPA.
         MR. GRIMES:  We'll get that information back to Mr. Dudley.
         DR. BONACA:  Move on.
         MR. SOLORIO:  All right; in the mechanical engineering
     branch area, the top issue, obviously, would be fatigue in GSI-190. 
     Baltimore Gas and Electric chose a plant specific solution for the most
     part here.  This was -- represents a lot of effort between the staff and
     Baltimore Gas and Electric trying to reach an understanding.  As you
     see, I've outlined you on the slide the general approach.  If you have
     any specific questions, please --
         DR. BONACA:  Well, I have a question.  There is a
     resolution, a proposed resolution on GSI-190 that essentially is based
     on two findings.  One is that the frequency of initiators, crack
     initiators, is significantly increased between 40 years and 60 years of
     life.  However, the core damage frequency associated with these kind of
     cracks, and mostly, it is because cracks will occur in smaller piping,
     and in certain locations, you will have looked before breaks and things
     of that kind, okay?
         So that's really -- there is a recommendation that is coming
     to us that says that we should close GSI-190 on the basis of the fact
     that CDF is not changed between 40 years and 60 years; however, certain
     provisions are to be made insofar as inspections to deal with the higher
     frequency of cracks that we will experience at 60 years rather than 40.
         Now, the question I have is also, in that evaluation, by the
     way, they say that the criteria used by the ASME standards is not
     conservative for 60 years.  So the question I have specifically is what
     is specific to the Calvert Cliffs fatigue engineering program that would
     allow us to account for these new findings that we have?
         MR. FAIR:  I'm John Fair with NRR.  The -- I'm aware of what
     you're talking about here.  Research is getting ready to or has, I
     guess, submitted the package on the resolution that GSI-190.  The
     findings were that you're going to get a fairly high frequency,
     predicted frequency, of crack initiation.  The study was based on the
     existing study that we had done several years ago by Idaho National
     Laboratory, which we took a sample of components, put in the
     environmental effects, calculated some usage factors and tried to
     determine whether we could get those fatigue usage factors less than
         In most of the cases, we were for 40 years, but there were
     some cases the usage factors were still greater than one in 40 years and
     quite a number that were greater than one in 60 years.  So the high
     incidence of leakage cracks out of that study are based on CUFs that
     exceed one with environmental factors taken into account.  The program
     here -- there are two options:  one is to adopt the GSI resolution
     that's coming over to you in the package, and the other one is in case
     that wasn't available, they had a plant specific monitoring program that
     they proposed.
         The plant specific monitoring program takes the existing
     fatigue monitoring program at the critical locations and uses the
     environmental factors from the Argonne studies and computes the CUF. 
     The intent of that is to keep the CUF from exceeding one and hopefully
     keep from getting the high incidence of crack initiations.
         DR. BONACA:  Okay; so the multiplier from the Argonne study
     is being utilized.
         MR. FAIR:  Right; and there were a list of the specific
     components which they're going to use this multiplier on.
         DR. BONACA:  Okay.
         DR. SEALE:  That all presumes the idea of leak before break
     as being the expression of any failure due to a crack; that is, and all
     of this is based on the idea that you'll get a leak which will give you
     an inspection product which tells you you've got a problem before you
     get a major break.
         MR. FAIR:  I think if you get the full study that research
     is going to send over on the GSI resolution, they have -- they predict
     the incidence of fatigue crack initiation and then through wall fatigue
     cracks, and based on some additional studies, they have determined once
     you get a through wall fatigue crack, there's some proportion of them
     that could be large breaks or large leaks.  So there's a statistical
     evaluation of that.  It just doesn't assume it.
         MR. GRIMES:  Let me make sure I understand Dr. Seale's
     point, because I believe that the answer is no.  If we were to take full
     advantage of our leak before break concept and simply say, well, we
     don't care whether the CUF is greater than one or not, we're simply
     going to let it leak and fix it, would be to discount this plant
     specific solution and to, you know, simply let it go.  Break it and fix
         But this approach and the approach that we've described for
     GSI-190 is that there's a policy issue to decide whether or not you're
     going to rely on that as the aging management program or whether, as
     John described, you're going to rely on a process of monitoring the
     critical locations that are approaching high utilization factors; you
     will account for the environmental effect in determining when to take
     action to fix it before it leaks.
         DR. SHACK:  Yes; in this case, I mean, you're really fixing
     it even before there's a very large probability that it's going to
         MR. GRIMES:  Correct.
         DR. BONACA:  It has to be very, very clear, because it
     wasn't -- I mean, since GSI-190, the proposal that came after this came
     wasn't clear to me how it was incorporated.  So what you're saying is
     that, if I understand the program from Calvert Cliffs, they are going to
     really count the number of cycles literally on limiting the components,
     okay, and they're applying the Argonne criterion, so therefore, once
     they get to that point, they will be taking some curative action, and
     therefore, the likelihood of having a larger number of licks is not
     going to be increased.
         MR. GRIMES:  That is correct.
         DR. SHACK:  But they could adopt GSI-190.
         MR. GRIMES:  Yes; in the event that the commission -- that
     when we present the resolution of GSI-190, if the commission wants to
     rely on the low impact on CDF and say, well, we're going to be
     risk-informed; we're not going to require this accounting for the
     environmental factor in order to make a judgment about the effectiveness
     of aging management, then, if the answer came out that way, and so, you
     don't need to do any reanalyzing; you don't need to do any monitoring
     like this, then, we would suspect that BG&E would come back and say no,
     we're not going to use the Argonne data.
         DR. BONACA:  But that is not what the resolution says.  I
     mean, I read it, and it says we don't recommend that we keep the GSI-190
     open, but we recommend that programs be instituted to control the
     effects, to control the rate.
         MR. GRIMES:  Yesterday, there was a meeting with industry to
     talk about the report.  The report is going to be released to the
     industry within the next few days, and we are prepared to come in and
     explain the policy issue associated with generic safety issue 190 to the
     committee on December 3, I believe it is, at 8:30.
         DR. SEALE:  I understand my copy of that has to be over
     there when I came into this meeting, so I haven't seen it yet.
         DR. BONACA:  I got it yesterday, and I looked at it, and it
     was interesting that it clearly says, yes, core damage frequency
     justifies closing GSI-190.  However --
         MR. GRIMES:  However.
         DR. BONACA:  Okay; and the however really is pretty much
     what is being instituted at Calvert Cliffs.
         DR. SEALE:  Well, the real question in my mind is whether
     fatigue-induced cracks obey the same failure distribution as ordinary
     or, rather, cracks.
         MR. FAIR:  We had a lot of discussion on that particular
     item, and that was the cause of some reevaluation that went on before
     this report got finalized.
         DR. SEALE:  Well, I'm sure we'll get into that on GSI-190. 
     But we won't worry about it here.
         DR. POWERS:  I wonder if I could ask a question about the
     history on the environmental factors.  It says here that the
     environmental factors will be based on correlations developed at a --
     some sort out in the Midwest.
         MR. GRIMES:  Which shall remain nameless.
         DR. POWERS:  Is it the case that the applicants came in and
     said that they had these environmental factors from some other
     organization, and NRC staff said no, you have to use ours, or did they
     know any environmental factor that was available?
         MR. FAIR:  We did have some discussions back and forth on
     what to use as far as those factors.  The data is the same.  Argonne has
     gotten worldwide data together to come up with their correlations. 
     There are some interpretation differences between the staff and the
     industry on how much credit in the existing fatigue curves can we take
     for environmentals?  That is, how much can we reduce that factor based
     on what already exists in the ASME curves?  And we reached some
     compromise agreement in this resolution here where we did give some
     credit to BG&E for existing conservatism in the ASME curves as far as
     that factor.
         MR. GRIMES:  But to be clear, John worked with BG&E in order
     to make sure that we had accounted for the uncertainty and the
     controversy over what the appropriate factor is for a decision criteria
     that we're prepared to defend as being effective at taking action so
     that we don't have to rely on leakage as the indicator that fatigue
     damage is occurring.  And so, the ultimate generic resolution, the
     GSI-190 aspects, are going to address these questions about the
     difference in interpretation of the data and what all the data means and
     that sort of thing, but in the meantime, the staff has accepted this
     plant-specific approach as being adequate even in the face of that
     controversy; is that correct, John, the way I said that?
         MR. FAIR:  Yes, you did say it correctly.
         DR. BONACA:  Okay; all right.  I have a question for the
     presenter, Mr. Solorio.  How long do you have still to go for your
         MR. SOLORIO:  Three or four slides.
         DR. BONACA:  But there may be other questions, so should we
     take a break now or just go through it?
         MR. SOLORIO:  I was going to say it's okay with probably us
     if we continue to go on so that these guys can get out of here.
         DR. POWERS:  Why don't I suggest that we charge right ahead?
         DR. BONACA:  Okay; so, let's complete this, and then, so,
     this will cover section three of their presentation.  Let's go.
         MR. SOLORIO:  The other area that we had additional -- some
     extensive interactions with Baltimore Gas and Electric on was the
     management of containment prestressing force with respect to the
     tendence.  We were trying to work out the most appropriate aging
     management program here, and through the additional interactions, we
     learned that the existing -- I guess some of the changes in the existing
     regulations that BG&E is going to have to start following that do go a
     long ways towards making -- having an aging management program.
         We asked for some additional details regarding how they are
     going to do these inspections, and under this 50.55(a), they provided a
     response back to us on what they were going to do.  We looked at the
     other response in terms of how did it pair up with our SRP elements as
     we've done in almost every other case; we just haven't mentioned up to
     this point, but you'll see that in the text, we usually address the
     elements that are appropriate, and we felt that their aging management
     program would be sufficient for this, and we're going to close it.
         MR. SOLORIO:  Do you need to clarify anything that I might
     have said wrong, Hans?
         MR. ASHER:  No.
         MR. SOLORIO:  With respect to the materials branch, also,
     there were some additional open items:  fatigue; there were a lot of
     cases where we were asking them just to include certain or to evaluate
     certain components in other systems to determine if there was any
     critical components in those systems that needed to be added to their
     fatigue monitoring program, and they made that commitment, so therefore,
     we were able to close some of those open items out.
         And then, we had some questions about the intake structure
     and its potential exposure to ground water that might have been
     corrosive or what was the potential to the exposure to corrosive ground
     water, and we closed that out, too.
         DR. SHACK:  John, did you do the fatigue analysis by the old
     method?  That seemed to me a rather legalistic argument, I mean, the way
     it was settled.  Was there really a discussion about the number of
     stress cycles there that was really pretty conservative, even for 60
         MR. FAIR:  You're talking about the class two and three
     piping on Calvert.  I believe in the design code for class two and three
     piping, all they do is look at thermal expansion bending stresses, and
     there's a criterion in there that you reduce that allowable if you
     exceed a certain number of cycles, which is 7,000 cycles.  They said
     they went back and took a look that they didn't exceed that 7,000
     cycles, and I believe that because that would, like, be a full range
     heatup and cooldown type of situation.
         And there was also another criterion they used, and that
     criterion, if they had a very small delta-T change in the system, which
     would not give you significant stress.  So I didn't have any problem
     with that.  The only argument between us was whether that was a TLAA, or
     it wasn't a TLAA, and we felt because it had a 7,000 cycle limit in the
     code, it constituted a TLAA if you went and checked to make sure you
     didn't exceed that.
         DR. SHACK:  Okay; so, there was no technical disagreement.
         MR. FAIR:  No.
         DR. SHACK:  Just legalistic.
         MR. FAIR:  Just the legalistic.
         MR. SOLORIO:  These are confirmatory items.  Once again,
     there were some other cases where we asked them to look at some other
     systems and determine whether or not they were critical components that
     needed to be added to the fatigue monitoring program in the CVCS. 
     They're not doing an RE.  That's clear now.  That was closed out.  We
     just had questions about how effective it was going to be if at all, and
     other things are just adding additional checks to existing programs of
     components that we thought they should be looking at.
         And the last slide I have is for EEIB, the electrical
     engineering branch had an open item related to some penetration
     components that weren't within the scope of an aging management review. 
     The applicant explained to us how they could credit some existing
     programs for managing these, and we were able to close out the item. 
     And that's it.  The last slide is just a schedule to kind of show where
     we are in our Calvert Cliffs review cycle in case anyone wanted to look
         DR. BONACA:  Could you put it up?
         MR. SOLORIO:  Sure.
         DR. POWERS:  On a previous slide, you talked about leakage,
     the one that is going to be used -- do you have any grazing or polymers
     or plastics?
         MR. SOLORIO:  I don't understand your question.
         DR. POWERS:  And that's what's happened.
         MR. SOLORIO:  Let me ask them to explain the details here. 
     Paul Shemanski?
         MR. SHEMANSKI:  I believe the answer is yes.  Basically, the
     concern is what effect would radiation and temperature have on the epoxy
     O-rings, you know, the nonmetallic portions of the electrical
     penetration assembly that could degrade, theoretically, from exposure to
     radiation and temperature.  So this is where BG&E credited one of their
     existing programs, the integrated lucrate test program, to see if they
     get significant leakage, then, they'll look to see whether or not the
     penetration internals are, you know, degrading from radiation or
     temperature.  The initial look they took was only at the outside, the
     metal itself.  They made an evaluation for corrosion.
         DR. POWERS:  What kind of fluences are they -- the epoxy
     O-rings susceptible to in penetrations?
         MR. SHEMANSKI:  I don't know.
         DR. KRESS:  The integrated leak testing is running what?
         MR. SHEMANSKI:  This is part of the tech spec, integrated
     leak test program.
         MR. GRIMES:  I don't know if there are any plants left that
     do have pressure tests.  It's typically performed at peak calculated, Pa
     in appendix J.  They were talking about eliminating the half-pressure
     test at 0.5 Pa, but I lost track of that one, so I don't know if that's
     still a provision or not.
         And then, the answer to your previous question is we could
     go and try to get a figure for what the fluence is at the containment
     wall, but it's pretty low.
         DR. POWERS:  It's probably not worth your time, because I
     don't think it's very high, and so, you don't have any of these
     synergistic effects that fool you, I suspect.
         MR. GRIMES:  We wouldn't expect so.
         DR. KRESS:  The nature of my question was is the loop test a
     sufficient test to see if you've degraded that stuff?  I don't know if
     it is or not.
         DR. SEALE:  But if you have an electrical failure in one of
     these penetrations, that doesn't fall under the aging program.  That's
     something that you would respond to in the context of an electrical
     failure in the normal operation of the penetration, isn't it?
         MR. SHEMANSKI:  That is correct; if you had a false current
     or something in your respond, you know, it's going to show up either a
     blown fuse or a tripped breaker or something like that.  So you will
     have a direct indication of an electrical type faulted condition.
         DR. POWERS:  I guess, you know --
         DR. KRESS:  Is this in this space again?
         DR. POWERS:  It's going to DBA space.  Are all the aging
     processes in polymers going to lead to shrinkage, or do any of them lead
     to swelling?
         DR. KRESS:  And will these penetrations survive DBAs and
     similar accidents is the bottom line.
         DR. POWERS:  Yes.
         MR. GRIMES:  In short, let me try and summarize.  We look at
     the aging management programs in order to ensure their intended
     function.  In this case, there are two functions that we have a concern
     about.  One is electrical continuity, which we think is constantly
     challenged by virtue of energizing circuits, and the other is the
     integrity as a leakage boundary, their containment leakage boundary, in
     addition to environmental qualification tests that try and -- that try
     to simulate the synergistic effects of the combination of all of these
     things over time.
         We also have Appendix J, which includes a provision for a
     visual inspection, and we're looking to Appendix J, the leak test
     pressurizing the thing; the visual inspection will give us some
     indication about whether or not we're experiencing something that needs
     to be corrected, and that's basically what our conclusion is.
         Paul, do you want to add anything to that?
         MR. SHEMANSKI:  No, I think that's a pretty good summary.
         DR. POWERS:  What you are saying is basically, you've got a
     performance criterion here, and so, you really don't care -- the polymer
     itself can be dancing cartwheels for all you care as long as the two
     performance criteria are met.
         MR. GRIMES:  That is correct, but I pointed out also that
     there is a visual inspection associated with containment leak testing,
     so even though you don't blow it out, if, you know, if it doesn't look
     right, or if you're experiencing some, you know, some bizarre bulging or
     something like that, there are those aspects that Appendix J also
     affords us that are important to aging effects as well, not just the
     leak test.
         DR. POWERS:  Essentially, on the frequency of leak testing
     called for by the --
         MR. GRIMES:  They came risk informed, and so, it's hard for
     me to describe it these days.  It used to be three times in 10 years,
     but now, if you do real well, you can put -- string it out.
         DR. KRESS:  Yes; essentially, anybody can do that leak test
     now every 120 months or something like that.
         MR. GRIMES:  Option B.
         DR. SEALE:  Are you going to put the schedule up there?
         DR. BONACA:  Why don't you put your schedule up there so we
     can look at it?
         MR. SOLORIO:  Oh, just to kind of highlight where we are
     right now and what we've done so far and where we have to go is the
     remainder there.
         DR. BONACA:  When did you put together that schedule?
         DR. KRESS:  Was this before or after?
         DR. SEALE:  What's that going to do for you?
         MR. GRIMES:  Nothing.
         DR. SEALE:  Nothing?
         MR. GRIMES:  This is our schedule.  We're working to this
     schedule.  On November 12, the district court made a ruling that is now
     going to cause the commission to decide whether or not they need to do
     something.  In the meantime, this is my schedule, and I will continue to
     work towards preparing a commission paper with a staff recommendation. 
     Then I, too, will toss the ball into the commission's court, and they
     will have to decide what to do with those two conflicting
     recommendations, but at this point, we're continuing to work towards
     this schedule.
         By the way, I believe our end game schedule was established
     in August or September, and it represents the stage to get to
     completion, but right now, the commission -- we are working towards the
     January 14 date, which is going to pull together the safety evaluation,
     the final environmental impact statement, a recommendation from the
     region in terms of the results of their inspections, the last of which
     will be completed December 3 or 4; I can't remember what that date, but
     it's December 4 on this schedule, but they're starting, I think, on
     November 29.
         DR. APOSTOLAKIS:  Does the public have any opportunity to
     intervene here anywhere to express comments independently of the
     decision of the court?
         MR. SOLORIO:  The public meetings, they're always asked --
         DR. APOSTOLAKIS:  Which ones?
         MR. GRIMES:  Your meeting is an opportunity because as
     noticed, it solicits an opportunity for public comment.  The commission
     meeting would similarly be noticed.
         DR. APOSTOLAKIS:  If, for example, the public wanted to come
     today to comment on the SER.  If I look at that schedule, I would have
     to agree with the court:  11/16, 11/18, and do they have enough time to
     review it?
         MR. GRIMES:  They also have an opportunity to comment at a
     commission meeting if requested.
         MR. SOLORIO:  I would add that they've had also the SER in
     its present form since March, what really we're only talking about now
     is the open item resolution.
         DR. APOSTOLAKIS:  Did you every get any comments on the SER?
         MR. SOLORIO:  No, I did not.
         DR. APOSTOLAKIS:  Since March, nobody has tried to give you
     any --
         MR. SOLORIO:  And my name is up in the front of the
     document, so they can find me.
         MR. GRIMES:  To be clear, we did not specifically go out and
     solicit public comments on the safety evaluation, but when we went out
     and did our activities and held public meetings, we described this part
     of the process.  We described the preparation of the safety evaluation. 
     We pointed out that the safety evaluation addresses plant aging effects;
     the environmental review does not.  So even though we didn't
     specifically say tell us what you think about the SER, it's been there,
     as David says, since March, and they could have commented on it.
         DR. APOSTOLAKIS:  It's been there where?
         MR. GRIMES:  In the public domain.
         MR. SOLORIO:  And on our NRC Website since the end of May.
         DR. APOSTOLAKIS:  I'm perplexed now.  You are the originator
     of this.
         MR. SOLORIO:  But I didn't think the court was talking about
     the process.
         DR. APOSTOLAKIS:  The decision said that they didn't have
     enough time to actually go to the plant with their own experts.
         DR. SEALE:  They said they changed the interpretation of
     that phrase.
         DR. APOSTOLAKIS:  I don't think the Washington Post, if they
     wanted their own experts to inspect the plant, not the SER, okay?
         MS. MOORE:  That court decision was limited to a ruling on
     what standard the commission used in denying a request for an extension
     of time to file contentions, and it concerned the filing of the
     application.  The court's decision wasn't -- didn't involve the SER at
     all.  It said that we change the standard from good cause for granting
     extensions of time to unavoidable and extreme circumstances without
     providing an opportunity for notice and comment, as though we had
     changed the rule.  That was the court's ruling, and they weren't
     considering the SER at all.
         Remember that that motion was filed in 1998.  It was when
     the application was filed in April, and the motion for extension of time
     was filed in August of 1998.  So it's related to how much time the
     intervenors had -- the petitioners, pardon me -- had from the time the
     application was received until the time that their contentions would
     have been due, which I believe was in September of 1998.
         DR. APOSTOLAKIS:  So the questioned that time interval.  It
     was too short.  Is that what they're saying?  I'm sorry; I don't follow
     the legal --
         MS. MOORE:  I understand that, but the real crux of the
     court decision was the court's view that we change the way we granted or
     the reasons for which we granted motions for extension of time, and we
     didn't do it by a rulemaking.  That was the basis for the court's
     decision, and they were concerned -- they remanded that the decision on
     whether the motion should have been granted back to the commission and
     said using your own standard, you should determine whether the motion
     would have been granted in the first instance.
         The court made some pronouncements about what it thought,
     but it did say that it was up to the commission to go back and
         MR. GRIMES:  Let me also add, because I've been trying to
     work both aspects of this, in the particular case that went to the
     court, the petitioners' view is that meaningful public participation is
     to litigate issues, and they were looking for more time to define
     contentions that would be litigated before a licensing board.  That's
     separate from and distinct from our attempts to go out and inform the
     public about the basis for a renewal decision; to discuss the contents
     of the SER.
         Those things don't count in terms of meaningful public
     participation in terms of the petitioners who actually want to get these
     issues before a licensing board and litigate them.  Now, the rules in
     part two that we've used for -- in the original licensing established
     that we weren't going to wait until the end of the process to litigate
     them.  We've always had a process that said that the petitioners have to
     tell us that they want to intervene and that they want to have hearings
     when we start the review process, not when we're done with it.
         And this particular case involves a question about whether
     or not the standard for the parallel schedule that we originally set up
     for adjudication, whether or not that offered them a fair amount of time
     in order to identify contentions of the issues that would be litigated.
         DR. APOSTOLAKIS:  So what are the options open to the
     commission now?
         MS. MOORE:  The commission -- the commission has to
     determine how they want to proceed from here and whether they're going
     to request information on whether the original motion should be granted
     or whether they're going to do it themselves, and they may have other
     options.  I'm not privy to them at this point.
         DR. BONACA:  Thank you very much.
         MR. GRIMES:  Needless to say, as I've said before, I'm going
     to make it clear that while the commission is deciding what their
     options are and what they're going to do, we're going to continue to
     move forward on this schedule towards the preparation of a commission
     paper in January.
         DR. BONACA:  Sure.
         MR. GRIMES:  We would expect that by that time, the
     commission would have decided, and we will know what they're doing, and
     we will act accordingly.
         DR. BONACA:  Okay; very good.
         With that, I think we'll take a break now until 10 of 3:00.
         DR. BONACA:  We will resume the meeting, and I guess --
         DR. BONACA:  Okay; we are resuming the meeting, and I think
     we are talking about status of standardization.  Somebody passed out?
         DR. POWERS:  What is this now?  The title is --
         MR. SOLORIO:  GALL.
         DR. POWERS:  It should be divided into three parts, I'm
     sure, at least.
         MR. SOLORIO:  GALL is divided into three parts.  It starts
     with the schedule.  It includes an invitation letter that I sent out to
     a list of folks who are at the back of the package and an agenda for the
     workshop that we are going to hold on December 6 to solicit stakeholder
     feedback on how to proceed with the generic aging lessons learned, which
     we otherwise call GALL, and we expect from that to develop the standard
     review plan improvements, and I'll just -- I'll point out that the
     overall schedule that we're working towards starts with a meeting that
     we had with NEI in October to basically outline our -- the outcome that
     we wanted to achieve, which is basically as much agreement as we could
     get in terms of how to credit existing programs and proceed with the
     development of a generic aging lessons learned report.
         Earlier this week, we participated in an NEI-sponsored
     workshop on license renewal, and we talked some more about credit for
     existing programs and how to focus on where programs need to be
     augmented to manage aging effects.  We're going to hold our own workshop
     here in Two White Flint on December 6.  UCS has agreed to be a
     participant in that effort, and we sent out a very wide distribution of
     invitations.  And then, following our workshop, we will take that
     feedback that we get from our stakeholders, and then, we'll work with
     NEI to develop the completion of the GALL report and to implement the
     new standard format and a revision to the standard review plan.
         We expect to bring that package to the ACRS in February of
     2001, but we will keep you informed in the meantime of our progress as
     we proceed toward that milestone with an expectation that we would
     submit GALL and a standard review plan to the commission for their
     approval in March of 2001.
         DR. POWERS:  I have a document called the GALL report. 
     That's just the current iteration of this or --
         MR. GRIMES:  We've been releasing parts of the report as
     we've finished it.  I believe we issued the turbine or the steam and
     power conversion section, which was the least controversial of the
     areas.  Today, we issued the electrical chapter.  As the contractors
     help us finish these chapters, then, we're going to put them out in the
     public domain in order to get as early stakeholder involvement as we
         DR. BONACA:  I have a question of the license renewal
     standard review plan, which is, you know, I reviewed recently the
     September 1997 SRP that is in place, and I find it to be informative,
     but really, there are no criteria of any type.  Everything is, you know,
     postponed, and it seems to me that if the number of applicants for
     license renewal is as large as we think it is going to be, they are
     going to be working at it now next year, and I really would have liked
     to see an interim update of the license renewal SRP ahead of time, even
     if it was a rough update, but something that would give some guidance on
     a preferred format on the part of the staff and content, my concern
     being that we may see proliferation or some other approaches or, you
     know, one of a kind solutions that may not be desirable, but they're
         MR. GRIMES:  We anticipated that problem as well, and that's
     why we concentrated on getting NRC and industry agreement on a standard
     format and content.  It basically outlines the way we want the
     information presented for our review.  The industry has agreed both
     generically, and also, the next two applicants, Arkansas and Hatch, have
     used that standard format along with the experience that -- the
     experience from Calvert Cliffs and Oconee.
         And I would like to say that even though we recognize the
     1997 version of the standard review plan was somewhat coarse, we were
     still very pleased that the staff managed to use that and conduct the
     reviews of the first two applications as effectively as they did, and we
     also will have the benefit of, as we get the GALL report out, and the
     applicants can see how we've used the 10 program elements on a program
     by program basis that there will be more guidance available for them.
         This schedule shows that we expect to be able to have a
     revised standard review plan in August of 2000 which we would send out
     for public comments to more directly engage our stakeholders, and given
     keeping up with the applications and resolving generic renewal issues
     and other things, that's about as ambitious as I think we can get.
         DR. BONACA:  So that would be your first product; I mean,
     that would go out for comment, so that would be the middle of next year. 
     I think that's reasonable.
         DR. POWERS:  I think you have to congratulate them for their
         DR. BONACA:  Yes.
         DR. POWERS:  -- the breadth of the things that they've sent
     out to offer this workshop to, and they are presumably reaching out to
     them.  But it still does not include the exposure before the learned
         MR. GRIMES:  Actually, when we sent our invitations out, I
     did send invitations to the professional societies, the ASME and IEEE,
     ANS.  I sent it to Mr. Kadak or Dr. Kadak.  We did try and reach out to
     -- I confess about the only thing that I didn't do was try to involve
     academicians, go to universities and those bodies, but I did feel like
     we reached out far enough to get the professional groups, and we posted
     the information on the Website, and as we find others who are interested
     in aging management, then, we will include them as well.
         DR. POWERS:  But there are learned societies that are
     completely devoted to the issues of corrosion.  There are journals with
     the name corrosion included, and I don't see you making contact with
     that community the way that community wants to be made contact with,
     which is not sending somebody, their president; it's participating in
     their meetings and giving voice to the things that you're trying to
     accomplish here.  And when does that happen?
         MR. GRIMES:  I don't know, but I'll figure it out.  I'll
     take -- I think that's an excellent comment, and we'll go back, and
     we'll consider how we can reach out to those organizations as well.
         DR. POWERS:  Because certainly, the groups that you looked
     at here for your workshop, it is a cross-section, and I do wish Graham
     Wallis were attending this meeting, because I think he would be
     delighted when he saw the cross-section that you had been able to touch.
         MR. GRIMES:  Thank you; but to the extent that we can try
     and find other contacts and notify them at least about the workshop in
     December, but then, between December when we hold that initial workshop
     and then when we go out for public comment, if we can engage other
     stakeholders that would have a particular interest, the corrosion
     society --
         DR. POWERS:  It just seems to me that it would be terrific
     if you could approach the -- one of the journals devoted to corrosion
     and aging.
         MR. GRIMES:  This is really -- I mean, if you've got NACE,
     then, I mean, certainly, they should be -- the National Association of
     Corrosion Engineers.
         DR. APOSTOLAKIS:  Well, the question that comes to my mind
     when I hear you say these things is why would these people come?  I
     mean, you don't go to meetings just to go to a meeting, right?  So I
     don't know that going out of your way to invite these societies would be
         DR. POWERS:  Obviously, I think I agree with you.  Getting
     this thing sent to -- I know the societies I deal with; if the president
     got this thing, he wouldn't know what to do with it, and he wouldn't do
     anything with it.
         DR. APOSTOLAKIS:  Right.
         DR. POWERS:  But on the other hand, if you had one of your
     staff giving the presentation at the NACE meeting or something like
     that, it exposes a cross-section of people that probably don't come in
     contact with it.
         DR. APOSTOLAKIS:  That's different, yes, that's different.
         DR. POWERS:  And they might be quite stimulated by just the
     recognition that people had problems, and it might be very interesting
     to do
         DR. SEALE:  Well, some of these societies have Washington
     offices, too, and they may choose to have a staff member who resides
     here anyway come to it.  If we could see if there's anything relevant to
     their --
         DR. APOSTOLAKIS:  I mean, relevant to what?  I mean, do they
     see any research support coming, or do they see any way of influencing
     things?  No; so their interest will evaporate very quickly.
         DR. SEALE:  No.
         DR. SHACK:  Well, I mean, NACE, for example, does sponsor
     environmental degradation and nuclear power plant symposia every other
     year.  You know, they have a professional interest.
         DR. APOSTOLAKIS:  So maybe that would be a good place to
     have a special session or something.
         MR. GRIMES:  We have managed to stimulate some interest more
     broadly by our participation in things like the international conference
     on nuclear engineering, the American power conference, the ASME power
     conference, things like that, and to the extent that we can make clear
     to these special interest groups that there are aspects about aging
     management for which GALL is attempting to identify the effectiveness of
     current programs and identify where programs need to be augmented, there
     is an aspect of that that does involve research needs for the future,
     and that has come up in our relationship with the Office of Research in
     terms of how they are coordinating with -- DOE has a NEPO program that
     looks at, you know, where there could be more research to assist in
     plant life cycle management.
         DR. POWERS:  Because I've been generally persuaded by the
     argument that by having credibility, an NRC program with a learned
     society contributes immeasurably to public confidence in that program,
     and I think you've got a good -- you've got an awfully nice job here in
     a lot of these things, and getting exposure to the professional
     societies and some sort of endorsement or at least credibility from them
     I think is merited here.
         MR. GRIMES:  We will keep working towards that goal.  We are
     very interested in trying to establish public confidence in the work
     that's being done here.
         DR. APOSTOLAKIS:  I think that the real measure of
     acceptance is to actually write a paper and send it to their major
     journal.  That's when people get out their knives and give you problems. 
     To go and present a paper doesn't really do much.  To publish a paper in
     Nuclear Energy and Design doesn't do much.  But if you send it to that
     journal of a society that deals with corrosion, for example, and then,
     you will see what comments you get, then, you're well on your way to
     getting either the blessings or the -- because I find that when people
     review papers, that's when they really put down -- they pay attention. 
     To go to a meeting really doesn't do much.  I mean, you can say
     afterwards we presented it at this meeting.  I mean, that doesn't mean
         Now, I don't know whether you can actually write a paper
     that will be considered by those guys a scholarly paper to be published,
     but I don't know.  I mean, there must be application someplace, because
     my experience, for example, with decision theorists, because a lot of
     the stuff I do touches on what they do, it's one thing to present it at
     the Society for Risk Analysis meeting and quite another to submit a
     paper to the Journal of Risk Analysis.  Boy, they're brutal; they're
         MR. DAVIS:  I'm Jim Davis.  I've been a member of NACE since
     1968, and they would not accept an article on license renewal in
     Corrosion Magazine.  It's a very theoretical magazine, and as a society,
     they really wouldn't do anything to endorse anything that we did.  They
     have an annual symposium that draws about 5,000 people.  They have a
     section; they have a technical committee on nuclear energy; they have a
     very well-attended seminar every other year.
         DR. APOSTOLAKIS:  But they don't have a forum for publishing
     applied papers?
         MR. DAVIS:  Yes, they do; it's Materials Performance, and
     it's more of an engineering type of journal, and I would guess that a
     group of us would publish something on that.
         DR. APOSTOLAKIS:  Something on nuclear.
         MR. DAVIS:  But the society in itself would advertise this
     meeting if it were sent to them months and months and months ahead of
     time, but the society itself would not attend the meeting, the members
     of the organizing committee.  They would just let it be known that the
     meeting is occurring.
         DR. APOSTOLAKIS:  Unless you say there is a lot of research
     money to come.
         DR. APOSTOLAKIS:  Then, they will come.
         MR. DAVIS:  They really are not very big on the research --
         DR. APOSTOLAKIS:  They are human too, you know.
         MR. DAVIS:  They are not very big in the research area. 
     What they really like to make their money on is sponsoring symposia, and
     they do a lot of symposia every year, and they make a lot of money doing
         MR. DAVIS:  And if the license renewal would like to have
     NACE be one of their co-sponsors, I'm sure NACE would be very interested
     in that.
         MR. GRIMES:  I'm sorry; I'm not going to bite on that one. 
     I do find that -- I am a volunteer reviewer for Nuclear Technology, and
     I agree with you.  I think that we will get some excellent feedback if
     we could find some way to capture the GALL results in some professional
     journals that would basically test the theories.
         DR. APOSTOLAKIS:  Right.
         MR. GRIMES:  And I'll have to try to figure that into our
     resource loads and plans, because we're going to have a difficult time
     just keeping up with writing safety evaluations, let alone trying to
     find staff members or others who could sponsor papers.
         DR. POWERS:  I think that is an area we need to chat with
     the commission about.
         DR. APOSTOLAKIS:  Sure.
         DR. POWERS:  Because I -- the visibility and the credibility
     among technical and learned societies contributes so much to public
     acceptance of what's going on that some measures have to be taken to
     make sure that these guys have opportunities to avail themselves, and
     they have to do a lot of it on their own time, because the membership in
     these societies is done at their own cost and things like that that's --
         DR. APOSTOLAKIS:  Sure.
         DR. POWERS:  The importance of it shouldn't be diminished at
         DR. APOSTOLAKIS:  That's right; now, in the past, the
     commission has appointed ad hoc review committees for major studies like
     the reactor safety study, NUREG 1150 and other studies.  Has there been
     an effort to have a review committee to go over the process?  That
     committee might include people from other industries.  From my
     experience with 1150, I'm not sure those guys contributed much, because,
     you know, everything was so new to them that it took a long time for the
     poor Sandia guys to educate them to deal with macroscopic phenomena.
         But something like that with members, you know,
     distinguished members from non-nuclear fields, because, you see, if you
     do that, then, it's sort of an honor to serve on that committee.  People
     will be willing to come.  They will meet with the commissioners at some
     point in the future.  In other words, you're stroking their ego a little
     bit, and that's the most powerful way to get people to do things.
         So maybe a committee of distinguished people to, you know,
     with a task to review the whole process or maybe parts of the process
     and then pass judgment, that may be a way of bringing -- I mean, you can
     ask societies to nominate people, for example, and getting some real
         MR. GRIMES:  All I could say at this point is no, we have
     not brought that matter up.  Certainly, you know, if the ACRS thinks
     that that would be a valuable way to try and establish GALL and the SRP,
     you could make that recommendation to the commission.  In the meantime,
     I'll go ahead and mention this to the license renewal steering committee
     and see, you know, what interest they have in pursuing something like
         DR. APOSTOLAKIS:  I don't know how the ACRS feels, by the
     way.  This is a personal view.
         DR. BONACA:  And it will be treated as such.
         DR. POWERS:  It will be views according to --
         DR. APOSTOLAKIS:  All this is on record.
         DR. POWERS:  And as in all things, you know, no good deed
     goes unpunished.
         DR. BONACA:  So we heard about the status of standardizing
     the LRP, and actually, I'm encouraged by the commitment to August for an
     update of the standard review plan.  By the way, I didn't intend to
     diminish the value of that plan as it is today.  I recognize it was a
     good guide.  I simply could not find any criteria whenever a judgment
     had to be developed on what is acceptable and what is not.  It typically
     was, you know, referred to who will determine it on a one-to-one basis. 
     That was the key concern I had on that.
         DR. APOSTOLAKIS:  The standardization refers to the existing
     process, right?
         DR. BONACA:  That's right.
         DR. APOSTOLAKIS:  No attempt to change the process.
         MR. GRIMES:  I would like to point out that if you look at
     the end of the schedule, I described how we get GALL and the SRC to the
         DR. APOSTOLAKIS:  Yes.
         MR. GRIMES:  But notice those last milestones, the staff
     requirements memo on credit for existing programs; the commission
     directed us to go seek public comment on rulemaking, that is,
     fundamental changes to the concept of license renewal, and so, we also
     have an obligation to go back to the commission with recommendations on
     how the very foundation of license renewal might be improved for the
         DR. SHACK:  NEI has that on their generic issues list, too,
     rule changes.
         MR. GRIMES:  And we are pursuing rulemaking for the petition
     for that particular change, but the staff requirements memo basically
     directs us to go out and seek a wider input on potential rule changes
     that could go to the very heart of Part 54 and Part 51.
         DR. APOSTOLAKIS:  So this is the May 1 item?  The public
     meeting to discuss need for rulemaking?  Is that what you're referring
         DR. BONACA:  Staff recommendation memo.
         MR. GRIMES:  Yes; starting in April of 2001 --
         DR. APOSTOLAKIS:  Okay.
         MR. GRIMES:  -- NEI would provide us comments on what they
     view as their need for rulemaking.  May, we would hold a public meeting
     and seek a broader input on potential rule changes, and we would intend
     on throwing the doors wide open.
         DR. APOSTOLAKIS:  Are we part of the loop?
         MR. GRIMES:  Not yet.
         DR. APOSTOLAKIS:  I at least -- personally, I would like it
     to be between the 5-1 and 7-1 dates.
         DR. BONACA:  Yes, I think we should be part of that.
         MR. GRIMES:  Look and see if Dr. Lee is cringing as I put
     another milestone on our chart.
         DR. BONACA:  Although you have a meeting with us on February
         DR. APOSTOLAKIS:  That's way too soon.
         DR. BONACA:  Yes.
         DR. APOSTOLAKIS:  I'd like to see the public comments and
     then the preliminary staff recommendations.
         DR. SEALE:  6:15.
         DR. APOSTOLAKIS:  Good.
         DR. BONACA:  Okay; so, we go on to that item four on the
     agenda.  Any other questions from members on that?
         [No response.]
         DR. BONACA:  If none, we're going to hear about comparison
     for Calvert Cliffs and Oconee on some key issues.
         DR. APOSTOLAKIS:  I have a question.
         DR. BONACA:  Please go ahead.
         DR. APOSTOLAKIS:  Has NEI shown any interest in risk
     informing the process?
         MR. GRIMES:  It's one of our generic renewal issues is
     risk-informed license renewal, and it would be towards giving --
     basically, NEI would like to get risk credit for changes in scope, aging
     management programs, need to maintain time-limited aging analysis, so we
     have basically -- my approach to this has been let risk-informing Part
     50 progress far enough where we can see the relationship and then draw
     parallels to license renewal, but my view is that risk informing Part 54
     would be one of those things that we would look at in the context of
         DR. APOSTOLAKIS:  Okay; so, you are waiting to see what
     happens to part 50.
         MR. GRIMES:  That is correct.
         DR. SEALE:  But if you have a utility who has already
     participated in a pilot study or whatever and has had an application,
     and the commission has acted on it for a change based on a risk approach
     to handling a problem rather than the prescriptive approach, that is an
     acceptable part of the application, isn't it?
         MR. GRIMES:  That is correct, because that constitutes a new
     current licensing basis.
         DR. SEALE:  Yes.
         MR. GRIMES:  Which you would then apply the criteria, the
     scoping criteria to and say what systems structures and components are
     relied upon to perform these safety functions?  Now, it doesn't help you
     for regulated events, because compliance with station blackout EQ, those
     things are still scoped in, but if the basic safety functions of the
     plant have been risk informed, then, I would expect that would
         We're still looking at that.  We're working very closely
     with the team that's risk informing Part 50 in order to look at the
         DR. BONACA:  And I want to point out that, you know, we're
     ranking like an option two has been utilized to substitute
     safety-related components from the deterministic parts with the new
     components.  We had a recommendation about two meetings ago about
     certain requirements that we would expect to see in changing the basis. 
     For example, one thing that we had talked about was credibility of the
     process.  I mean, you could just say this component was here, and now,
     it is not there anymore; it's something else.
         So this is just an example of some of the requirements that
     we would expect to see, and do you have any plan to have some guidance
     of that in the SRP, or is it too early to expect that to happen?
         MR. GRIMES:  Well, at this point, it's been enough for us to
     simply get guidance on the issue of scoping as it relates to how to view
     the CLB.  i would expect that guidance would continue to be updated as
     we go into risk informing Part 50 and changing the very foundation of
     what constitutes safety-related.
         DR. BONACA:  Because right now, for example, it's not clear
     to me that some of the applications, you know, with one application that
     all the decisions that were made regarding certain components, replacing
     them, have been documented or have a very clear basis of -- what was the
     basis for that decision, and I think that becomes very important in
     license renewal space, where you are dropping a component that really
     should be there because of the deterministic approach, but you don't
     have a documented basis for why it was changed just because you have an
     expert panel that made certain decisions.
         And probably, they had all kinds of insights for it, but, I
     mean, certain requirements are -- I mean, it is going to be a pretty
     sticky issue.
         MR. GRIMES:  Well, my personal view is as the staff goes
     forward and risk-informs Part 50, I think that that fundamental question
     about whether or not it's really a good idea to say that certain things
     are no longer safety-related is being captured by how do we treat
     defense in depth and the basic philosophy of how the plant design is
     maintained, and I really look to that area to help decide how the
     treatment of the four boxes in risk informing Part 50.
         It's fundamentally a treatment issue.  So certain things are
     going to be treated as very important, and they need good inspection
     programs.  There are other things that were traditionally not
     safety-related, and we now recognize that they need to be treated like
     safety-related equipment, and then, there is a lot of safety-related
     equipment that does not need the pedigree that the amount of
     maintainability and precision that we had classically, and I think that
     when we look at defense in depth, that's really going to answer that
     question in terms of how to draw that fine line between the different
         And at this point, license renewal just wants to be staged
     so that as the current licensing basis changes, we will have guidance
     that explains how to treat that for a license renewal review.
         DR. BONACA:  Okay.
         MR. GRIMES:  Unless there are any questions about generic
     renewal matters, we are going to move into a discussion about a
     comparison of the Calvert Cliffs and Oconee license renewal treatment. 
     There are three issues.
         DR. BONACA:  Four issues.
         MR. SOLORIO:  Four issues?
         DR. BONACA:  Well, we added one, which was the swelling of
     postilytic components, stainless steel.
         MR. SOLORIO:  They're not on the slide.  They mentioned that
     they wanted to talk about it earlier.
         DR. BONACA:  After this part of the meeting.
         MR. SOLORIO:  So, sorry, it's not on my slides, but the
     right guys are here to talk about it.  Previously, we had been told that
     there were three areas you all wanted to have a summary of how we dealt
     with them so you could possibly see a range of dealing with these
     issues.  Today, Barry Elliot and Allen Hiser are going to -- Allen is
     going to talk about CASS.  I'm just going to quickly summarize the
     fatigue and also mention the similarities and differences we found with
     one-time inspection, and I used the acronym ARDI there, but it really
     should have been one-time inspection, because that's not what Oconee
     uses as the terminology.
         MR. HISER:  Regarding management of CASS components, I guess
     the first thing I want to describe is there is sort of a two-step
     process overall.  The first step in the process is determining the
     susceptibility of the component to thermal aging, and that would take
     into account the fabrication process and the molybdenum content and
     things like that of the material itself and also the operating
     environment.  There would need to be a high temperature operating
         If a material or a component then is determined to be
     susceptible, then, it would require some sort of aging management.  If
     it's not susceptible, then, the assumption is that the fracture
     toughness is adequate; that there should be no problems throughout the
     license renewal period.
         Now, on the left hand column are the four classes of
     components that are fabricated from cast alstinitic stainless steel. 
     The first three, piping, valves and pump covers and casings are
     basically pressure boundary components, so they have the 2,000-plus psi
     pressure, whereas the reactor vessel internals do not see any pressure
     retaining characteristics, but they're there for other purposes, so they
     see different sorts of loads.
         Now, regarding the piping, Calvert Cliffs proposed basically
     a three-option management program.  First of all, if the component is
     determined to be susceptible, then, it would be subjected either to
     supplemental explanation in conjunction with the flaw tolerance
     evaluation or a full leak before break evaluation, or Calvert would just
     replace the component.
         DR. SHACK:  Where do you get this CASS typing?
         MR. HISER:  Surge line and various nozzles, things like
         In contrast, Oconee has no CASS materials in the piping
         Regarding valve bodies and bonnets, Calvert, again, looking
     at susceptible items, would provide the same three options as with the
     piping, so either an examination and flaw tolerance, a leak before break
     evaluation or a replacement.  In contrast, Oconee or Duke Power has
     proposed to use the current ASME Section 11 requirements.  And
     basically, staff has found that to be acceptable.  And let me sort of
     jump ahead for a minute.  With pump covers and pump casings in both
     cases, both applicants are either proposing to use the current ASME
     Section 11 requirements or Code Case 481, and regarding valves and
     pumps, pump covers and casings, we found that the overdesign on those
     components is so great that the current requirements are sufficient, no
     matter how -- the toughest would have -- no matter how low it could
     degrade during operation, it still is sufficient.
         Regarding vessel internals, to tackle the simplest one
     first, Duke Power has proposed a supplemental examination of a sample of
     all of the items composed of CASS, so in this case, they basically are
     assuming that everything is susceptible, and they're just lumping
     everything into their inspection scope.  The sample size examination
     method and acceptance criteria would be determined by reactor vessel
     internals aging management program, which is basically a research
     program that the B&W owners' group has initiated.
         In contrast --
         DR. SHACK:  So they haven't quite defined what it is they're
     looking for when they do this supplemental exam.
         MR. HISER:  That is correct; what they've done is lay out a
     process to determine the sample size examination method and acceptance
     criteria.  They don't have the details at this point, mainly because
     some of the mechanisms they want to do additional research to determine
     susceptible areas and, yes, where they could or should focus their
         In contrast, BG&E has an approach that's really, I guess, in
     line with the piping.  First of all, with the internals fabricated from
     CASS material, we have the thermal aging and brittlement, and we also
     have neutron fluents on the components.  The two of those embrittle the
     material in somewhat of a synergistic approach, and so, you really need
     to consider it a little bit differently from the non-irradiated
     components.  So the first criterion that they have proposed is to look
     at the neutron fluents.  If it's below 1017 neutrons per centimeter
     squared, then, the assumption is that neutron embrittlement does not
     contribute.  If it's greater than that fluence level, then a synergism
     of thermal and neutron embrittlement has to be considered.
         If it's only thermal embrittlement, then the same
     susceptibility criteria used with the piping would have to be justified
     as being applicable to the internals, and if it's found to be
     susceptible, then some sort of a supplemental exam would be required,
     and at this point, they proposed a visual enhanced VT-1 approach.  If
     thermal and neutron embrittlement are both contributing, then we have a
     stress cutoff that BG&E has proposed, that the stress under all design
     conditions is low enough that should cracking occur -- well, cracking
     probably wouldn't occur because the stressors are so low, but even if
     there was something there that would not propagate, then no supplemental
     aging management program would be required.
         If the stresses are high, then supplemental examination
     would be required, and again, the proposal at this point is an enhanced
         DR. POWERS:  Can you tell us the basis for selecting the 5.5
         MR. HISER:  Basically, we were looking for a low stress
     level.  Many of the components in the internals are compressively loaded
     under normal operating conditions, and we were -- the main concern that
     we have is that should there be a stress reversal due to an SSE or a
     large break loca, then, you could have stress reversal and possibly put
     the component under a tensile load.
         That basically was just what we chose as a low stress
         DR. POWERS:  So if I have something that's at 5.6, I'd
     better do anything about it?
         MR. HISER:  At this point, with this criterion, that would
     put you into that mode; that is correct.
         DR. POWERS:  I think I need more help here.  It just
     surprises me that at 5.6, you're going to kick me over into doing a lot
     of work.
         MR. HISER:  At this point, given the criteria that have been
     laid out, that's what would happen at this point.  My guess is that
     there probably would be a submittal requesting relief from that.
         DR. SEALE:  I'd give them a chance to sharpen their pencil.
         DR. SHACK:  Every time you have a bright line --
         MR. HISER:  Well, one major difference that I guess I'd like
     to point out between the two proposals, and realizing again that Calvert
     Cliffs is a mature review at this point with the final SE issued;
     Oconee, we're still resolving open items.  Calvert has proposed this
     aging management as a part of the 10-year ASME code ISI program.  At
     this point, Oconee has only proposed the supplemental exams as one-time
     inspections, and that's something that we are discussing with them.
         DR. BONACA:  I have a question regarding on the internals,
     just the philosophy of acceptance.  You have the Calvert Cliffs program,
     which is very detailed.  I mean, you could step through it, question it,
     critique it, and, in fact, we came to some discussion at the end of some
     of the commitments.
         For the Oconee one, you have a promise of a program, and
     that probably is a great program, but have you seen the program?  I
     mean, the reactor vessel internal aging management program from the --
         MR. HISER:  We have -- they basically, the B&W owners group
     has laid out goals of the program and basically the framework of the
     program.  Reactor vessel internals degradation in general has become a
     major industry program, and where all of the vendors and owners' groups
     have basically banded together because the issues are the same, there
     may be different material.
         DR. BONACA:  And will you have an opportunity to comment on
     that before you grant the life renewal license to Oconee or if not, what
     opportunity has the staff to participate in that kind of process of
     establishing what's enough and what is not enough?
         MR. HISER:  What we have done with Oconee in particular is
     to request periodic updates on the status of that program, the RVI/AMP
     program.  One of our concerns is that in 10 years, the applicant may not
     have sufficient information to put together that program.  We want to
     make sure that that doesn't happen.  So we expect that we will have a
     lot of interactions with this greater industry program and also with the
     RVI/AMP just to make sure that the proper issues are being addressed and
     that things are coalescing in a timely manner.
         DR. SHACK:  But just in the sheer mechanics, then, you will
     issue a license with some sort of conditional statement that they will
     come up with an acceptable program, or you'll trust that they will come
     up with an acceptable program?
         MR. GRIMES:  At this time, we haven't finished the
     resolution of the open item for Oconee, so we don't know what the
     framework is.  But Allen's point is well-taken.  For Calvert Cliffs,
     we've come to a plant-specific solution that we can refer to as the
     basis for managing the aging effect.  For Oconee, they're referring to
     an owners' group activity where the real hook that we've got is in the
     resolution of their generic solution that is going to be referred to by
     several plants, and so, I don't know what this thing would look like
     yet, but it basically is going to tie them to that generic activity.
         DR. SHACK:  But what happens if you don't come to an
     acceptable resolution of the generic activity?
         MR. GRIMES:  Then they're going to have to -- then they
     couldn't fulfill the commitment that is now part of their new licensing
         MR. ELLIOT:  The research is going to lead to an inspection
     or recommendation for inspection or not to have inspections.  At that
     point, they will recommend something.  Then we, as regulators, will do
     our regulatory duty is look at their thing and decide what action we
     have to take at that time.
         DR. BONACA:  The reason why I'm pursuing this is that to the
     degree that you have plant specific or grouping that you have, you may
     end up with hundreds and thousands of commitments out of there, okay,
     two programs which you have to verify at a later time, and participants
     in the program just -- I'm trying to understand really this issue that I
     opened up the meeting with on how, you know, this stuff really has to
     review its way of getting back into the process in an effective way that
     is feasible, that is not overwhelming, you know, from a resource 10.2.
         Again, you know, I look at the left column; I like that.  I
     understand what they're going to do.  I agree with that, and I go with
     it, and I look on the right --
         MR. HISER:  And one aspect is that BG&E is also
     participating in this industry program, and within their proposal for
     the reactor vessel internals aging management, they explicitly state
     that if the results of the program indicate that this inspection is not
     necessary, then, they would come in requesting relief from that.
         My expectation is that what will happen is the industry will
     develop an approach to manage reactor vessel internals not only for CASS
     materials but probably void swelling and some of the other issues that
     we have, and that probably will be the approach that all licensees will
     want to take.
         DR. BONACA:  You know, I would think that maybe the bottom
     line is that clearly, discovery, you know, in the next 30 or 20 years,
     discovery of new phenomenon or some degradation in some respect or
     changes would cause significant changes to the commitments that are
     going to be made, and again, we talked about 50.59 as a decent process
     to get into, but I think it's a complex that you may want to reflect on,
     you know, do you need anything else?
         MR. GRIMES:  That is a question that we've faced and will
     continue to face.  The purpose of the Calvert Cliffs safety evaluation,
     we found that the commitments fit in a category that we believe that
     they could be managed by 50.59.  We noted that for the future actions,
     50.59 doesn't deal with this question about timing and that we needed a
     provision for that.  When we finish Oconee, we're going to face that
     same question.  We always have the same option of setting out separate
     license conditions for particular things, actions that the commission
     should be directly involved in deciding, but to the extent that, as Dr.
     Bonaca has pointed out before, we're trying to rely on process, project
     how that process is going to continue to evolve between now and the end
     of the current license term and then manage the system structures and
     components beyond that point, we're trying to keep it simple as well.
         We can keep it simple if we get the commitments as specific
     as possible and tied to specific activities and actions that the
     licensees are going to manage in their licensing basis in the future.
         DR. BONACA:  Okay.
         MR. GRIMES:  The FSAR issue is one that NEI continues to
     believe that we don't give enough credit for commitment management
     processes in the way that the utilities, manage their plant designs, so
     rather than complicate it with trying to develop more devices, we're
     going to rely on 50.59 and license conditions as the two mechanisms for
     commission involvement.
         DR. BONACA:  Okay; do you want to -- okay, any more
     questions on this?
         [No response.]
         DR. BONACA:  If not, maybe we can talk about swelling now or
         MR. HISER:  Actually, if you'll put that slide back up, we
     have received similar responses from both BG&E and Oconee, and the
     program that I talked about, the industry program on reactor vessel
     internals, one of the tasks that has been undertaken on that is an
     assessment of void swelling, looking at material properties, looking at
     impacts on core internal structures, things like that.  Both applicants
     have committed to participation in the industry programs.  They have
     committed to assess the need for any supplemental examination programs
     and then to implement those programs as needed during license renewal. 
     I think we have found that to be acceptable given the uncertainties
     involved at this point and the scope of the problem.
         DR. POWERS:  If I wanted to get myself up-to-date on the
     latest in void swelling, what would I read?
         MR. HISER:  Probably anything from Dr. Garner, P&L.
         DR. SHACK:  Just do a literature search on Frank Diamond,
     and then, you can watch how Frank goes.
         DR. SEALE:  Bill!
         DR. BONACA:  All right; okay, thank you.
         MR. SOLORIO:  Earlier this afternoon, you heard me mention
     and John explain in detail the Calvert Cliffs fatigue management
     program.  Oconee has some similarities and some differences notably
     prior to exceeding design cycles for corrective actions and also with
     respect to monitoring design transients specified in the FSAR, and they
     also propose to implement the GSI-190 resolution, and I guess they have
     some other particular components that they're subjecting to apply the
     environmental factors to different there than Calvert Cliffs does.
         DR. POWERS:  Their research should have taken a copyright
     out on the ANL environmental factors, and they would probably be wealthy
         MR. FAIR:  The ANL -- this is John Fair again, by the way --
     the ANL factors are very similar to factors developed by the Japanese. 
     They're all evaluating the same data, and so, although they're published
     in ANL NUREG reports, the data is from other sources.
         DR. POWERS:  Just trying to find a way to stretch the NRC's
     research budget a little bit.
         DR. SHACK:  As a matter of fact, the Japanese get very
     unhappy to see themselves referred to as ANL environmental.
         DR. SEALE:  I bet!
         DR. SHACK:  Doctors Higuchi and Aida sort of ding us about
     that quite often.
         DR. BONACA:  All right; so essentially, Oconee has pretty
     much the same program.
         MR. FAIR:  Yes; the programs are just slightly different in
     that in the monitoring, the Calvert has critical high usage factor
     components that they are monitoring, and they are monitoring based on
     the usage factor, whereas Oconee is just monitoring the cycles of design
     basis transience from the FSAR.
         DR. BONACA:  I mean, how do you --
         MR. FAIR:  As long as you monitor the design basis
     transience in the FSAR, and you don't exceed them, you won't exceed the
     usage factor of one.
         DR. BONACA:  Okay.
         MR. FAIR:  The advantage of Calvert's is they get to take
     some conservatism out of the analysis by monitoring usage factor.
         DR. BONACA:  But they look at the critical components.
         MR. FAIR:  But they look at the critical components.  The
     GSI resolutions, again, are similar.  The factors applied at Calvert at
     the monitored locations, the stainless steel locations, which are the
     critical components as far as the factors go, and what Oconee did,
     because they're not actually monitoring specific locations were to apply
     these factors at the locations recommended in our NUREG 6260, and the
     way those factors are applied is just to divide the number of allowed
     cycles by that factor, and both have proposed either to implement these
     plant-specific programs or implement the resolution of GSI-190,
     whichever imposes the least restrictive requirements.
         DR. BONACA:  All right.
         MR. FAIR:  The last thing you all asked us to talk about and
     to give you an idea what the spectrum was was one-time inspections, and
     both Calvert Cliffs and Oconee are similar in that they use them for
     similar reasons to rule out the occurrence of aging effect.
         DR. POWERS:  That has to be the most amazing thing, to rule
     out that something is not occurring.
         DR. POWERS:  Does that mean is occurring?
         MR. SOLORIO:  Well, I guess there are reasons that they
     believe that there is a possibility they can't -- maybe the chemical
     environment would make it plausible or potentially plausible, but they
     haven't seen it before.  So therefore --
         DR. BONACA:  That doesn't belong there.
         MS. COFFIN:  Who wrote that?
         DR. APOSTOLAKIS:  Remind me please what ARDM is.
         MR. SOLORIO:  Age-related degradation mechanism.
         DR. APOSTOLAKIS:  Aging?
         MR. SOLORIO:  Age-related degradation mechanism.  I believe
     that's a --
         DR. APOSTOLAKIS:  And why is that different from an aging
         MR. SOLORIO:  Well, what I'm using is a Calvert Cliffs
     acronym, terminology, yes.
         DR. APOSTOLAKIS:  Is there a difference?
         MR. SOLORIO:  Remember, I'm the Calvert Cliffs guy, so I
     don't think in terms of Oconee as much.
         DR. POWERS:  It certainly reads like CASS speech.
         DR. APOSTOLAKIS:  So this will address the question what if
     something you don't know about is happening?
         MR. GRIMES:  Let me attempt --
         DR. APOSTOLAKIS:  No, that's what it does.
         MR. GRIMES:  Let me attempt to clarify, although I can't
     promise, but I'm going to try.
         MR. GRIMES:  These one-time inspections were intended where
     there was an aging effect that could not be completely dismissed, but
     it's not that we don't know it's happening.  We know it happens, but
     we're not certain whether or not it happens to the extent that it needs
     to be managed.
         DR. APOSTOLAKIS:  An example of that would be --
         MS. COFFIN:  A stainless steel valve body, because it's --
     it may have stagnant water in it, you know, a couple of days a year. 
     But it's ARDMs that are expected to be very minimal because the
     environment is generally very benign, or the design is very robust, but
     it is an ARDM that could occur, and it's something that they want to
     categorically rule out that it needs a full-blown aging management
         DR. POWERS:  There should be some ARDMs that are
     sufficiently remote that you don't ask for an inspection and others that
     are not so remote that you're afraid to go without an inspection.  I
     mean, there is a dividing line between the two.  Can you tell me how you
     decide that dividing line?
         MS. COFFIN:  I think a lot of it just comes down to
     engineering judgment, and in terms of Calvert Cliffs, I think they went
     above and beyond in terms of if they couldn't categorically rule
     something out, they put it in a one-time inspection, and I think they
     covered just about every ARDM known to a corrosion engineer.
         DR. POWERS:  In other words, their threshold, whatever it
     was --
         MS. COFFIN:  Was very low.
         DR. POWERS:  -- was low enough that it didn't cause you to
     ask them to specify it.
         MR. SOLORIO:  Also, I think through the many conversations
     I've had with the Calvert Cliffs people, there is a thing about, well,
     is this aging effect, it may be occurring, but is it really occurring
     such that we've got to worry about it?  And that is part of what the RD
     is doing now.
         DR. APOSTOLAKIS:  Help me feel a little bit better.  What if
     it is occurring, and 3 years from now we have to worry about it?  Don't
     we have programs in place that will alert us to that fact?
         MR. SOLORIO:  When you say programs --
         DR. APOSTOLAKIS:  Or something that will tell me that 3
     years down the line, I do have a problem, not now, 3 years.
         DR. SHACK:  I mean, you would only do this on components
     that you're not inspecting for some other reason.
         DR. APOSTOLAKIS:  And if they fail, what happens?
         MR. SOLORIO:  They have a site corrective action process
     that dispositions that.
         DR. APOSTOLAKIS:  I mean, I'm not in trouble if they fail,
     am I'
         DR. SHACK:  We're risk informed here.  We don't like water
     on the floor, George.
         DR. SHACK:  You know, whether the core melts or not, we
     don't like water on the floor.
         DR. APOSTOLAKIS:  No, no, how about the cornerstones?  I'll
     grant you the cornerstones.  I don't want an initiating event.  Now,
     some water on the floor, I don't know.
         DR. SHACK:  This is a barrier.  We don't degrade them.
         DR. BONACA:  But, you see, for mechanisms, like, for
     example, for the issue of fatigue, I mean, they have full programs. 
     These are, if you look at the details of them, really is unlikely that
     you have that phenomenon taking place, or if it does, it looks like for
     whatever they've seen, it's very superficial; it's not going to go
     there.  So that's why they justify the one-time inspection.  The bigger
     issue is what if you don't confirm, in fact, that your presumption?  And
     we discussed that before.  So the important thing is to have in place a
     change process that allows not only for the applicant to change his own
     program if he finds out that the RD in fact confirms that there is a
     problem but also for the staff to participate in reviewing it and
     accepting it.
         MR. GRIMES:  We wouldn't expect the staff to be involved in
     reviewing and accepting it.  Remember that this is -- these are aging
     effects for which there is no clear evidence that it is such a severe
     problem that it warrants a program to manage it over time.  These are
     ones that -- these are aging effects that we could not dismiss a priori. 
     And so, we have to say --
         DR. SHACK:  This conjecture is if your inspection in fact
     showed that it was much more severe than you expected for some whatever
         MR. GRIMES:  And in the event that this one-time inspection
     finds something sufficiently significant that like any other discovery
     of a nonconforming or degraded condition in the plant that affects an
     intended safety function, then, the quality assurance process says what
     is the problem?  What caused it?  What do I have to do to prevent its
     occurrence?  And it becomes self-correcting, and that's why the
     commission felt that license renewal could just focus on, you know,
     looking at aging management programs, but the regulatory process is
     going to continue to learn; going to continue to react; going to
     continue to improve programs as new knowledge comes forward, and so, we
     don't need to look for -- if you remember the 1991 version of the rule,
     it says identify all age-related degradation unique to license renewal.
         We said we can't do that.  We're not that smart.  We don't
     know what it is.  So this is simply a process piece that says, well, it
     may not; let's go look later.  If we find something, we'll fix it.
         DR. BONACA:  I'm not proposing that you have no regulation;
     and certainly, you have ways to disseminate the information, to send out
     bulletins or whatever now you send out.  I know there were changes
     there, too but --
         MR. GRIMES:  That raises an interesting corollary, and that
     is now, as we do generic communications, and we identify problems, and
     we try to decide, well, what do we need to do to fix them, we need to
     also consider that there will be renewed licenses out there that have
     aging management programs, and they need to be provided for as well.
         DR. BONACA:  I'm convinced that as we go into the extended
     period of operation, we will discover a lot of things, and so, that's
     why I think a lot of the questions we had today were focusing on that
     issue, on not only a corrective action program and the effectiveness of
     it but also some degree of involvement that the staff will have to have,
     and you're telling me that you feel that the current processes are
     adequate for you to get an involvement, and that's fine; okay.
         MR. SOLORIO:  I guess what we felt the major differences to
     be is kind of in their approach.  Calvert Cliffs kind of does it by, you
     know, by system.  They look at what they have already for managing aging
     and then come up with an additional one-time inspections where they
     don't have an existing program, and whereas Oconee apparently does it by
     material and aging effect, they just have a different way of running
     their aging management programs there.  So, they go off and look at
     piping in one fell swoop and then, wherever it be, or they don't have
     inspections; I believe they were coming up with more other -- where they
     didn't have existing programs, they came up with one-time inspections.
         DR. POWERS:  Both of these applicants have some reason for
     being very generous in which things they would inspect for.  The next,
     as people come down the pike later on, they're going to say gee, I don't
     want to do all of these inspections, because nobody ever finds
     everything to begin with, and it takes a lot of money, and so, I want to
     be less generous, in other words.
         How does he decide what things he should not inspect for and
     still have people comfortable?
         MS. COFFIN:  I think safety significance would come into
     play there in a big way, like the RV internal ARDIs or small bore piping
     inspections, that might be a way of deciding.  That's not a very easy
     question to answer.
         DR. POWERS:  I think it's one you're going to have to
         MS. COFFIN:  I think you're right.
         DR. POWERS:  Because the next guy down the line is just not
     going to want to do all these things.
         MR. GRIMES:  The question usually is posed to us from the
     other side of the fence in terms of are you going to preclude regulatory
     creep from thinking of more things, more one-time inspections.  As the
     staff gets smarter in terms of reviewing the programs, how do we know
     you're not going to expand the list and come up with even more things
     for us to have to inspect?
         And that gets back to capturing this experience in the SRP,
     developing guidance in terms of where we have seen one-time inspections. 
     Some utilities may decide that they want to -- well, in a number of
     cases, we saw where it might have been argued that the aging effect was
     not plausible or applicable and instead to just include it in a system
     walkdown or they expanded their procedure to basically consider this,
     too, as you're going along, because it really doesn't cost them
         So we're constantly, again, going to have to calibrate that
     point and say, you know, is this both the necessary and sufficient basis
     for --
         DR. SEALE:  Somebody is going to come at you with a risk
     informed aging inspection plan.
         MR. GRIMES:  That changes every time the IP is updated.
         DR. SEALE:  Yes.
         DR. POWERS:  I mean, that's the way things are.
         MR. GRIMES:  That's why we concentrate on process.
         DR. BONACA:  All right.
         Any other questions for the presenters?
         [No response.]
         DR. BONACA:  If not, I would like to thank all of the
     presenters here for the information you provided, and I would like to
     move on to the discussion of the Calvert Cliffs applications among the
     members.  I would like to go around the table and see if there are
     specific comments, and then, at the end of that, decide what we are
     going to ask the staff to present us --
         DR. APOSTOLAKIS:  Is the staff requesting a letter?
         DR. BONACA:  Yes, yes.
         DR. SHACK:  Yes.
         DR. BONACA:  The ACRS will be out.
         Let's first of all discuss what we would like to hear at the
     full committee meeting, okay?
         DR. BONACA:  What should we hear at the full committee
     meeting, first?
         DR. APOSTOLAKIS:  I don't want to see those tables again.
         DR. SEALE:  No.
         DR. BONACA:  You don't want to see the open items?
         DR. APOSTOLAKIS:  No.
         DR. BONACA:  Okay.
         DR. SEALE:  How long do we have?
         MR. DUDLEY:  I think an hour and a half.
         DR. APOSTOLAKIS:  No.
         DR. BONACA:  Okay.
         DR. SEALE:  How long do we have?
         MR. DUDLEY:  I think an hour and a half.
         DR. SHACK:  Well, everybody's here except John.
         DR. BONACA:  Two issues.  One, in October, we had a
     presentation on the generic issue list, okay?  Then, there may be a
     summary that would be valuable for the full committee.  It's not
     specific to the G&E application.
         MR. GRIMES:  That's all right.  I have to do one for the
     steering committee anyhow, and I can bring that.
         DR. BONACA:  Any suggestions?
         DR. POWERS:  I'm going here with a thought that the kind of
     presentation the committee needs is a statement of what are the aging
     issues at Calvert Cliffs, and what things will limit the amount of time
     that plant can run?
         DR. SHACK:  They're only worried about whether they can run
     60 years.
         DR. POWERS:  What I'm asking for is --
         DR. KRESS:  Those are only the replacement components that
     we have to project.
         DR. POWERS:  Yes; the replacement components, I assume, get
     replaced as they needed to.
         DR. KRESS:  They're talking about fatigue and embrittlement
     and -- I think it's a very limited number.
         DR. SIEBER:  And for Calvert Cliffs, remember, they've said
     they could replace the CASS components if necessary.
         DR. POWERS:  Something eventually limits this plant.
         DR. SEALE:  If it's unique to this plant that you might not
     find some other place.
         DR. APOSTOLAKIS:  What's the CDF again for this plant?
         DR. POWERS:  2 x 10-4.
         DR. SHACK:  Again, why do we need to know that if the
     decision is, you know, do you grant the license for 60 years, and the
     question is is it good for 60 years?
         DR. POWERS:  Because I'm sure they're going to ask gee, if
     it's good for 60, come back for 80.  Will it break in 61?
         MR. GRIMES:  We went through this philosophical problem when
     we amended the rule in 1995, and the answer that we give you in terms of
     what's going to limit the life of this plant is going to be when the
     economics say that the plant is no longer economically competitive.  It
     might still be just fine.  As a matter of fact, I think that Mr. Kadak
     is still annoyed that they say Yankee Rowe got shut down because of
     license renewal.  Yankee Rowe got shut down because they decided it
     wasn't going to be economically competitive, and we're going to say
     we've identified -- we've got this bit map of programs that manage aging
     effects, and we rely on these processes, and if something comes along,
     we don't know what might limit the life of the plant, because it might
     be something that we don't know about now.
         DR. APOSTOLAKIS:  So there is no --
         MR. GRIMES:  There is no life-limiting component here, save
     the PTS projections are currently at 48 effective full power years, as
     you pointed out.  If they change the fuel management strategy, you know,
     they might bump up into the criteria, but they bump into those criteria
     at some point in the future where they may have the option of replacing
     the vessel.
         DR. BONACA:  Although, again, I mean, the economics may be
     such that you have to do so many things to keep it up.  Why don't you
     keep --
         DR. POWERS:  I'm willing to speculate some, but I'm not
     willing to speculate too much.  I mean, it seems to me that I think we
     want to know, when we sign off on these things, we ought to know more
     than it will last for 60 years.
         DR. APOSTOLAKIS:  Is there any estimate of the remaining
     lifetime of the plant?
         DR. SHACK:  Well, I mean, it lasts for 60 years with margins
     that are acceptable.  I mean, it's not as though it lasts for 60 years
     and, you know, the vessel is going to turn into glass in 61.  You know,
     at 60 years, the PTS limit is still below the screening limit.
         DR. BONACA:  The presumption is all the regulatory margin is
     totally intact.  That's what it is at any time.
         DR. SIEBER:  I think it's even more liberal than that.  What
     you've done is say we're going to monitor and repair all of the active
     components, and now, we've set up an inspection program and a way to
     monitor the passive program.  Therefore -- components, excuse me -- and
     therefore, if we abide by the conditions of the license and all of these
     commitments, then, the public health and safety is assured, reasonably
         DR. UHRIG:  Presumably, it can run as well at 60 years as it
     did at 6.
         DR. SIEBER:  It should start at day one, and I think there
     was, at day one, some assumptions as to whether you needed to use back
     door or otherwise deal with passive components, but when you get to 40
     years, you want to assure yourself that there is -- there is margin or
     at least identify that you have to monitor beyond that point.  And so, I
     don't think how long it will last is a factor so much as is the degree
     of public health and safety preserved by what the license renewal has
         DR. POWERS:  But you have no measure of degree of public
     health and safety.  The question I have a measure
     on --
         DR. SIEBER:  There is a presumption, as we all know.
         DR. POWERS:  I want to know what limits the life of this
         DR. SHACK:  In what sense?  I mean, when will it stop
     meeting all of the regulatory requirements?  You know, when will it stop
     being economical?  What do you mean what limits the life of this plant?
         DR. BONACA:  The whole aging program is intended to maintain
     the regulatory margin.  Anytime you get close to where you think you are
     eroding it, we have to do something, which means you have to --
         DR. SIEBER:  Remediate.
         DR. BONACA:  Replace, yes, remediate; that's the right word.
         DR. KRESS:  I think it's when you quit meeting regulatory
     requirements, and I think those would be either the PTS requirements or
     the fatigue, one or the other.  It's going to be one of those two.
         DR. SIEBER:  You can remediate everything.  So it really
     comes down to money, you know.  Am I going to --
         DR. POWERS:  Without remediating, okay.  Obviously, that's
         DR. BONACA:  I think it is a good question in terms of --
     because, I mean, the more you look at it, we spend all the time looking
     at everything, okay?  But in reality, you are looking at some, you know,
     fatigue.  I mean, PTS issue on the vessel, a few elements which are
     global, and they are affecting the main components and may be the reason
     why probably the plant will be shut down at some point, because simply,
     you don't want to spend the money to remediate, okay, that component for
     that issue.
         So that would be probably some interesting perspective.
         DR. KRESS:  I think, Dana, it's probably interesting:  how
     close are we to some sort of cliff?  And, you know, if the PTS -- you
     bump up against PTS really in the year 61, it may not -- as opposed to
     year 70 or --
         DR. SEALE:  Seventy-five or 93 or whatever.
         DR. KRESS:  Because this is a process we've gone through,
     but we haven't evaluated any uncertainties.  Everything is supposed to
     be conservative in time, so you know there's margin there, you just
     don't know how much, because you haven't really evaluated.  So how much
     margin do you need?  I think it's an interesting question.
         DR. BONACA:  Yes, it is.
         DR. APOSTOLAKIS:  Put it in a different way:  even if I'm
     willing to live with a 2 x 10-4 core damage frequency now, are you
     guaranteeing to me that 20 years from now, it will still be 2 x 10-4?
         DR. SHACK:  That's different.
         DR. APOSTOLAKIS:  Why is it different?
         DR. SEALE:  In what sense, George?  That the plant has not
     changed, or the standard which we judge to be acceptable has changed?
         DR. APOSTOLAKIS:  No, the plant; is it still going to be 2 x
         DR. POWERS:  George, there's no question about this plant
     having any particular core damage frequency.
         DR. BONACA:  No, I understand that, but I think this is a
     different way of stating the same question.  Is it still going to be 2 x
     10-4, or is it going to go up?
         MR. GRIMES:  The presumption that we're operating under with
     the process is that it's going to be 2 x 10-4 or better in terms of
     we've got programs that are going to maintain the plant conditions,
     maintain the margins.  We've added to the current licensing basis; we've
     got a maintenance rule now that ties back important reliability values
     in that core damage frequency; you know, the fact that Calvert Cliffs is
     -- appears to be, you know, a collection of contributors as opposed to,
     you know, one or two things that we could whack on, I'm sure that
     they're going to continue to look at that in terms of there's a
     motivation here for the utility to understand the plant behavior well
     enough because they basically want to be able to say we're going to know
     when O&M costs are going to make us make this plant uneconomic.
         They don't want a cliff either.
         DR. BONACA:  No, I would raise the point, however, that in
     the success criteria in PRAs, wherever you have information on best
     estimate, you use that.  Then, we give you an example on containment,
     for example; containment, typically in design basis, the regulatory
     limit is the design of the containment, if there is any value, 50 psi.
         We, however, take credit for 120 psi or whatever, we believe
     it's, in fact, a realistic limit and now --
         DR. KRESS:  You think that limit might change with age.
         DR. BONACA:  It may change with age, okay?
         DR. KRESS:  So the risk status is changing.
         DR. BONACA:  That's right; I mean, it may.  It may.
         DR. KRESS:  You're managing it.
         DR. BONACA:  That's right; so you're maintaining the
     regulatory margin of the 50 psi, and you're not going to bump into it. 
     You're far from it, but you're eating some of the margin outside of
         MR. GRIMES:  The same uncertainty about, you know, what the
     behavior of the containment is going to be under design basis and severe
     accident conditions is still going to be there.  We would hope that that
     knowledge base is going to continue to grow, and it is the uncertainty
     in LERF, not necessarily make it larger but, you know, time will tell,
     and the more that we learn about how much margin or how much certainty
     or uncertainty there are in the best estimate values, we would expect
     are going to continue to improve our understanding.
         That's why we try to focus on the processes for
     understanding what the plant conditions are and performing remediation
     so that in parallel, the reduction in uncertainty about what really
     contributes to risk is going to help to better manage the plant
         DR. KRESS:  I think in principle, you're right, but where I
     come from, it's fatigue and so on are the primary packing system.  But
     you can't really do it to the extent that you are going to reduce the
     uncertainties very much, and as time goes on, I'm sure the probability
     of initiating frequency of the loca is interest.
         DR. SHACK:  The delta is probably within the 1174 limits.
         DR. KRESS:  It's probably pretty dog gone low.  That's the
     point, and that's the point which he's making, and as long as you stay
     within the licensing renewal process of inspecting and looking and
     calculating how much it can be, as long as you do that correctly, you're
     probably staying within limits.
         DR. BONACA:  The regulation may keep the margin -- no
     difference between 55 years and 55 years, because for some components,
     you have studies.  You're remediating, and you have some other
     component-like vessel, it's a different story.  Sitting there, you're
     not mitigating anything and monitoring its aging.
         DR. APOSTOLAKIS:  As I recall, in rule 54, 50.54, says that
     the applicant must demonstrate that the current levels of safety are
         DR. SHACK:  For current licensing basis.
         DR. APOSTOLAKIS:  No, safety levels.  There is a safety
     there, no?
         DR. KRESS:  Does it say that?
         DR. APOSTOLAKIS:  Yes.  Get your book.  And I have three
     experts here telling me that the frequency of the loca increases.
         DR. BONACA:  So there is a presumption here of adequate
         DR. KRESS:  It's a range.
         DR. BONACA:  Did we get 50.54?
         MR. GRIMES:  Part 54?
         DR. POWERS:  Should the loca -- should the loca occur, and
     the plant survives a loca; that's how they're designed.
         DR. APOSTOLAKIS:  Yes, but the current level of safety is
     not maintained.
         DR. POWERS:  No.  It's the ability to survive a loca.
         DR. APOSTOLAKIS:  That's one interpretation of safety.
         DR. POWERS:  But it happens to be one that figures strongly
     in our regulations.
         MR. GRIMES:  I know that there is somewhere in part 54, the
     statements of consideration all talk to safety level, and I will tell
     you our safety evaluation was geared toward developing the finding in
     54.29 that says actions had been or will be taken to ensure that the
     aging effects for -- and then, it refers back to scope -- to maintain
     their plant safety, safety level.
         We've used the safety benchmark that we're using is
     consistent with the current licensing basis.
         DR. APOSTOLAKIS:  The words are slightly different.  There
     is one sentence that's a full paragraph, and it reads as follows: 
     structures and components will be managed to maintain the CLB such that
     there is an acceptable level of safety during the period of extended
     operation, not the same.
         DR. KRESS:  Exactly.
         DR. SHACK:  You would never write a law that says you
     maintain the same.
         DR. APOSTOLAKIS:  Why not?  And now, you have a question of
     what's acceptable; come on.  If you really want to --
         DR. SHACK:  George, you don't write it because you're always
     aware of some guy like you coming along and measuring it.  And if you
     measure it to what it should be --
         DR. APOSTOLAKIS:  Well, I mean, if it says an acceptable
     level of safety, and the definition of acceptable is what we say is
     safe, then it's fine.  Now, if you say you have to have 54.29 with the
     standards of issuance of a renewed license --
         MR. GRIMES:  The whole focus of the safety evaluation is
     getting to that conclusion.
         DR. BONACA:  Do you have enough there?
         DR. SHACK:  Eventually, the thing that you will no longer be
     able to meet is probably the vessel.
         DR. APOSTOLAKIS:  The vessel is eventually --
         DR. SHACK:  Eventually, yes, sooner or later.
         DR. APOSTOLAKIS:  Don't say words like that.
         DR. SHACK:  Well, I mean, I can even project it.
         DR. APOSTOLAKIS:  Can you project it?
         DR. SHACK:  I mean, I don't know what it is.
         DR. APOSTOLAKIS:  Can you project it?
         DR. SHACK:  Well, yes, I can project it.
         DR. APOSTOLAKIS:  Give me an idea.
         DR. SIEBER:  It can be a margin.
         DR. APOSTOLAKIS:  Okay; well, give me a margin.  Everything
     has been the same.
         DR. SHACK:  I mean, you know, they met it for 60 years.  My
     guess is, you know, I can't even remember what the margin was at Calvert
     Cliffs when they got the 60 years, but they hadn't hit the screening
     limit.  The had -- yes, Oconee was a lot tighter, I think, so, you know,
     they're out some years beyond 60.  I would have to go back, but, I mean,
     it's a pencil and paper --
         DR. APOSTOLAKIS:  Some years means 5, 10?
         DR. POWERS:  You keep asking the question that I proposed
     that we ask, but you didn't want to hear that.
         DR. APOSTOLAKIS:  I did what?
         DR. POWERS:  You keep asking the same question that I asked
     them to talk about.
         DR. APOSTOLAKIS:  Yes; we're getting closer to an answer.
         DR. SHACK:  We can answer that question.  I just don't know
     once you get the answer, what are you going to do with it?
         DR. APOSTOLAKIS:  Well, I will feel better.  Dana's question
     was what?  Sixty-one?
         DR. SHACK:  If it's 61, and I hit the screening limit, I'm
     not exactly going to break into a cold sweat.
         DR. SIEBER:  The question is --
         DR. KRESS:  One of the Oconee units is very close.
         DR. SIEBER:  -- along with the NRC, which is what you're
     really asking.
         DR. KRESS:  If it hits in the 59, are you going to stop the
     -- and do it, do the calculation.
         MR. GRIMES:  The true answer that I would give you if I were
     trying to answer that question is I would say, well, there is a majority
     of folks who believe that the vessel is the limiting component, and it's
     either going to be a little before 60 if they change their fuel
     management strategy and don't take remediation, or it's going to be a
     little bit after 60, because there is still some margin in the
     calculations, and as you go through time, they will work that out
     without remediation, unless there are some other components that we are
     not monitoring as closely that is going to get caught by all of these
     inspection practices and turn out to be the economic factor that drives
     a decision to shut the plant down prematurely.
         That's our answer.  We always look to the vessel as being
     the limiting feature, and that's where there's a lot of focus on that,
     but there could be a structural element where it just becomes too
     expensive to repair or replace.
         DR. SHACK:  They thought they had the flux problem before,
     and all of a sudden, they thought the vessel supports were going to be
         MR. GRIMES:  I remember when they thought that the
     resolution of one of the generic safety issues was basically going to
     make the pads the vessel sits on the limiting component because of the
     dynamic forces associated with the flow around the vessel.  So, you
     know, anything that we would say about what is life-limiting for the
     plant is going to start with a, well, whenever it becomes economically
     infeasible or economically uncompetitive, and it's going to end with
     probably the vessel but maybe something else, and that's about all we
     could say, but then, we would turn back to but the commission's rules in
     Part 54 look to a process of managing the plant so that you'll know how
     to decide and when to decide.
         I remember when we were first putting together the standard
     review plan in 1975, and there were people saying, well, you know, don't
     spend a lot of time being concerned about repair criteria for steam
     generators, because nobody is ever going to replace one.  God knows what
     the economics would do in a deregulated environment.
         DR. BONACA:  Let me propose, by the way, first of all, there
     is already a request here from Dana, and I think that's a good one, you
     know, to talk about aging issues at Calvert Cliffs and the limiting
     issues, but I also would like to hear about one-time inspections, just
     because even to look at some of the examples so that we could get a
     better feeling for, you know, these criteria that we discussed that are,
     you know, you do a one-time inspection where you don't believe you're
     going to find something, okay?
         Or the other thing I would like to hear about is describe
     the process a little bit that you're having in place or already in place
     to assure that commitments are being met and also that changes
     identified by the plant or discovered, I would say, allows for the NRC
     involvement.  At least we understand what these processes are, I mean,
     you seem to be very aware of those.  I would like also to hear, if it's
     possible, why the guidance -- and you don't have to spend a lot of time
     on that but the current guidance of 50.59 doesn't really seem to be
     adequate to address this new, you know, license renewal phase.
         One question that I asked before about ASME's Section 11
     ISI, the frequency 10-year periodicity, I mean, nobody may have that
     answer to that question.  So, maybe it still puzzles me.
         DR. KRESS:  The technical basis?
         DR. BONACA:  Yes; except it is a nice even number.  You
     know, 20 was too much, and 10 is better than 20.  I mean, I could bet
     you that there is some of that when the interval was --
         DR. SHACK:  Well, you also have to remember, though, that
     when they have an inspection for cause, the intervals are really set on
     a much more rigorous basis.  I mean, you know, if you have an
     erosion-corrosion program, it's not every 10 years; it's because you
     know -- but the every 10 years is almost let's just go out and look at
     this piping; we don't think there's anything wrong with it --
         DR. BONACA:  Okay.
         DR. SHACK:  -- but we're just going to keep looking at it
     anyway just in case we're wrong and so --
         DR. BONACA:  You're saying that there is a criterion or
     process within the ASME to accelerate --
         DR. SHACK:  Yes; I think wherever they've really identified
     a true cause and a true degradation mode, there's typically an augmented
     inspection program that, you know, doesn't rely on an arbitrary
     selection of time.  It's really much more mechanistically driven.
         MR. GRIMES:  The same is true with the surveillance
     requirements and technical specifications.  They started off with some
     arbitrary time frames that were established on the basis of well, we can
     check these each refueling outage; you want to check this stuff sort of
     on a quarterly basis.
         But where the surveillance results have identified a need,
     for example, two decades worth of studies on diesel generators to
     establish just the right frequency, you know, not too much, not too
     little for testing diesel generators, so that's generally what we find
     in in-service inspection and other practices as well.  We find that
     these surveillance programs start off with a, you know, this looks like
     a good frequency and then adjust itself.  It's self-correcting.
         DR. BONACA:  Okay; I think we heard about -- I'm sorry.
         DR. APOSTOLAKIS:  One last chance here.
         DR. BONACA:  Yes.
         DR. APOSTOLAKIS:  The core damage frequency is 2 x 10-4, and
     that has excluded passive components, which is typically done in PRAs,
     right?  PRAs, usually, we don't include them.
         For the next, I mean, 20 years beyond the 40 year license,
     will I be justified in ignoring the passive components and still say
     that it's 2 x 10-4?
         DR. KRESS:  I think the answer is yes, because the PTS rule
     is designed to keep that from -- it's 10-6.  Now, even if you buck up on
     this, and I think it's even less for the T, it's even less than that.
         DR. APOSTOLAKIS:  Okay; so --
         DR. KRESS:  So I think even though you're bucking up against
     the limits, you're still not adding a significant amount to the 10-4 for
     those two components.
         DR. SEALE:  That's what the process is trying to assure you
         DR. APOSTOLAKIS:  Well, I don't know.  It could be a 59
     here; it could be 65.
         DR. SEALE:  Well, yes, but the caveats were there, too.
         DR. BONACA:  All right; okay.  Do we need to hear about
         DR. SEALE:  We're going to hear about that separately.
         MR. GRIMES:  Yes, you're going to hear about that on
     December 3.
         DR. BONACA:  All right.
         MR. GRIMES:  Mr. Wesman and Mr. Wichman kept getting real
     nervous when --
         DR. BONACA:  Yes; and I am satisfied for what Calvert Cliffs
     is doing.  I mean, I like what they're doing about that.  And by the
     way, is that factor a 1.5, the one that accounts for the fatigue
     specific, the environmental -- I notice in the open item closure that
     they're saying that the criterion is multiplied by a factor of 1.5. 
     Anyway, I don't want to go into details.  That's probably what -- what
     the adjustment is, just to reflect this closure on GSI-190.
         Have we given you enough to present?
         MR. GRIMES:  Oh, yes.
         MR. GRIMES:  Definitely 2 hours with the dialogue.
         MR. GRIMES:  And also, and I will ask BG&E to be prepared to
     speak to the question about what is life-limiting and the commitment
     management process from BG&E's end, and the NRC staff will talk about
     commitment management CRB maintenance from our perspective.
         DR. SEALE:  Very good.
         DR. BONACA:  Any other issues that --
         DR. APOSTOLAKIS:  Did we ever get that summary of the BG&E
     PRA?  I remember vaguely we did.  But we don't have that full PRA, do
         MR. DUDLEY:  Yes.
         DR. APOSTOLAKIS:  Do we have the full PRA?
         MR. DUDLEY:  Yes, we do.
         DR. APOSTOLAKIS:  Oh, we do?
         MR. DUDLEY:  I think we do, yes.
         DR. APOSTOLAKIS:  Was it submitted as an IPE?  Yes; the
     summary, I know we got, but how about the full PRA?
         MR. DUDLEY:  The staff has it.
         DR. APOSTOLAKIS:  The staff has it?
         MR. DOROSHUK:  My name is from Barth Doroshuk from
     Constellation Nuclear, and I'm on the Calvert Cliffs license renewal
         DR. BONACA:  Let me go around the table a moment now and see
     is there any other issue that we have not discussed that we want to
     raise for inclusion in a draft letter?  I'm trying to put together a
     letter at some point.  We discussed the one-time inspections; processes
     to get the NRC involvement and to change this; we talked about
     environmentally-assisted fatigue effects, closure; GSI-190; and as the
     meeting, I would like to put a recommendation that we would like the
     program that they have in place, the plant-specific one.
         We adopt the interim update of the LRP; I mean, clearly, the
     standard review plan that they're doing it now.
         DR. SEALE:  Yes.
         DR. BONACA:  And then, the issue of guidance for determining
     SSCs for plants with a risk-informed CMP.  That's a different thing, and
     we will want to include that in the letter for Calvert Cliffs.
         Any other issues that you would like to consider for
     inclusion in the letter for Calvert Cliffs?
         DR. UHRIG:  We're not going to deal at all with the active
     components?  That's already taken care of?
         DR. BONACA:  That's right, active components, yes.
         DR. SEALE:  It's maintenance.
         DR. UHRIG:  I was wondering specifically about cables. 
     There was some discussion of that originally.
         MR. GRIMES:  We have cables in the safety evaluation report,
     not dynamically but from the standpoint of reliance on the environmental
     qualification process.
         DR. BONACA:  We will have an opportunity anyway, you know,
     after the presentation on December 3 to raise other issues if you would
     like to bring them up.  What I would like to do after the meeting is
     make a copy of these three pages where I have some of these issues and
     distribute them to you and please add whatever you feel you would like
     to add.
         DR. APOSTOLAKIS:  Are you going to send the draft of your
     letter before we come here in December via email?
         DR. BONACA:  What I would like to do tomorrow morning,
     tomorrow at some point, Bob and I are going to sit down and try to draft
     a letter.
         DR. APOSTOLAKIS:  So you will send it beforehand?
         DR. BONACA:  Yes, definitely.  Some of the issues are here
     in these three pages, okay?  They have to be rewritten somewhat but --
         DR. APOSTOLAKIS:  I would like to see that letter.  I mean,
     if you guys want to do it tomorrow, then, great.
         DR. BONACA:  Well, you know, we are debating here, because
     we are so anxious to hear about ATHEANA that, you know, we don't want to
         DR. BONACA:  -- take time out of that.  I'm not kidding
     about that.
         So it will come out sometime.  Okay.
         DR. KRESS:  Is this the last letter we're going to write on
     the Calvert Cliffs?
         DR. BONACA:  Huh?
         DR. KRESS:  Is this the last letter, the final one?
         DR. BONACA:  Yes; we are not writing any other letters.
         DR. KRESS:  My advice is not to muck it up with a lot of
     issues --
         DR. BONACA:  That's right, no, no; in fact, as I mentioned
         DR. KRESS:  You might want to write another letter to the
     commission saying here are some things to think about that you might not
     have -- I'd keep the Calvert Cliffs letter --
         DR. SEALE:  Crisp.
         MR. GRIMES:  I'd point out that it is our intent that the
     letter that you send will be incorporated into the safety evaluation
         DR. KRESS:  Just make that crisp and to the point.
         DR. BONACA:  All right; good.
         Okay; with that, if there are no other comments, I think we
     will adjourn the meeting.  Any other comments?  No?
         [Whereupon, at 4:31 p.m., the meeting was concluded.]

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