Plant License Renewal - November 18, 1999
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
MEETING: PLANT LICENSE RENEWAL
Conference Room 28-1
Two White Flint North
11545 Rockville Pike
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
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
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
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
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
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
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
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
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
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
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
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
DR. POWERS: It depends on whether they did it by entering
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
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
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
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
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
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
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
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.
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
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
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
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
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
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
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
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
MR. SOLORIO: But I didn't think the court was talking about
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
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
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
DR. POWERS: It just seems to me that it would be terrific
if you could approach the -- one of the journals devoted to corrosion
MR. GRIMES: This is really -- I mean, if you've got NACE,
then, I mean, certainly, they should be -- the National Association of
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
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
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
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
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
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
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,
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?
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
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
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
DR. BONACA: Okay; do you want to -- okay, any more
questions on this?
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
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,
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
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
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?
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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.]
Page Last Reviewed/Updated Tuesday, July 12, 2016