Plant License Renewal - October 19, 2000
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
SUBCOMMITTEE ON PLANT LICENSE RENEWAL
Thursday, October 19, 2000
11545 Rockville Pike
. P R O C E E D I N G S
CHAIRMAN BONACA: The meeting will now come to
order. This is the first day of the meeting of the ACRS
Subcommittee on Plant License Renewal.
I am Mario Bonaca, Chairman of the subcommittee.
ACRS members in attendance are Vice Chairman Robert Seale,
Thomas Kress, Graham Leitch, John Sieber, William Shack, and
The purpose of this meeting is for the
subcommittee to hear presentations by the staff and the
Nuclear Energy Institute concerning drafts of the standard
review plan for license renewal, the generic aging lessons
learned report, the draft regulatory guide DG-1104, standard
format and content for applications to renew nuclear power
plant operating licenses, and NEI-95-10, Revision 2,
industry guideline for implementing the requirements of 10
CFR Part 54, the license renewal rule.
The subcommittee will gather information, analyze
relevant issues and facts, and formulate proposed positions
and actions, as appropriate, for deliberation by the full
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 4,
A transcript of this meeting is being kept and
will be made available as stated in the Federal Register
notice. It is requested that speakers first identify
themselves and speak with sufficient clarity and volume so
that they can be readily heard.
We have received no written comments or requests
for time to make oral statements from members of the public.
The ACRS reviewed and commented on the staff's
review of two license renewal applications. The staff
presented the ACRS with an overview of the draft guidance
documents during the August 29-September 1, 2000 ACRS
We discussed the draft guidance document at the
October 5 and 7, 2000 ACRS meeting, and provided the staff
with an outline of our concern.
Today we will hear a more detailed presentation
regarding the guidance documents. We also provided the
staff, in the past, with a set of criteria that the ACRS
will focus its review on and, hopefully, in the course of
the two days, we will hear about the perspective of the
staff on those seven criteria that we set.
With that, we will now proceed with the meeting
and I call upon Christopher Grimes, Chief of the License
Renewal and standardization Branch, to begin.
MR. GRIMES: Thank you, Dr. Bonaca. I would like
to start off by noting that we're still in the process of
assembling the public comments, including the industry
comments and comments from the Union of Concerned Scientists
on the proposed guidance.
We've had a substantial amount of general public
opposition in nuclear power comments that arose from a
misrepresentation of what this action represented in some
media coverage in California.
But we need to sort all those comments out in
preparation for a Commission meeting on December 4 and as we
get the comments assembled, we'll share that with the ACRS,
The presentation that the staff is going to
proceed with today will focus primarily on the exchange that
we had with the NEI license renewal task force on the
original issuance of the guidance last December, when we
held our first workshop, and we also had the benefit of a
subsequent workshop that was held on September the 25th and
to the extent that we got feedback during that workshop,
we'll share that information with the subcommittee, as well.
I'm going to begin by introducing Dr. P.T. Kuo, at
my right, who is the Section Chief who has led this effort,
and Dr. Sam Lee, who has been the Team Leader who has
admirably mustered the forces of the staff to work an
extremely aggressive schedule to pull together credit for
existing programs in a way that we can share that with the
Commission in December.
With that, I'll turn the meeting over to Dr. Lee.
MR. LEE: Good morning. My name is Sam Lee. I'm
from the License Renewal and Standardization Branch, NRR.
In your handout is the agenda for today and then
we have the second pages for tomorrow. And like Chris
Grimes indicated, this effort on the improved license
renewal guidance document has been a significant agency
effort. It involved NRR staff doing the license renewal
reviews, and, also, the Office of Research and Brookhaven
and Argonne National Labs as contractors.
And today and tomorrow, many of them will be here
to make a presentation and answer your questions.
As an introduction we issued four documents in
August for public comment. The comment period ended October
16 and, like Chris indicated, we are still in the process of
sorting out the comments, and the four documents are the
generic aging lessons learned report, the GALL report, the
standard review plan, the SRP, the reg guide, and the NEI
industry document 95-10.
As background, why we embarked on this effort,
during the review of the initial license renewal
applications, both the NRC and industry recognized that many
of the license renewal programs are existing programs.
So NEI submitted a letter characterizing this
issue as credit for existing programs. As a result, we
prepared a SECY paper, 99-148, with options and
recommendations for the Commission to consider to improve
the efficiency of the license renewal process.
As a result, the Commission, through a staff
requirements memorandum, directed the staff to prepare the
GALL report that would document the basis for the acceptance
of the aging management program, and to prepare an SRP that
will reference the GALL report and then focus the staff
review in areas where existing programs would be augmented.
And we are to prepare these documents with
stakeholder involvement and to brief the Commission on
public comments received, and we are to provide these
documents to the Commission for final approval.
And after we have additional review experience
with license renewal applications, we are to return to the
Commission with recommendations for any need for rulemaking
to further enhance the license renewal process.
The GALL report is the technical basis document
for the SRP. The SRP provides the guidance for the staff to
do a review of license renewal applications. The reg guide
endorses, proposes to endorse NEI-95-10, which provides
guidance to an applicant to prepare a license renewal
And we have involved stakeholders early on, as
Chris indicated. Back in last December, we provided an
early draft of the GALL report in a workshop and, subsequent
to that, we also provided an early draft of the SRP to the
NEI provided significant comments on these
documents. As a result, we've held many public meetings
with NEI to discuss their comments and you will hear the --
today and tomorrow, you will hear some of the NEI comments.
And let me say, NEI comments today and tomorrow,
those are comments before August. We haven't sought out the
NEI comments as a result of this public comment period.
And we also received five reports from the Union of
Concerned Scientists, five technical reports, and we have
considered them in the GALL report, and you will hear about
that later on in the presentation today.
DR. SHACK: Sam, those public comments, are they
available on the web site in raw form?
MR. LEE: They are not on the web site. It's like
a foot of paper, and they are in ADAMS, if you can find it.
MR. GRIMES: We will offer to extract them from
ADAMS for you, if you'd like us to get the raw comments for
DR. SHACK: I wanted a sample of the comments.
MR. LEE: Just information, I guess. We counted
about 700 comments from NEI. So it's quite a bit of
comment. And like Chris indicated, we just had a workshop
last month and at that workshop, we discussed tests. We had
that during the public comment period and some of the issues
we discussed are like the format.
The GALL report now has a rather cumbersome page
format. You have two pages, you have to line things up and
if you put it on the web, you only see one side, you can't
see the other side. So it's very difficult to, I guess,
So one of the topics discussed at the workshop was
can we condense this table into a one-page format, still
retain the information, just a format change. And some of
the issues discussed are like are there alternative programs
that are equally acceptable in GALL for older plants versus
So the things that we have to consider. So that
was a pretty helpful workshop. And these documents are
supposed to be consistent with each other, the GALL, the
SRP, Reg Guide 95-10, but because GALL and SRP were
evolving, NEI intends to make further changes to 95-10 to
MR. GRIMES: Sam, if I could add to that. There
was an NEI license renewal workshop earlier this week,
second annual event, where they gather together the primary
industry groups that are interested in pursuing license
renewal and a main theme that came out from the feedback
that we got during that workshop is that the industry
believes that there is room for further integration of the
standard review plan and GALL and opportunities to make the
And the concern that they expressed is that the
guidance is developed largely based on newer plant designs
and FSARs and they wonder whether the guidance would be as
useful for pre-GDC plants, where the older plant designs
don't have the same level of detail or program description
in their licensing bases.
So that's going to be a major challenge for us in
resolving the comments, is a means to make GALL and the
standard review plan even more consistent and integrated and
applicable to the whole fleet of plants across the country.
MR. LEE: Here is the schedule that we are on.
Like Chris indicated, this is a very aggressive schedule.
We issued these documents in August, as originally
scheduled. We have a workshop and we are here briefing the
ACRS and we are scheduled to provide a Commission briefing
on the public comments received on December the 4th. That's
the latest date we have now.
And we have to provide the document for Commission
final approval March of 2001, and July 2001, we are to
provide recommendations to the Commission for any need for
rulemaking to further enhance the license renewal process.
DR. SHACK: Do you have any tentative thoughts on
MR. LEE: We have discussion with NEI. The
industry is leaning against changing the rule. From the
staff point of view, we think the rule is working fine,
also. So the tendency now is not to change the rule.
To change the topic. Back in 1997, we made a
draft SRP publicly available. That is the 1997 timeframe.
The NEI provided significant comments on that and those
comments have raised some new issues. There are like a
hundred of them. And since then, we have license renewal
applications, we have granted licenses, we have reviewed and
approved topical reports on license renewal, and we have
given credit for the system program issue, we have the
Commission decision on GALL, and basically a complete
rewrite of the SRP.
Because all these activities, the GALL and SRP
envelope all these license renewal issues, that's our
feeling and NEI and the industry agree and the strategy is
now not to further pursue the license renewal issue by
itself, but the public comment on GALL and SRP, and if they
think the issues are still not satisfied, are not resolved,
they can provide comment during the public comment period on
GALL and SRP.
But for today and tomorrow, we have grouped the
license renewal issues by chapters of GALL and SRP and
pointed out where they might be linked. So if have any
question on them, feel free to ask questions.
And some of these license renewal issues doesn't
fit particular chapters of GALL and SRP, so I list them
here. And these two are basically the credit for existing
program issue that result in GALL and the complete rewrite
of the SRP, and the inspection activity issue, since 1997,
we have now written inspection procedures, so they'll
And since 1997, we have reached agreement with NEI
on the standard format of an application and the SRP
actually is consistent with that format. So that addressed
MR. LEITCH: I have a question about that. There
were, I guess, order of magnitude about 104 or 106 license
renewal issues inventory and I guess 12 of those or so were
resolved by specific letters.
These are the ones that are still outstanding, I
take it, and I guess -- and the remainder, were they
generally incorporated into a later revision of the standard
review plan or how were they dispositioned?
MR. LEE: In this complete rewrite of the standard
review plan and the GALL, these issues are addressed, to
some extent, and some of these are not even applicable
anymore. Like inconsistencies in the SRP, we just rewrote
the SRP. So the inconsistencies pointed out in the SRP
doesn't apply anymore.
So some of these don't apply anymore, and most of
these were addressed. The GALL and SRP captures the lessons
we learned in the license renewal application review.
So we actually touched upon most of these. So
that experience has been captured in GALL and SRP. The
public might not be satisfied with the way we address it, so
they can provide comments through the comment period.
For the 12 or so that you indicate, we have
actually a lot of letters from NEI that says this is the
best solution. They have been incorporated in the GALL and
SRP, except for one, I think, and we actually sent a letter
to NEI to ask them to incorporate that into 95-10 and we
also incorporate it in the SRP.
MR. GRIMES: Sam, I have the benefit of Mr.
Konig's files that we brought with us. In a letter to the
NEI and USC on May 4 of 2000, we provided a disposition of
the license renewal inventory that explained that we were
going to address a number of the issues in GALL.
We ended up with, out of the 106 issues, there
were five that were dropped. There were 11 that were
resolved. Of the remaining open items, 37 were addressed in
GALL, 12 were addressed in the revision to the standard
NEI addressed 25 of them in their comments and that left
eight active issues that we're continuing to work.
MR. LEITCH: Thank you.
DR. SHACK: Sam, are you going to talk about how
the Option 2/Option 3 special treatment requirements could
affect license renewal?
MR. LEE: That's Chris'.
MR. GRIMES: No, we weren't prepared to explain
how the Option 2/Option 3 approaches might fit into license
renewal. I will say that I've had a number of conversations
with Mr. Strosnider and Mr. Wessman about different
approaches that we could take and right now we're looking at
whether or not there's a corresponding scope change for
license renewal which would require rulemaking or whether or
not we would bifurcate the treatment of aging management
programs to credit -- I believe it's Appendix T is the
special treatment provision for non-risk-significant.
DR. SHACK: That's the binning criterion.
MR. GRIMES: Right. But the binning criteria
would also, as we understand it, at this point, have some
general expectations about what treatment would consist of
and then we would have to address how that treatment
constitutes an aging management program under Part 54.
So we're working very closely with the
risk-informed licensing group to make sure that we end up
with a consistent approach of license renewal.
DR. SHACK: I guess my question is, do you think
it will take a rule change or is it something that can be
accommodated with the scope of the existing rule.
MR. GRIMES: If we credit special treatment for
aging management, I think that we can accommodate it under
the existing rule. But at this point, I think it's too
early to tell and so I wouldn't foreclose the possibility
that there might be a corresponding rule change, even if we
have this bifurcated aging management treatment.
MR. LEE: I'm going to start talking about the
SRP, this is the introduction to SRP. We have just been
assigned a NUREG number. It will be called NUREG-1800, and,
as indicated before, it references the GALL as a technical
basis document for evaluation of aging management program
and it focuses the staff in areas where programs should be
augmented and incorporates the lessons learned from the
initial license renewal reviews, topical report reviews,
and, also, license renewal issues, and, as discussed before,
it uses the standard format agreed upon with NEI.
Another thing is this SRP also follows the
NUREG-0800 style, areas of review, acceptance criteria,
review procedures, findings. So the staff should be
familiar with that style.
This is the table of contents of the SRP. It
follows the rule requirements. Chapter 1 is on
administrative information. Chapter 2 is on scoping and
screening to identify structures and components that are
subject to license renewal requirements.
Chapter 3 is on aging management review. That is
where the GALL information would fit in. Chapter 4 is on
time-limited aging analysis. Then we have some branch
technical positions, and we will go through this in the
Are there questions? If not, I'll turn it over to
Dr. Mitra to start the presentation on Chapter 2.
MR. MITRA: Good morning. My name is Eskay Mitra,
Eskay like hotdog, Eskay Actually, my name is too long and
people doesn't pronounce right. So I reduced this to Eskay
I lead the license renewal technical staff, who have
accumulated the scoping and screening methodology and the
result of Chapter 2 of SRP.
With me, my colleague, Juan Peralta and Chris
Gratton, and they have significant contribution of writing
As Sam already spoke, that we have quite a number
of comments from NEI and we only picked some significant
ones to discuss here, and we'll try to explain the comments
as much as we can.
The first comments are that reviewers should focus
on verifying applicants' as-implemented and acceptable
scoping methodology rather than verifying no omission of
structures and components subject to aging management
On this comment, actually, staff concurred and
added a sentence as recommended by NEI, saying to verify
that the applicant has properly implemented its methodology.
The staff reviews the implementation, resolves separately
following the guidance in the Section 2.2 through 2.5 of the
standard review plan.
Actually, during the review of both Section 2.2
and 2.5, to come to a reasonable assurance of finding, the
staff should find no omission of structure and component
identified by the applicant as subject to aging management
DR. LEITCH: Eskay, just one question, for
clarification. Are these NEI comments on the draft of
August 2000 or are they comments on an earlier draft?
MR. MITRA: These are the draft -- these are
accumulation of earlier draft and some of them on August
MR. LEE: This is April 2000.
DR. LEITCH: So these comments have already been
incorporated in the draft that we have in front of us of
MR. MITRA: Yes, some of them, and whichever is
not, I will tell you.
DR. LEITCH: Very good. Thank you.
MR. MITRA: The first one, as I said, was
DR. KRESS: The objective of an NRC review is to
verify no omission of structures and components. So why are
they objecting to you doing that? Is it because it would
take too much of their time and your time and that's not
really practical to do that? I don't understand the
MR. PERALTA: Good morning. My name is Juan
Peralta, NRR staff. The issue was not that we were not to
look for no omissions. It's just that the language in the
introduction appeared to indicate that we were looking for
to demonstrate the absence or to prove the negative, which
is a matter of semantics in the text. It wasn't anything
technical, per se.
DR. KRESS: I see.
MR. PERALTA: It was just a matter of
DR. KRESS: Okay.
CHAIRMAN BONACA: I still had a comment on this
issue. A general comment I have, even reviewing the current
SRP, is that the scoping and screening methodology is still
a patchwork of efforts to identify what is and what is not
in the current licensing basis.
I don't see that there is a recipe that is so
clear-cut, if you follow it, you identify everything. I do
believe that the experience that you had with Oconee, for
example, it will be still repeated for almost any older
plants out there, whereby they will come in with a certain
core licensing basis, you will begin to ask questions of why
does the high energy line break, doesn't belong into the
current licensing basis. They will take a certain position,
you will take another one, and then there will be some
Because of that, I just don't understand the
thrust of this comment, and I don't see why -- because if
there was, again, a clear-cut methodology that you can
follow, then I would agree with this comment. Otherwise, I
just don't understand it.
MR. PERALTA: I personally don't think that we're
ever going to see -- well, hopefully -- another review like
One of the reasons why the SRP doesn't provide a
cookbook approach is because we need to remain flexible to
different licensing bases. That's one of the reasons why we
do an on-site review and we go through a very detailed
review of all licensing basis documents on-site.
So I don't think you'd be able to come up with a
very fixed algorithm that you can go through and fit every
licensing basis into that.
CHAIRMAN BONACA: Okay. I understand that.
MR. PERALTA: There has to be some room to
maneuver. There may be cases where there are some
discussions or arguments back and forth, but in every
instance, we'll have to find what is the conclusive
licensing basis for each facility.
CHAIRMAN BONACA: Let me ask you a question. Are
you going to talk specifically about the scoping methodology
that you have in the SRP at this point during the
MR. PERALTA: Yes.
CHAIRMAN BONACA: All right. We'll talk about
MR. MITRA: The next comment is individual plant
examination and individual plant examination of external
event, IPE and IPEEE, results should not be used in license
renewal scoping and on that issue, we agree that since
license renewal rule is deterministic, not probabilistic,
the industry commented that PRA techniques are very limited
use for license renewal scoping and thus wanted to eliminate
review of IPE and IPEEE in the SRP.
DR. KRESS: It's true that the rule is
deterministic as written.
MR. MITRA: Yes, it is, and we agree with that.
DR. KRESS: And if there is information in these
that are useful to you, why would you not use it?
MR. MITRA: Well, that's what I'm trying to say.
But, also, feels that use of IPE and IPEEE results provide
useful insights into the CLB.
In addition, the Commission, in the rule, stated
that in license renewal, probabilistic methods may be most
useful on a plant-specific basis in helping to assess the
relative importance of structures and components that are
subject to aging management review by helping to draw
attention to specific vulnerabilities; that is, result of
IPE and IPEEE.
So even though we agree that license renewal rule
is probabilistic, it still have the reference of IPE and
DR. KRESS: I should have waited till you
MR. MITRA: The next bullet is, next comments,
rather, explicit identification of design basis events may
not be necessary for all plants and our view is while not
always necessary for all plants, for scoping and screening
process used by the applicant for identifying SSCs within
the scope of the rule depends on knowledge of plant-specific
design basis event as captured in the plant CLB.
Therefore, the staff's position on this issue is
even when applicant elects to rely on a pre-existing list of
SSCs to meet the criteria in 10 CFR 54.A.1, the applicant
must still demonstrate the applicability of such list for
purpose of license renewal scoping.
But next comments we will discuss is they're
talking about examples used in SRP should acknowledge
preeminence of plant-specific CLBs. The staff included
clarification that highlight CLB bounds and examples, on
Any questions on the comments? As I said, we
included, saving time, just the more significant comments.
MR. PERALTA: Dr. Bonaca, this is Juan Peralta
again. I think this may be a good point, if you want to ask
questions on it.
CHAIRMAN BONACA: Okay. My question was if you
were going back on this scoping and screening, and you are
telling me this is the time.
MR. PERALTA: This is it.
CHAIRMAN BONACA: All right. So let's talk about
that. I mean, you've said that the Oconee experience is
pretty unique. Well, we have reviewed two license renewals,
so we don't know how unique it's going to be. There might
be some other difficult ones that come.
I still have a question regarding the guidance,
because the guidance is very general. It's similar to the
one we had in the previous SRP draft, with some
enhancements, I think. But during the Oconee review, a
disagreement came about the number of accidents that were
not included as part of the CLB of Oconee, and they were, in
fact, I think, had to do with requirements that were imposed
by the NRC in later years, I think in the late '70s and
early '80s, and I was always struck on how the
misunderstanding could be there and essentially the -- I
don't think that Duke changed their perspective on what the
CLB of Oconee was.
They simply followed the direction of the NRC to
go back and review those additional accidents. And to the
degree to which there is that confusion and that can be
repeated, again, that bullet number one, it's quite
significant, it seems to me.
MR. PERALTA: It wasn't so much an issue of going
back and arguing on DBEs. It was a fundamental argument the
definition of safety-related structures, systems and
components with respect to Oconee and with respect to the
way to define it in the license renewal rule, and that's
where the argument came about.
CHAIRMAN BONACA: So you feel now comfortable that
with the guidance as it exists today, that kind of confusion
won't be there.
MR. PERALTA: I think there's always the potential
to run into problems with all older vintage plants, but I
think we need to remain flexible to a dialogue with the
licensee and to understand their basis of their position.
I don't think we can dictate, for example, a set
of DBEs that were applied to a plant, it would be
impractical to do that.
CHAIRMAN BONACA: Could you develop a list for a
plant that meets all current requirements, plant design to
current SRP, and could you -- just as a question, could you
develop such a list for that plant?
MR. PERALTA: For a given plant, probably. For a
CHAIRMAN BONACA: I'm talking about for a very
recent design and I'm only probing to see if you could
enhance your guidance by putting a couple of examples in it
of what you would require could be for a very -- for a
current plant, and then maybe list an example of an older
plant, without naming the plant, for how to go from one to
MR. PERALTA: I just don't see how that would be
helpful, since we still need to go through the CLB and look
at all the exemptions, all the orders, and plant-specific
basis, before we understand how the scoping methodology was
And some plants have developed very extensive lists, so
called Q-lists, and if we understand the process by which
they developed those lists and if we're satisfied that
they've looked into the FSAR and the complete CLB and
they've captured all the plant-specific DBEs, I mean, I
don't see how having a list of typical DBEs would be
MR. GRIMES: Dr. Bonaca, I'd like to emphasize
that, as Juan has described, the controversy that we had
over Oconee largely involved a language difference. What
they called design basis events, in our view, was very
narrow and they considered other things that we would have
considered design basis events as plant capabilities, and we
ended up spending a considerable amount of time just
comparing language differences.
And in the end, we made a convincing case by
explaining plant capabilities in terms of what the
boundaries of the current licensing basis are and that's the
way that the standard review plan has captured the Oconee
It's more in terms of defining the boundaries of
the CLB and then putting the burden and responsibility on
the licensee to decide what constitutes a plant capability
without having to argue about what is the definition of
design basis event.
We felt that that guidance was more constructive.
Even when we laid a list before Duke, they spent most of
their time explaining that that's not the way they talk.
And so the value of a list, in our view, is more
detrimental because it tends to drive the older plants
particularly into defending their language use more than
looking closely at what their plant capabilities are.
CHAIRMAN BONACA: The list was purely -- the thing
that I wanted to -- one of the issues was, for example, high
energy line break. High energy line break has meant -- the
implementation of it has meant actual design changes of
power plants, modifications to withstand those accidents
that could occur in different locations.
That was a major thing that happened. I don't see
how that could be only a capability for the plant rather
than a design basis.
All I'm trying to say here is that reading the SRP
guidance and reading the NEI document, I don't see that
there is any additional help being provided to the next
plant and to the reviewer of a plant in understanding -- in
facilitating the review and the approval in the SER process.
I'm not saying it cannot be done. I'm only saying
that I don't think the documents have been modified in a way
to help the process.
DR. LEITCH: Could you contrast between the
scoping, as described here, and scoping in the maintenance
rule? Evidently the two are not exact. There are some
things in the maintenance rule that are not here and some
things here that are not in the maintenance rule.
Could you say a word about that, help me
understand that distinction?
MR. PERALTA: The maintenance rule overlaps, to a
large extent, except for, for example, regulated events are
not included in the scope of the maintenance rule and they
are in the license renewal rule.
Also, seismic considerations, the maintenance rule
does not consider those. For the most part, the definition
is very much the same.
DR. LEITCH: What was the first one?
MR. PERALTA: Regulated events, for example, ATWS,
station blackout, are a bit broader than the maintenance
rule. And some licensees have elected to use that as a
starting point when they're preparing the scoping and the
DR. LEITCH: Is there anything in the maintenance
rule that would not be included here?
MR. PERALTA: Probably emergency operating
procedures, EOPs. They are not explicitly addressed in
DR. LEITCH: So the maintenance rule, as you
indicate, could be a good starting point.
MR. PERALTA: And it is.
DR. LEITCH: But there is another set of issues
beyond the maintenance rule.
MR. PERALTA: Right.
DR. LEITCH: Okay.
CHAIRMAN BONACA: One more question is to do with
in the SRP, there is a clear reference to the documents that
need to be looked at in scoping, there is a table. I can't
remember the number of the table.
But in the table, there is an identification of
the EOPs. The EOPs may commit certain systems that then
become part of, I guess, the scope.
The NEI document has a table just like that, but
does not include any reference to the EOPs. Is there any
difference there with the industry regarding this issue?
MR. PERALTA: I would say that they would try to
remain as close to the rule as we could. This is a guidance
to the staff. So we tried to have as much references as we
can, as much information as we can. That does not mean it's
going to be used as the acceptance criteria. That's the
same -- in the same vein that we use the PRA summary report,
for example. It does not certainly mean there's going to be
-- that equipment or SSCs identified through the PRA summary
report will have to be included in the scoping of the
license renewal rule.
So there was considered to be used as a good
source of information, additional information. But looking
back, it may not be strictly necessary.
CHAIRMAN BONACA: How do you make that judgment?
How does the reviewer make a judgment that if a piece of
equipment is committed by the EOP to perform an important
function to go to cool shutdown, for example, cold shutdown,
it would be there?
MR. PERALTA: EOPs go beyond the design basis of
the plant. So, again, we have to go back and try to
understand and provide the bounds or understand the bounds
to the CLB and make those calls there.
CHAIRMAN BONACA: What about severe accident
management, there were commitments of equipment for that,
MR. PERALTA: That's beyond the scope of the rule.
CHAIRMAN BONACA: So you don't consider it as part
MR. PERALTA: Right.
MR. GRIMES: Actually, Dr. Bonaca, I want to point
out, Juan raised an important point. That EOPs and severe
accident capabilities and IPE/IPEEE insights are all useful
information to the reviewer to identify areas that are
important in the plant. But then we go back to the -- the
test is whether or not the licensing basis, as it's
described in the guidance, captures that equipment and
relies upon it to perform one of the functions described in
And so these things are useful tools for the
staff, particularly to focus on areas that are particularly
important in plant capabilities. But ultimately, the scope
of aging management reviews is tested against the definition
of the licensing basis.
CHAIRMAN BONACA: But isn't it true that if you do
a change to an EOP, you have to perform a 50.59 to determine
whatever 50.59 determines?
MR. PERALTA: That's true, but that's related to
the licensing basis.
MR. GRIMES: That, similarly, is a test of whether
or not the change involves a change in the licensing basis
that requires prior NRC review and approval.
CHAIRMAN BONACA: That's right. But I heard here
a clear exclusion based on the fact it's not part of the
MR. PERALTA: Well, we didn't say that. We said
that we look into that and to understand the bounds of the
CHAIRMAN BONACA: Let me a question now. Will the
plants commit to have severe accident management still
during the additional 20 years of operation?
MR. PERALTA: I'm not the one to answer that.
CHAIRMAN BONACA: So for the first 40 years, they
have committed to severe accident management and commitments
beyond that, and then for the next 20 years, we don't know.
MR. GRIMES: When plants commit to severe accident
management, they're committing to a process, not necessarily
committing to change the scope of systems, structures and
components that fit on the cue list. The commitment to
manage severe accidents is still going to exist. It is part
of the CLB that carries forward, but the commitment to
severe accident management did not, in and of itself, change
the definition of what is safety-related in the current
CHAIRMAN BONACA: Although I do believe that you
would want to perform a review to make sure that what you
committed to do in case you get into severe accidents, you
can still do in the next 20 years of operation. I don't
think that -- I think that there should be an understanding
with the industry that there's potential for those actions
that they identified in the severe accident management
commitments should be still supported during the 20
additional years of operation.
It seems to be reasonable.
MR. GRIMES: I would tend to agree, if we can find
a way to articulate that in some expanded guidance and the
expectation for how the CLB carries forward, we might be
able to do that.
But I think that that expectation has been clear
in the past.
CHAIRMAN BONACA: Okay. Thank you.
DR. SEALE: Well, isn't it part of the CLB?
MR. GRIMES: Yes, sir.
DR. SEALE: Then what else needs to be said?
CHAIRMAN BONACA: That's why I'm troubled by the
fact that the NEI document doesn't mention at all the EOPs.
The SRP only mentions that as a reference document on a
table, and then we hear some vagueness regarding those, and
insofar as the severe accident management, there has been no
understanding that the commitment would be maintained
entirely, and that's what troubles me, Bob.
MR. GRIMES: I think that there is a wide range of
process commitments that are embodied in different ways in
all of the operating licenses and it would be -- I confess,
I think it would be confusing for us to try and surround
them with a description of our expectations about how the
variety in those licensing basis would be expected to carry
Statements of consideration in Part 54, I think,
are very crisp and clear in terms of the role of the CLB and
how it carries forward with a renewed license.
CHAIRMAN BONACA: Thank you.
DR. SHACK: Just for the SSCs that are in GALL, is
that expected to be an enveloping group or do you expect to
identify new components or will the scoping essentially
reduce that scope?
MR. PERALTA: I guess I don't understand.
DR. SHACK: Is everything that you expect to find
in GALL, in most cases known?
MR. GRATTON: No.
DR. SHACK: So you really do expect to have
additions to systems, structures and components beyond those
identified in GALL.
MR. GRATTON: This is Chris Gratton, from Plant
Systems. The way I understand, the product of the aging
management review, the components that come out of that can
then be compared with GALL and if there are components in
GALL that match up with those components, you can use that
aging management program.
It's a predetermined review. But there are -- we
expect there to be many components, or maybe not many, but
other components that are on that list of components subject
to aging management review that are not in GALL and they
would have to do a plant-specific evaluation.
So they're not going to be going in synch or
reduce the number. It's just for convenience, they've
already been pre-reviewed.
DR. SEALE: It's generic, but not complete.
MR. GRATTON: Not complete sounds so bad. No. We
always do a complete review.
DR. SEALE: The list is generic.
MR. GRATTON: The list is generic and it's the
ones that we expect to find, but every plant has got
components that may not be on that list.
MR. GRIMES: We would like to say generic and
MR. MITRA: Anymore questions?
MR. MITRA: As Sam said, all SRPs and GALL have
license renewal issues that came in that jurisdiction and we
have, in the scoping methodology, we address a few of them
and one of them we already talked about, the 98-007, the
risk-informed license renewal. We already talked during the
The 98-012, a letter of March 10, 2000, internal
management is, like I say, a generic question and it's being
resolved. The -024, methodology review guidance, and we
issued the SRP and that's the guidance we are talking about.
072 is the commodity groups, also resolved by the
letter written on March 3 -- March 10, 2000. 073, rule of
evolution boundaries has been resolved. 082, hypothetical
failure, scoping guidance, is resolved by a letter written
on August 5, 1999. It's incorporated in Section 3C-B of SSC
and it's also page 216 of SRP.
Number 090, verification needed on the term design
basis condition, as used in the SRP section, resolved, term
no longer used in SRP. And 096, applicability of the
piece-part is resolved, term deleted from the SRP.
DR. SHACK: What was the issue on the hypothetical
failures? It seemed to me the statement of considerations
was clear and the guidance is consistent with that. What
was the issue there?
MR. GRIMES: I'll take it. The concern was how
creative could we get in hypothesizing failures that might
go well beyond what was considered in the licensing basis.
So the explanation about the boundaries of scoping in terms
of identifying what constitute design basis capabilities and
design basis events addressed that concern.
We don't hypothesize new combinations of things,
and I think that was fundamental to this issue.
MR. MITRA: Anymore questions?
CHAIRMAN BONACA: So for all these issues, there
is a pretty -- there is a consensus from NEI that you have
pretty much addressed those.
MR. MITRA: I think so, hope so.
CHAIRMAN BONACA: So you have reasonable closure.
DR. SHACK: You still have 700 comments.
MR. MITRA: Right.
DR. SEALE: Notwithstanding.
MR. MITRA: Not withstanding, yes.
CHAIRMAN BONACA: But your feeling is that even
though -- even though --
MR. MITRA: We have a good feeling about it.
CHAIRMAN BONACA: Even knowing where the 700 comments are,
you feel that these issues have been sufficiently understood
MR. MITRA: These issues are not -- it's there
since '97. So we would have heard if they have any problem
MR. GRIMES: I'd like to add that I don't -- I
would not be surprised if we didn't get additional comments
from the industry on some of these areas in terms of whether
or not there's still a level of detail that they might like
to see in an improved guidance.
But I wouldn't consider that to be a lack of
success. I think that as fast as we can get the guidance
improved, the industry has been able to identify areas where
further improvements could be made and it's a matter of just
drawing a line on, I think, what's typically referred to as
low hanging fruit.
We're going to go for as much improvement as we
reasonably can without putting the credibility of the
guidance at jeopardy within a timeframe that we have to
DR. SHACK: But there was general agreement there
was no such thing as low hanging fruit.
MR. GRIMES: Depends on the area.
CHAIRMAN BONACA: This is all about scoping and
MR. MITRA: On methodology, early results.
CHAIRMAN BONACA: Good.
MR. MITRA: According to the agenda, we have a
break, but if we are early, we can go ahead.
CHAIRMAN BONACA: Let's proceed. I think we'll
take a break as close to ten as we can. I don't want to
belabor the issue of the EOPs. However, I want to say that
for older plants, I'm very familiar with some of the FSARs,
even have data, there is very little information, there are
transients that are summarized, there are surrogate
transients, very few minutes or seconds, description, very
little understanding about what equipment is being used for
The EOPs become a very important document to
understand what further commitments the plants made to be
able to deal with accidents, much more than for newer
plants, for which you have substantial information in the
All those commitments are, you know, since they
are referenced in the FSAR, they are commitments that I view
as part of the current licensing basis.
If I am incorrect, let me know, because every time
you had to make a change to those, you had to perform a
And I heard two different stories here. At the
beginning, I heard, well, we're only looking at the current
licensing basis and the EOPs, we're only looking at them as
we look at the IPEs. Then I heard a response to Dr. Seale
that, no, it's part of the current licensing basis.
I would like to have a clear understanding of that
issue and maybe this is the time, since we are ahead of
MR. PERALTA: That's precisely why we have the
EOPs and PRA and so forth, to try to understand the boundary
of the CLB for each plant, since, like you said, it's not
very well documented.
When we go on-site, we venture into those areas.
We need to remain a bit cautious because we need to
understand also the bounds that are dictated by the CLB.
So we didn't want to come across as indicating or
implying that every -- that the whole EOP or the severe
accident management now becomes part of the CLB.
CHAIRMAN BONACA: You're making me uncomfortable,
because you're throwing in the EOPs with the IPEs and with
severe accident management. They are different things.
EOPs are referenced in the FSAR, are, in my judgment, part
of the current licensing basis.
Severe accident management are commitments that
the industry has made outside of the current licensing basis
and, also, I agree that the IPEEEs are the same thing.
But it's not every equipment that is relied upon
for severe accident management falls within the scope of the
CHAIRMAN BONACA: I understand that. I'm talking
MR. GRIMES: Dr. Bonaca, let me try again, because
I understand your concern and the difficulty that we face is
essentially the same difficulty that we face in the
controversy over the definition of design basis that was
recently resolved in NEI guidance on the treatment of design
The fact that current licensing basis embodies a
commitment to manage severe accidents or to have EOPs or to
maintain the plant in a quality way, that will carry
forward, because that is part of the licensing basis. But a
commitment to have and maintain EOPs does not necessarily
change that some older plants do not describe certain system
or component capabilities as design basis events or abnormal
And so having the EOPs provides a capability for
the plant to cope with that, but it doesn't necessarily
change the boundary of what constitutes safety-related
systems, structures and components, and that's the
distinction that we're trying to make here.
The CLB, for our purpose, is what is a
safety-related piece of equipment or a safety-related
structure for which there should be an aging management
review. The commitments to have severe accident management
in EOPs give us insights into what plant capabilities are
important, but ultimately the test of whether or not the
equipment that's relied on, and I would say that the most
difficult for us is fire protection, because in fire
protection space, the description of the fire protection
capabilities vary widely, even across the more modern
But ultimately, that is the test that we look to
in terms of whether or not a particular equipment, not
processes, but equipment, systems, structures and components
is relied upon to perform the functions described in the
scope of the rule.
CHAIRMAN BONACA: You're still making me
uncomfortable. You're throwing together the severe accident
management guidelines and the EOPs. The EOPs are specific
to the equipment. In many older plants, there is no
description of how you depressurize and cool down to cold
shutdown, but the EOPs contain that and they define very
clearly what equipment you need to rely on, the auxiliary
I mean, older plants, at times, have had that
listed as not safety-related and then later on, it clearly
was considered. But that kind of clarity has to be there,
because the EOPs are committing to do fundamental steps like
going to cold shutdown.
MR. GRIMES: That's an excellent example, I think,
of the point, because I know that there are a number of
older plants for which they have emergency operating
procedures for feed-and-bleed capability, but that
capability is not described in the FSAR and is not part of
the licensing basis.
So for plants who have a commitment to maintain
EOPs, that carries forward into the renewed term, but if the
plant design basis does not specifically call out a reliance
on a feed-and-bleed capability, we're not going to -- we
might not see that equipment captured within the licensing
And if we think it's important enough, then we
would pursue changing the licensing basis under Part 50.
CHAIRMAN BONACA: Okay. Thank you.
MR. MITRA: Now, we will present scoping and
screening results, and, again, there are many NEI comments
and we only address the significant ones. The first one is
we have a question of scope of review and design basis
Their comment reflects a need for clarifying the
staff's review approach. The staff uses the following
approach during the review. We define the -- the scope is
defined in 10 CFR 54.4 and design basis events are found in
current licensing basis as defined in the five documents.
The applicant can choose to include SSCs not
meeting 10 CFR 54.4. Staff samples SSCs that are identified
to determine whether they perform intended function and meet
Reasonable assurance achieved by finding no errors
in the sampling or no omission of structure and components
subject to AMR and this constitutes an independent review of
results, not a verification of application method.
These are the five approaches the staff takes when
The second comment we addressed is, again, no
omission of structures and components subject to an aging
management review. The staff's position on this issue is in
order to come to a reasonable assurance finding, the staff
should find no omission of components and structures
identified by the applicant as subject to the aging
Any inconsistencies are addressed as they are found, either
justified or included within the scope.
And the next one, the comment is the industry
things to verify applicant's scoping and screening results,
the staff should verify applicant's scoping and screening
And NEI recommended that staff should review the
applicant's scoping methodology to review scoping and
screening results. However, the staff perform an
independent review, and it's called that, of applicant's
scoping and screening results.
The purpose of the independent review is to verify
the adequacy of applicant's scoping methodology.
These three comments we have addressed among the
others and these are the more significant.
DR. LEITCH: Is what's proposed then that the
staff would do -- are you describing an audit rather than a
complete review? Is that the sense of what we're hearing,
that rather than a complete review, you would do a sampling
or an audit?
MR. GRATTON: No. This is the methodology that we
implemented for the first two applications. The licensee
sends in their complete application and as many as 50 or 60
systems, including the tables of all the components that are
in scope, and along with that, they send in diagrams that
show the bounds of the systems that they include -- that
they consider are within scope.
The methodology that Juan was talking about
describes how they put that information together and he
independent verifies that his is complete.
What our section does is we take the results and
along with those diagrams and the five basic documents,
which are the FSAR, any license conditions, the applicable
regulations, orders and exemptions, and we try to bound the
CLB and look at the diagrams and the lists to determine
whether or not the components that are on that list
constitutes a complete picture of all the components and
structures that are within scope.
The application is broken down and distributed
among reviewers and the reviewers go system by system,
component by component and verify the list.
So right now, it's a complete 100 percent review
of all the information that comes in in the application and
the steps that you're looking at, when we look at those, at
the drawings, it says that the applicant can choose more
systems, structures and components than are require by the
licensee, sometimes by convenience, they will mark off
portions of the structures and components that are not
So we sort of have to discriminate and the best
way that we've found to discriminate is to look at the
portions that are not highlighted, the ones that are not
included within the scope, and try to determine whether or
not they have a safety function that's described in one of
those five documents.
If it is, those are the areas that we focus on,
because the other ones are included. They're going to be
subject to an aging management review.
So to answer your question, NEI said, hey, you
know, you're doing a negative review, you're looking at
things that are not in scope, why are you doing that. We're
verifying that what they've excluded, the omissions are
So when we have a finding of no omissions, that
means we have reasonable assurance that everything has been
captured. It might be more than everything, but everything
has been captured in that list, and to verify their
methodology would do nothing more than say, yes, your
methodology has been fixed in these tables, but that doesn't
say that what's been left out we've even looked at.
So we didn't want to go through that sort of test
as we were doing our review. We wanted to do something that
was independent and we felt that this was the best way,
because we looked at what was not included.
DR. LEITCH: Thank you. I understand.
CHAIRMAN BONACA: I have a question. I've looked
at the agenda for the next two days and there is a
presentation tomorrow by NEI on their document, but to the
degree -- but there is no area where the staff is commenting
on the NEI document, which really interfaces with this.
To the degree to which you have information, when
you come to the specific section, if you have insights or
comments you would like to make on the NEI document, I would
appreciate that, because we hear a lot of interaction here
on what the expectations of NEI were on the SRP, but there
is a burden on the NEI document, too, because it supports
the reg guide, and I would like to hear from you if there is
MR. GRATTON: It's not done in a vacuum. Over the
past couple of months, we've interacted with NEI. Have we
actually reviewed the draft documents? I've seen a couple
of them. I'm not sure whether or not I've seen the most
recent version of their 95-10.
MR. GRIMES: Yes. As a matter of fact, we've
reviewed Revision 2 of 95-10 and we believe that there is
reasonable consistency, as Dr. Lee pointed out. We have an
expectation that having gone through this process, to get
this far with the August standard review plan, that NEI is
going to go through another revision of 95-10 to make
So to the extent that the staff is describing a
resolution that could impact the 95-10, Mr. Walters will
tell you tomorrow that they expect to make additional
conforming changes and the nature of the comments so far
you've heard has been largely in the language on the
instruction to the staff on how they should do their job.
But the resolution of these particular technical
issues is also being reflected, either has been or will be.
So it would be appropriate for you to challenge Mr. Walters
tomorrow, and let's not tell him, so that it comes as a
CHAIRMAN BONACA: The reason why I'm raising it
now is there is only one hour for that tomorrow and probably
is enough, but I think the applicants are going to look at
the NEI document as a means of developing their
applications. So all the comments we are having here is on
the ability of the reviewer to put together an SER, a
But I think that -- so to the degree to which you
have insights, where there are open issues with the NEI
report, please raise them today.
MR. GRATTON: After NEI submitted these comments,
there was a meeting that they had attended or that we
attended with them here and the same methodology that I've
just described to you was described to them and it was after
they had sent in these questions about, hey, how come you're
looking at the parts that are not in scope, you're supposed
to be reviewing the scope that's within scope, and I think
that clarified a lot the fact that we -- there was an
interaction between the staff and NEI at that point about
how it's done and it may clarify their methodology for
putting together application, because we do -- we've
communicated with the licensees early on in their
application point how vital the diagrams and the
descriptions are to us performing our review and the method
that I've just described.
And I'm hoping to see that reflected in their
CHAIRMAN BONACA: Thank you.
DR. SEALE: I'll be interested to hear more about
this sandbagging management style.
MR. MITRA: If you don't have anymore questions on
comments, then we'll go to the license renewal issues.
Number 8 is a component list and the staff identifies the
component list by plant-specific diagram, as Chris was
saying, P&ID diagram, that is.
The commodity groups are allowed and guidance on
how to evaluate commodity groups is contained in a revised
SRP and it's in Section 2.1 and through 2.3 through 2.5.
And next, 11 through 20, it's passive-active
determinations, fuses, active-passive transformers,
indicating lights, heat tracing, electrical heaters.
The determination of passive-active was made on
NEI document 95-10 and later on included in SRP table 2.1.6.
The electrical components identified above are
determined to be active components, and thus not subject to
an aging management review.
Number 21, which is recombiners, it will be
evaluated in plant-specific basis as a complex assembly.
One or two model breakers in storage, as Dr. Lee
previously said, that we missed this, also NEI missed it,
but this is outside scope of license renewal. We didn't
include in SRP. It is not included in 95-10, but it will be
included in the next revision of SRP.
CHAIRMAN BONACA: That's equipment in storage?
MR. MITRA: Yes.
CHAIRMAN BONACA: Still you're looking at passive
The passive portions of those components.
MR. MITRA: And the last one, 105, heat transfer
function, this is result and included in table 2.1.3.
DR. UHRIG: Go back to motors and breakers. Those
are nominally active components, are they not?
MR. SHEMANSKI: This is Paul Shemanski. This
issue was identified at Oconee, I believe, during part of
the scoping and screening process and the question was how
do we treat these.
It turns out that motors and breakers are
identified in the license renewal rule as being active. So
based on that, Oconee determined that they were out of
But we had a concern about whether or not these
items in storage are going to receive any type of treatment
which would ensure their functionality when they are put in
So we had discussions with Oconee and we
determined that even though these are active components, it
just seems logical that they need to give us some assurance
that these components will work, in fact, when they are
taken out of storage and installed in their proper circuits.
We did give credit to the fact that these
components are -- even though they're in storage, Oconee
told us that they are periodically given -- they are looked
at primarily from a maintenance and surveillance standpoint
and some testing.
So it's not like they're put in storage and then
nothing is done. They do receive some treatment. So that
gives assurance that they will function when they are called
DR. UHRIG: What about components that are in some
vendor's storage? Is that any different?
MR. GRATTON: The components that he's talking
about were for specific set of events. These are the SFF
called-out components that are stored on the shelf and in
the event of a design basis fire or some other event that
the SFF had to be implemented for, it would be brought out
and installed at that time.
So these are not like motors and breakers that are
on the shelves anywhere. These are specific set of
components that are called out in their procedures that need
to be installed in the event of a certain DBE or DBA.
MR. GRIMES: I'd also like to add, to clarify the
point about the treatment of this equipment, although it's
active, they are active components, but what we revealed
through this evaluation was that the foundation of the
license renewal rule is basically predicated on the
maintenance rule being able to provide a means to verify the
reliability of active equipment.
And for these components, when they're sitting on
the shelf, they are not tested and they don't fit the
description of why we excluded active components from the
scope of license renewal. So we pursued it from the
standpoint of making sure that we had reasonable assurance
that this equipment in storage was, in fact, going to fit
within the context of the underlying concepts of the rule.
That's why we felt that it was important to
address this equipment.
DR. UHRIG: The fact that they do perform some
testing on this makes it then --
MR. GRIMES: Provides us with reasonable assurance
that when the equipment is called on to perform its intended
function, it will operate properly, but it doesn't -- when
you look at the description of the license renewal rule, it
says that active equipment does not need to be subjected to
an aging management review because it's constantly being
Well, this didn't fit that explanation. So we
felt it was important to capture that in the evaluation
MR. MITRA: Thank you very much.
CHAIRMAN BONACA: Mr. Mitra, might this be a good
point to break?
MR. MITRA: Yes.
CHAIRMAN BONACA: Let's take a break until quarter
CHAIRMAN BONACA: Let's resume the meeting. Dr.
DR. LEE: My name is Sam Lee. I'm to discuss
Chatper 3 of the SRP. Chapter 3 is the aging management
review, and this is where the GALL report fits into the SRP.
I'm not going to discuss the aging management programs here
and you will hear the discussion this afternoon and tomorrow
with respect to the GALL report.
But in the SRP, what we have done is that we
referenced the GALL report as the technical basis document.
So when GALL says a program is adequate and provides a
basis, the SRP does not direct the staff to repeat this
review of those programs.
But if the GALL report indicates that a program
should be augmented, the SRP will point the staff to that
direction and focus its reviewing areas where the program
should be augmented.
And for the April version of the early draft SRP,
we did not receive any comment from NEI in Chapter 3.
Instead, they chose to comment on GALL and that will result
in changes in Chapter 3 of the SRP.
And some of the license renewal issues that apply
to Chapter 3 are the FSAR content. The license renewal rule
requires an FSAR supplement summarizing the aging management
In Chapter 3 of the SRP, we provided such a
summary and we also provided some in Chapter 4 for TLAA,
Then the other two license renewal issues relating
to commitment tracking, say the licensee or applicant
commits to some aging activities in the future, how do we
track that. And based on the experience from the two
initial licenses, renewal licenses, those are handled by
license conditions and the SRP reflects that.
And I'm not going to talk about Chapter 3 anymore.
As I said, you'll hear the individual technical discussion
on the GALL chapters today and tomorrow.
Instead, I will go into Chapter 4. With me, I
have colleagues from Division of Engineering to answer
questions relating to the TLAA. I've got Barry Elliot, Shou
Hou, Paul Shemanski, and Kamal Manoly. They are from
Division of Engineering, NRR.
The license renewal rule requires an evaluation of
time limited aging analysis. Those are analysis that have a
40-year assumed operation in the analysis.
The first step is to identify them and that is the
purpose of Section 4.1 of the SRP is to reveal the list that
has been identified by the applicant.
And in the 4.1, we provided some examples of what
TLAA -- the initial applicants have identified. We know
TLAAs are plant-specific. They depend on the plant CLB and
the rule provides a definition of what they are.
But before it would be helpful to reveal some
examples, but NEI was saying those examples are not
necessary, but we think they are. So we are keeping those
in the SRP.
DR. SEALE: There is no suggestion that your list
is complete, is there?
DR. LEE: No, there is no suggestion, not on the
DR. SEALE: That's the only danger I could see, is
if someone felt that they satisfied such a list, that they
were home free in that regard.
DR. LEE: I think NEI's concern is that we will
use the lists and not RAIs for every one that did not get
identified by an applicant. And that is not really the
That gets to the second bullet. NEI suggests
instead of asking an RSI for every TLAA in that example
list, that the applicant did not identify, that we really
should stop at the FSAR and not a licensing document, we
look at and see if there's any TLAAs or anything that would
apply to the plant.
So we agree to that and we'll actually make that
CHAIRMAN BONACA: So what change will you make?
DR. LEE: We put that in there to say this is not
important, to stop at the FSAR, rather than use the list of
examples. They indicate the impression that you start with
DR. UHRIG: What is the updated FSAR?
DR. LEE: The August version, yes. The April
version was the early one, just to engage the stakeholders.
For the August version, we actually make that change.
So when you see NEI comments today and tomorrow,
those are pre-August.
And here now we get into some technical
evaluations. The first one, Section 4.2, that's on the
reactor vessel embrittlement and that is a TLAA and one of
the things that NEI commented on the April version is that
we included the reactor vessel surveillance program as TLAA,
and NEI responds that, gee, that is not a calculation, it's
just a program in there. So we realize there need to be
extended for license renewal, but they characterized it as
an aging management program rather than a TLAA.
The result is the same. You still need to have a
monitoring program, but we agreed, we said, okay, we put it
under the aging management program.
Another comment they have is on the
pressure/temperature limits. They want to emphasize that
the pressure/temperature limit is such as required by
Appendix G. So we said that's fine, so we incorporated
And there's one license renewal issue, that's
pressurized thermal shock and we included that in Section
And the next TLAA --
DR. LEITCH: Sam, these issues on table 4.1.2, the
potential time limited aging analysis, I'm looking at the
Chapter 10 of the GALL. Are those parallel? In other
words, is the intention that in Chatper 10, the goal, there
be a discussion of each one of these issues?
DR. LEE: No, there is not. The way Chapter 10 --
I can show you in the next slide. In the initial license
renewal application review, some applicants have proposed
aging management programs to address that TLAA.
And those are captured in Chapter 10. So we
captured experience in Chapter 10. There were a few, there
were like -- there is stress and there is one more, EQ.
Those are the initial license renewal applicants
and then they all used the aging management program approach
to address the TLAA, and because there is an aging
management program type approach, we put it into this new
That was the NEI suggestion to create Chatper 10
for the some of the TLAA information. But it's not a
comprehensive list. Those are the ones that we actually
tackled in the applications and we feel comfortable that we
should document them.
DR. LEITCH: So we should view -- well, we'll talk
more about Chatper 10 when we get to the goal, but I guess
we should view that as examples.
DR. LEE: That is correct.
DR. LEITCH: Rather than a complete list.
DR. LEE: Yes. It's more -- this is actual
experience, the ones which were accepted and were documented
in Chapter 10. In Chapter 10, those are acceptable. That
is not complete, I guess. In the future, when we get more
experience, that will probably expand.
DR. SHACK: Sam, I missed a chance to ask a
question about the PT limits. In the draft SRP, existing PT
limits are valid during the period of extended operation
because the neutron fluency projected to the period of
extended operation is bounded by the fluency assumed in the
Is that true?
MR. ELLIOTT: That's an option. There are plants
that give us very conservative pressure/temperature limits.
A lot of plants don't have a big embrittlement problem.
They have a small embrittlement program.
So they may give us pressure/temperature limits
that go out for 40 years or more and they -- and then they
recalculate the fluence in the year 25 or something and it's
a very conservative number.
So those pressure/temperature limits which were
good for 40 years may go for 60 years, depending on the fuel
cycles and how the fuel cycle affects the neutron fluence.
It doesn't happen for all plants. It's a way of
complying with a TLA that's an option.
DR. SHACK: Okay. This just reads funny.
DR. LEE: I guess that got brought up. The way
the rule says for TLAA, there are three options for an
applicant. One, just like Barry said you can show us that
your TLAA is so conservative that it's actually valid for 60
The second option is you just extend your analysis
from 40 to 60. The first option is to go with an aging
management program, to address that aging management program
and that's the Chatper 10 approach, is to use the aging
Section 4.3, that's on fatigue. We have a GSI-190
on the environmental effects on fatigue and in the initial
license renewal applications, the applicants had an analysis
to address their GSI-190, environmental effects, and the SRP
And NEI's comments -- well, the way the SRP and
the initial applicants addressed GSI-190 is basically by
analysis to modify the fatigue curve and try to incorporate
And NEI's comment is in the future, there might be
inspection or enhanced inspection that can address
The staff has not reviewed or accepted this as an
approach. So we did not include that into the SRP.
And the issues are basically fatigue, so there's
not much there. And like I indicate, in here, we accepted a
fatigue monitoring program in the initial -- I guess the
initial applicants and Chapter 10 reflects that and the SRP
says that is one acceptable way to address this TLAA.
Are there any questions? Okay.
The next one is section 4.4, that's environmental
qualification, EQ of electrical equipment. This one, we
actually spent a lot of time in the initial applicant review
and actually was one of the, I guess, the programs that NEI
pointed to when they raised the credit for existing program
It's an existing program, why does the staff spend
so much time reviewing it, and what we found out is that for
EQ, there are certain things that -- like the analysis of
the qualified life, we need more information on that and
then after we have gone through the first license renewal
applicants, we capture their experience in Chapter 10.
And NEI commented on that and we are very
comfortable with what is in Chatper 10 as an acceptable EQ
program, they will manage EQ, and the SRP refers to that as
one acceptable way to address the EQ.
And that is basically the NEI comment. They
commented through Chatper 6 of the GALL report on electrical
equipment and then they requested us to make the conforming
changes and we did that.
DR. UHRIG: This is tied in to Generic Issue 168.
DR. LEE: That's correct.
DR. UHRIG: And that is to be resolved in the not
too distant future.
MR. ELLIOT: Yes, that is correct. I believe
GSI-168 is currently scheduled to be resolved by the end of
December and if you recall, recently, ACRS was briefed on
the status of 168.
DR. UHRIG: Which is long before the next plant
application is under consideration.
MR. GRIMES: Long is a such a fragile phrase. The
safety evaluation for Arkansas, safety evaluation with open
items is scheduled to be completed, I believe, in January.
So we're going to be challenged to complete the
safety evaluations for the three plants under review and
fold in the recommendations of that effort.
DR. LEE: The next item is Section 4.5, that's on
containment stress. Also, this is one of the three
write-ups in Chapter 10. We accepted the containment stress
program in the initial applicants, so we documented that in
Chapter 10 and the SRP points to it as an acceptable
And I guess NEI indicated that the program is not
really TLAA, but we disagree with that. The tendon is there
for 40 year analysis. So we kept that in the SRP.
And, also, NEI provided comments in, I guess,
through Chatper 2 of the GALL report on the containment
tendons and we incorporated that.
CHAIRMAN BONACA: Why did NEI feel that this was
not a TLAA?
DR. LEE: They say it's a program, they say it's a
monitoring program. So it's doesn't involve calculation on
the program part, even though you have these tendon stress,
the calculation -- to us, the whole thing is kind of rolled
into one. You have the calculation, you get monitoring to
make sure your protection is correct. So we roll it all
CHAIRMAN BONACA: Okay.
DR. LEE: It's a matter pending. Do you just call
it TLAA or do you call it aging management program, the
outcome is still the same.
DR. SEALE: That's semantics, for crying out loud.
DR. LEE: But for the rule, yes, because the rule
required them to identify TLAAs.
CHAIRMAN BONACA: The thing is that would preclude
one of the three approaches that you are proposing for
resolution of TLAA.
DR. LEE: Yes, but for tendons, based on the
experience of the initial license renewals, they are all
down here based on the program. They all rely on programs.
CHAIRMAN BONACA: The second option you outlined
before was show that it's bound by analysis. So in case you
are not within those curves, you can extend those, and if
you do not do that, then you have to automatically implement
an aging management program. It's the only option you
reserve. All right. I understand now.
DR. LEE: Right.
DR. SEALE: The guys at Oconee certainly paid a
lot of attention to it.
DR. LEE: Section 4.6, that's on containment liner
fatigue. NEI recommended as to look at the comment on
fatigue, they provided on Section 4.3, and we did that. We
had a discussion with NEI on that and we actually made some
changes, I guess, based on the meeting we had. We actually
have some understanding of what this section was supposed to
Those are the kind of more generic kind of TLAAs
that we expect most plants would have. So we have the SRP
specifically for those. But there are other TLAAs that are
plant-specific, so we have this 4.7, which provides generic
staff guidance, which kind of describes the three options
for TLAA; if someone has a certain TLAA, what those three
And NEI has a very minor comment on that and the
last one, the issues there all relate to the third option,
the aging management program option. This is the '97
timeframe. At that timeframe, we were unsure in terms of
what that means, but since we've gone through some license
renewal applications, we feel now we have these three
examples already. So we know better what that means. So
the SRP has been revised to reflect that.
Is there any questions on TLAA, Chapter 4, SRP?
DR. LEE: Then I'll go to the appendix, which is a
branch technical position.
CHAIRMAN BONACA: Let me ask a question. You're
practically at the end of the SRP review of the list of
issues raised by the industry.
The question I have is when you look at the
plant-specific operating experience, it's not really
discussed in the SRP. It's discussed in the GALL report.
It's one of the ten criteria that you're using.
And maybe you want to discuss it then when we
review the GALL.
DR. LEE: Yes, the GALL report. That's a good
lead-in into this branch technical position. This branch
technical position, the A-1, describes how you -- the
generic approach to your program, based on the ten elements,
the ten program elements.
One of the elements is operating experience. So
it describes that that program will have -- good experience
that shows that the program is effective, if you actually
had degradation, if you actually modified your program to
address the degradation.
So this actually described generically in this
branch technical position.
In the GALL report, we had actually followed this
guidance in preparing the GALL report, and, also, in the
initial license renewal application reviews, we had to
follow this guideline.
CHAIRMAN BONACA: One thing that was clear in the
GALL report is that there is a body of experience also from
the whole industry in general that is applied in those ten
criteria which you're looking at.
I just was wondering more about the plant-specific
experience. I mean, experience that a plant may have, say,
a BWR may have had a crack in the sparger. We haven't
looked at BWRs yet, but -- and so there maybe some specific
concerns with those components there and typically that kind
of experience is summarized in the application.
I think the introductory chapter, there is one
operating experience. And how is it addressed specifically
for the plant? A plant unique experience. Now, I
understand the spargers have broken in different plants, so
it be generic.
DR. LEE: For the sparger case, those are generic
and we've already captured them.
CHAIRMAN BONACA: What if there is something very
unique about a plant that says a component really needs to
be paid attention to because it went through some experience
that is unique?
DR. LEE: The way the GALL -- I guess in the
chapter, the first thing we start out with is to identify
the applicable aging effects. One of the things in this
section we said is you look at the industry-wide experience
and you also look at your plant-specific experience to
identify aging effects.
So your plant -- if you have a certain situation,
you crack a certain component, that's how we identify the
aging effect. That's how we get to the applicable aging
effects. So that's one input into identifying that.
CHAIRMAN BONACA: And that's still addressed in
DR. LEE: It's actually in the SRP.
CHAIRMAN BONACA: One of the criteria of the GALL
DR. LEE: That's correct. Actually, the way, if
you look at Chapter 3 of the SRP, it says on the actual
applicant's GALL report, before they can say the GALL report
applies to them, they have to go through and say, yes, my
plant actually looks like GALL.
If GALL says this component doesn't crack and then
for your plant it actually cracks, GALL isn't applied to
CHAIRMAN BONACA: But let me just give you an
example. Assume that you read the application and I
remember still some of the one we read for BG&E and for
Calvert Cliffs and for Oconee, and they were pretty
abbreviated in some of the events. So now I'm trying to
understand how a reviewer is going to really understand the
issue clearly and see how it's carried through in the
evaluation of certain components.
I am trying to understand how that process works.
MR. LEE: It is reliant on applicant to identify
the specific issues. And also we have inspections that we
do for license renewal, and actually for the Oconee case, on
electrical, I guess -- we actually gone to the site.
We had to pull the maintenance records, and found
certain latent effects that the applicant did not identify
in the application.
Okay, so we actually tried to verify some of the
information. So you do have, in fact, inspections that you
do, I remember that.
CHAIRMAN BONACA: A free inspection.
MR. LEE: Yes, you do that, one inspection that
looks at the aging effects and the program that they claim.
CHAIRMAN BONACA: Now, that phase of -- you know,
of action is non-specific. It's identified in the SRP, yes.
MR. LEE: I guess we spent a lot of time on that
already, and we did not receive any comment from NEI for the
And actually, in fact, NEI revised the 95-10 to
incorporate this information, these ten program elements,
okay, to be consistent.
This is the process we use to perform the initial
review and prepare the GALL report.
And the next branch position is on quality
assurance. And the way the -- we evaluate the aging
management program, we're looking for corrective action,
administrative control and such QA type activities.
And we have written up a position relating to
Appendix B, to Part 50, and that is in this technical
And do you have any question on that?
CHAIRMAN BONACA: I may be jumping from one to the
other, but it seems to me that any time you find that an
existing program is not sufficient, then there is a
reference to going to the Branch Technical Position for
MR. LEE: That's correct, right now, yes. We
realized that's one of the things that we probably need more
work in the SRP, because now it just points to that and kind
CHAIRMAN BONACA: That's right, you stop there and
there is no further understanding of what the criteria are,
what you have to do. You go to the GALL, and you look for
some programs, and you say that you see it says more is
MR. LEE: That's correct, yes.
CHAIRMAN BONACA: In some cases, there is a
definition of what the "more" is, and in many cases, there
MR. LEE: The way we tried to do it is, we tried
to capture experience from the license renewal reviews.
CHAIRMAN BONACA: Yes.
MR. LEE: In cases, we actually come to a
position, so to speak, and then we capture that. But in a
lot of cases, they are plant-specific, they go this way and
they go that way, so we had a hard time in terms of how to
capture in GALL, so we kind of left it, and then we further
reviewed it to the generic items.
We understand that we need more work in that area.
We know that.
CHAIRMAN BONACA: Is the GALL report intended to
be a living document?
MR. LEE: We intend to update this when we capture
additional experience, but the timeframe, we don't have a
timeframe for that yet.
CHAIRMAN BONACA: But you intend to reflect the
experience in the future?
MR. LEE: That's correct, yes.
CHAIRMAN BONACA: Okay. You know, would it be
worthwhile -- I understand that would imply commitment on
your part, but would it be worthwhile to indicate that in
the characterization of the GALL report?
I mean, I've seen a big improvement in the GALL
report from the first time I looked at it, and what is being
presented now. And if there is an intention to by some
means to keep it a living document that would reflect the
additional experience with the new plants, that would be
worthwhile to point it out somewhere.
MR. LEE: Okay, that's a good comment. We
MR. GRIMES: Dr. Bonaca, I'd like to add, I think,
my reluctance to do that at this point. It was an
expectation that it might be possible for us to merge GALL
and the SRP. And at this point, that's an insurmountable
task in the near term.
But I do think that it would be valuable to point
out that in whatever form it evolves to in the future, that
we would intend to continually improve it and add new
CHAIRMAN BONACA: Most of all, at least it will
provide an answer to why there isn't any further guidance.
I think you gave us a good explanation here. I understand
it that there is no experience, but I think that, you know,
if you say that, then the -- there is no casual reader here,
but whoever --
MR. GRIMES: Get's sucked in.
CHAIRMAN BONACA: Gets sucked in, right, because I
think you're going to have new plants coming in, and they're
going to start anew and maybe to wonder why there is no
further guidance there.
And I think you gave us a good reason, but I think
it should be documented somewhere.
MR. LEE: The Branch Technical Position is on the
generic safety evaluations. This position indicates that
certain TSIs are those in NUREG 0933, and that needs to be
-- that should be addressed for license renewal, because
they relate to aging, so these position states certain
criteria that someone can go through, or some process
someone can go through, NUREG 0933 and identify those
We gave some examples. And one of the examples is
TSI-173, the spent fuel storage pool.
And the way we characterized it in the SRP, we
said that it is closed or nearly closed, but I guess that as
things turn out, that is still open.
So, but then when we look at this again, we found
out that this issue doesn't relate to aging, so that's not
need to be addressed anyway.
Okay, so we'll probably make some changes for the
DR. KRESS: What was your conclusion that the
spent fuel storage pool doesn't have aging issues; what was
that based on?
MR. GRATTON: This is Chris Gratton again.
DR. KRESS: The concrete walls could age.
MR. GRATTON: It's not so much that the spent fuel
pools don't have aging effects; they're captured by the
rule. It's the GSI-173(a), itself, looked at a specific set
of design issues, and we went back and we looked at how
those design issues were being played out with respect to
their license basis.
And they were not --
DR. KRESS: So you're not excluding the pool?
MR. GRATTON: No, no, the structures and the
components that support the pool are all within scope. The
racks are in scope, all of items are in scope. It's just
the specific design issues that were in 173-A.
DR. SEALE: Are you trying to tell us that all of
the GSIs that have application to plant aging have now been
MR. GRATTON: I get all the good questions. No,
sir, I don't believe that's what we're trying to say at all.
And actually, I'd ask what gave you that
DR. SEALE: The fact that 173 showed up this way,
sort of suggested to me that here's one, but it doesn't
really -- I mean, it's not resolved, but it doesn't really
apply to this case.
MR. GRATTON: I think the reason 173(a) showed up
was because we were trying to remove it from the list that
they had to address when they sent an application in,
because we said that it was closing, and we were a little
bit premature to say that it was being closed.
We were removing it because we said it closed; not
because it didn't have aging effects. So the changes, the
item of interest is the fact that we are going to eliminate
it from the list, but because the issues in 173 are not
aging-related, and that's the difference.
MR. GRIMES: As a matter of fact, we went through
all of the GSIs, and evaluated them specifically in terms of
is there an aspect of the GSI that needs to be resolved for
the purpose of a license renewal decision?
And in order to get to that conclusion, we look at
the GSI to determine whether or not there is any unique
aging-related issue that needs to be addressed.
GSI-190 and GS-168 are the ones that popped out as
these involve particular aspects of aging that need to be
considered for the purpose of license renewal. But the
others, we wrote out an evaluation that explained why those
issues can remain open and not require some unique decision
for the purpose of license renewal.
DR. SHACK: So you have such a list?
MR. GRIMES: We have such a list.
DR. SEALE: And that list does not include things
which require immediate resolution in order for you to be
able to do this job?
MR. GRIMES: That's correct.
DR. SHACK: Then why isn't that list in the SRP
MR. GRIMES: Because we were trying to figure out
a way to interface the Standard Review Plan with NUREG 0933,
because GSIs will continue to evolve, and we didn't want the
SRP to necessarily be dependent on the evolution of GSIs.
So we describe a process for addressing GSIs.
DR. SEALE: Okay, Chris, this is a good place for
me to ask a question, another question I had. That is,
we've looked at some of the GSIs and the way in which they
have been resolved.
And I think we've commented in the past that there
seemed to be a lot of what I'll call sharpshooting in the
resolution of the GSI, namely, you identify an issue, you
put together the full scope of the issue, and then you look
at a part or the approach to that issue, really in a fairly
And you determine how that issue will be treated,
and you then in some cases, I have to say, it seems like,
willy-nilly, declare the whole issue to be resolved. And
that's what I call sharpshooting, that is, you really didn't
resolve all of the issue; you resolved the issue in a narrow
sense, and it may have been complete as far as the status of
the problem was at that time.
I guess what I'm worried about is that I can see
things which have been declared as resolved generic safety
issues in that narrow context, reemerging as you look at the
conditions that might exist under life extension.
Have you looked at the GSIs that are resolved and
asked yourselves, are these guys going to stay in bed?
MR. GRIMES: Or stay six feet under.
DR. SEALE: Wherever you put them and took care of
MR. GRIMES: Let's see, we're going to start with
the process piece. The process piece is that the Office of
Research went through and looked across all of their generic
safety issues, with an eye towards whether or not the
problem definitions captured license renewal.
And the process is in going to continue to evolve
in the future because the 0933 process was created at a time
where there were lots of questions being raised, the
definition of the problems was being treated almost on an
assembly line basis.
And now the nature and the role of Research is
evolving. And so I expect to see process changes.
But I would point to the controversial resolution
of GSI-190, where the answer specifically addressed the
question that was posed, relative to the need for any
backfitting requirements for fatigue analysis.
But it also included a consideration of what is
appropriate for license renewal. And that caused a bit of a
stir, but I think it was the right thing to do, and I expect
that we would continue to do the right thing as future
generic safety issues are resolved.
There's a need for the process to have a clear
scope definition and a clear mission statement.
DR. SEALE: Yes.
MR. GRIMES: That doesn't necessarily preclude us
from looking beyond the specific answer to the question, to
the broader implications for license renewal or other policy
DR. SEALE: And I agree that that was a very good
example. But in a sense, you could see the plume of dust
coming down the road towards you, that the licensing renewal
issue was raising.
And you knew that you were going to have that
problem. Now, are there questions in the past which were
resolved at a time when license renewal was not a
particularly visible possibility that might require
MR. GRIMES: I would contend that if there were,
they were revealed through the process of going through
GALL, and looking at the typical treatment of system design,
vis a vis the aging management programs.
I am not going to believe that some of those
resolved issues will stay resolved forever, because I think
that some of those issues might emerge again in the future
as new operating experience puts a different perspective on
the nature of the question.
DR. SEALE: That's as good an answer as I can
expect a this time.
MR. GRIMES: And we want to emphasize that there's
a process aspect of license renewal that says that we do not
expect that the current licensing basis or an extended
licensing basis is going to -- is fixed.
We expect that the process, as it evolves in the
future, might identify new regulatory requirements that may
have to be backfit on renewed licenses differently than they
would be backfit on 30-year licenses.
DR. SEALE: Okay, that answers my question.
CHAIRMAN BONACA: I have a more general question I
would like to ask. You know, regarding the spent fuel pool,
I mean, I guess from the beginning there was a feeling in
the early designs and even in current designs, that the fuel
that is inside the reactor has a number of barriers from the
cladding to the RCS to the containment and a lot has been
done to talk about that, to defend those barriers, to do all
Now, the spent fuel pool is a different thing. It
still has a number of active systems, like, for example, the
spent fuel pool cooling system that for some plants, and
maybe for many plants, is not part of the licensing basis.
We have seen examples of those, and so therefore
there are no programs addressing those components, except in
an example we have seen where the statement was that in the
case there was a loss of inventory to the pool, then it
could may be made up through high pressure injection that is
a safety grade system which falls into the scope of license
I am still wrestling with that issue, if there is
an oversight tied to the whole history of the licensing of
these power plants, with a specific issue of the pool versus
whatever is inside the reactor. And I just would like to
have your thoughts about that.
I mean, the results of it is that you have a lot
of components which are not going to be in the scope of
license renewal for the spent fuel pool. You're relying on
an emergency system that will have to make up water as you
begin to lose it.
And, granted, there are a lot of considerations
there insofar as timing available for those actions, but
still it left a question in my mind, you know, the box of
the rule is too tight for this particular issue.
MR. GRATTON: As far as the review of spent fuel
pool cooling systems and the design of those storage
facilities, you can kind of break them up into two groups:
the ones where there's cooling systems that are
safety-related, and in which case, a boiling event that
results in evaporation of water from the system is not
within their design basis. They're not design to have a
Because the seismic -- because the pools
themselves are seismically-qualified, you're not going to
have, within the design basis, a loss of the coolant below
whatever the design limits are, you know, the physical
penetrations of the pool.
So, in that group of plants, you have a cooling
system that will prevent boiling, and you have a
seismically-qualified pool itself that will retain the
CHAIRMAN BONACA: And the cooling system is within
the current licensing basis?
MR. GRATTON: And it would be within the current
licensing basis. The other group of plants are the ones
that you're speaking to right now.
And within their licensing basis, they're required
to have a seismically-qualified safety-related makeup water
system or a redundant, one that satisfies the Staff's
review, a series of these things that provide some sort of
defense-in-depth, let's call it, you know, several of these
makeup systems that provide, you know, additional coolant
inventory in the event that there is a boiling event.
The pool is still required to be
seismically-qualified. And also there are no drains to the
pools, or the capability of siphoning the pool, in the event
that the cooling water system was as source of a siphoning
There are passive anti-siphon devices on all of
the penetrations that go into the pool, so they can't begin
a siphoning event.
So the way that you would maintain water in the
spent fuel pools is through this CLB makeup water system.
That would be included within the scope of license renewal
because it addresses a design basis event for the pool,
which would be some sort of a loss of cooling or a seismic
event that would take out the cooling loops on the
If they were also required to have a ventilation
system to support that process of ventilating the pool, that
would also be included within the scope.
But those calculations would be described in the
SER, and that would capture them within the scope of license
renewal. So when the Staff goes to do their review, they
have to assess what is in the documents that describe the
licensing basis, and ensure that the licensee has included
those on the diagrams, the scoping diagrams, or somehow else
captured a description of those components and included them
So, to summarize, the ones that are
seismically-qualified, the cooling water systems, they're
clearly within there, and you would expect to see them.
The other ones are not so clear, and you'd have to
identify which systems they rely on to provide makeup water.
CHAIRMAN BONACA: I understand that. And on the
other hand, you've talked about mitigation. The question I
had was more about if you have piping connected to the pool
that is not being monitored for degradation, could you
postulate that the frequency or the probability of a leakage
through, for example, a hole in one of these pipes could
increase the frequency of a spent fuel pool drainage?
Are you looking at those things when you're
looking at an application? Are you checking that there are
no check valves in the pipes?
MR. GRATTON: That's part of the current licensing
basis. That's a Part 50 question about the adequacy of the
design. We bring that in, the Part 50 design, into Part 54.
We know what the Part 50 design is, and we just
make sure that they have included the components that are
relied upon in Part 50.
CHAIRMAN BONACA: Okay.
MR. GRATTON: To ensure that, so --
CHAIRMAN BONACA: So, you're looking -- I mean,
so, even for the older set of plants, there is a review of
that and a determination of whether or not the frequency of
the draindown is increased by the aging of components?
MR. GRATTON: We do not look at whether or not the
frequency of a draindown is increased by the aging of those
components. As far as reviewing a spent fuel pool
application, you know, in the largest sense, when you go in
to look at that review and you say what would a seismic
event do to this system? What do you assume?
It doesn't make any difference whether it's in
year 35 or in year 55, you would assume that the piping
systems have failed and would drain the pool to the
penetration points, and then you'd say, okay, what do they
rely on to maintain the stored fuel in a safe condition?
It really doesn't make any difference, whether
they've gone past 40 years or not. You just assume that it
MR. LEE: I can go into the GALL report, if you
CHAIRMAN BONACA: I think we should proceed, yes.
MR. LEE: Okay, thank you. Can I have Rich and
Yung come up to the table, please?
I'm going to start the introduction to the GALL
report. As indicated earlier, this has been a significant
Agency effort involving the NRR staff, the Research staff,
and the contractors, and I have -- from Argon National Lab,
and Rich Morante from the Brookhaven National Lab. They are
the respective Project Managers at the Labs, and Brookhaven
is responsible for the electrical and structural portions of
And Argon is responsible with the mechanical
portions of GALL, and also the SRP.
And the GALL report, we have also been given a
NUREG number, and it would be called NUREG 1801. And it is
a systematic evaluation of aging and programs, aging
It builds on the previous reports, NUREG CR
reports, and this is -- which is based on extensive --
Office of Research, nuclear -- aging research program
And the GALL report reviews the -- identifies the
components, and then it identifies the environmental
material that components are in. And then it -- the
applicable aging effects that need to be managed.
Identifies the aging management programs; and then
it uses the ten-element generic evaluation to determine if
that program is adequate to manage that aging effect.
And if that program is determined to be adequate,
then the GALL report will say no further evaluation is
If not, then a re-evaluation is recommended, like
Dr. Bonaca earlier indicated, some places we would actually
put the -- the -- should be; other places, we would not
And this is the two-page format. It goes from the
component all the way across to the program, and the
evaluation and the conclusion.
Like we have discussed earlier, we are thinking of
combining these two into a one-page format, maybe combining
some of these columns or deleting some redundant
information, and then using what we call the Chapter 11, you
know, more extensively.
The GALL report, the big GALL report is called --
which is the -- of all the aging factors and tables, but to
make it a little more user-friendly, we prepared a summary
that we call -- .
This describes the process which is the
ten-element evaluation, and then describes how we should use
GALL, so we are going to use GALL as an approved topical
report type, and then reference the SRP and then focus the
staff review in the areas where GALL determines programs
should be augmented.
And then we also provided a bridge between the --
, the GALL tables, and the SRP, which captures the essence,
so you go -- from SRP to specific pages in the catalog.
And also it has some appendices in here which are
basically indexes, should someone want to look up certain
things, you go to these indexes.
DR. LEITCH: I have a couple of very minor
comments that I think would help to make the flow of the
documents a little easier.
On the very first page of Volume I, the index, I
think it would be helpful if we said that where tables on
pages 5 through 39, but it doesn't really describe what's
going on in pages 5 through 39. See where I mean, the very
first page, Volume I.
MR. LEE: Understand. Yes, that's a good comment.
DR. LEITCH: And also on page iii, I think it
might be helpful to indicate that the pages referred to
there, beginning, you know, at page 45 and on down, were
page numbers in Volume I.
MR. LEE: Okay. Because the heading says --
DR. LEITCH: Which is correct, but it might be
helpful if it indicated that those page numbers were pages
from Volume I. They're minor points, but it would just make
it a little easier to read, I think.
MR. LEE: Okay. We are so emersed in this thing
that we don't see things like that, so thank you for
pointing that out.
Here is the Table of Contents of the GALL report.
And most of the technical evaluations are in Chapters 2
through 8, and you'll hear presentations later this
afternoon and tomorrow, structure-by-structure, and
And the way we have in here, like we discussed
earlier, is this Chapter 10, okay. They are field aging
management programs that addresses TLEAs that we have
accepted in the initial license renewal reviews, and we
documented them in there.
And also in here we have the Chapter 11, Aging
Management Programs. The way GALL report is -- double-side,
double-page format, it goes from component aging effects to
program, and then the program ten-element evaluation.
That column with the ten-element evaluation gets
very long, and also is very repetitive, because the programs
are repeated, I guess, referred to in many places.
So that was actually an NEI comment to create a
Chapter 11 to put the program evaluation just in one place,
okay, and -- from the table.
For the August version, we did not have time to
wholesale make the change, so what we did was, for places
that was easier for us to make that change, we did it, so we
put it in Chapter 11, which are the ten-element evaluation
of the programs.
And then in the table, we refer to it. And other
places, we just kept with the table, and the way they are
thinking in terms of the single-page format for the final
version, we will probably put -- for the programs to Chapter
11 in one place, and that will be much easier for us, just
to handle the document.
CHAIRMAN BONACA: You talk about the final
MR. LEE: That's the March one.
CHAIRMAN BONACA: The March one, after you get all
MR. LEE: Yes.
CHAIRMAN BONACA: So you are going to work on the
format still as you gather new comments?
MR. LEE: That's correct.
CHAIRMAN BONACA: The question I have is regarding
-- you already have substantial information regarding PWRs
and BWRs. I imagine that the experience for the first two
applications is reflected in this?
MR. LEE: That's correct, yes.
CHAIRMAN BONACA: What about the BWR VIP program?
Have you --
MR. LEE: Yes, we updated this. Actually, there
was an industry comment on that that included VIP, so we
included the VIP.
CHAIRMAN BONACA: We have not seen those yet, but
will you please at some point give us a description a little
bit of how you have folded in this information, and what
additional information you expect to see?
MR. LEE: Yes.
CHAIRMAN BONACA: The question, I guess, I'm
pursuing, is, we have not seen yet any BWR application for
license renewal. I mean, it hasn't come yet as an SER.
MR. LEE: I understand.
CHAIRMAN BONACA: The Staff has gone through the
first application, I imagine, to a substantial degree. Has
that information already been brought inside the GALL
report, and if not, when you finalize this GALL, okay, I'm
expecting to see a lot of new data coming from the first
application of BWR.
How are you going to fold that information into
this kind of document, unless it is a living document of
MR. LEE: I understand, yes. This afternoon, when
we discuss Chapter 4, you'll hear about the VIP.
CHAIRMAN BONACA: Okay.
MR. LEE: That information has been folded into
CHAIRMAN BONACA: Okay.
MR. LEE: Even though the VIP is not complete, but
we incorporated it. By March 2001, it will be complete.
CHAIRMAN BONACA: But again, you'll not be able to
capture the information on the first review of the BWR.
MR. LEE: Actually, some -- the NRR staff work on
GALL on reviewing that right now.
So we rely on them to bring the information to
CHAIRMAN BONACA: Please, as you go through the
presentation today, when you have a chance, it would be
interesting to see, you know, how that process took place.
MR. LEE: Okay.
CHAIRMAN BONACA: Of folding in an ongoing
evaluation of a BWR into this kind of document. Thanks.
MR. LEE: Okay.
DR. SHACK: The Hatch itself must be a fairly
unique BWR, because it presumably doesn't lean so much on
the VIP documents, because they're not approved yet. I
would expect future BWRs to be heavily VIP-dependent.
MR. LEE: I guess all the BWRs are committed to
the VIP program; that's correct. But like I said, Hatch. I
guess Chris wanted to add something to that.
MR. GRIMES: Yes, Hatch relies heavily on the BWR
VIP documents as well. And there -- we expect that we're
going to have the BWR VIP SERs completed in time to support
a final safety evaluation for Hatch.
DR. SHACK: Now, does the Hatch commodity approach
overlay this structure in some reasonable way?
MR. LEE: You mean the format?
DR. SHACK: Yes. When people treat things as
commodity groups, how does that sort of match up to this
MR. LEE: Yes, I guess that's an interesting
question. The way the NEI standard format has it, okay,
they provide an option, a standard format, but then you can
use a system approach or you can use a commodity approach,
okay? So it provides links. It's one format and you -- to
it, so if you're a commodity, you point this way; if you're
a system, you point this way.
But the overall --
DR. SHACK: Covers both?
MR. LEE: Covers both, okay, and GALL will be able
to cover both.
I'm not going to discuss Chapter 10 and 11
anymore. We have already gone for a TREA. Chapter 11, we
are going to discuss it when we actually talk about
individual structures and components, and so the programs
that come up when you hear the presentation this afternoon
and tomorrow on the structures and systems.
DR. SEALE: I don't know, I look at that list, and
then I ask myself, what do I do with a commodity list, and
it looks to me like a bunch of shotgun pellets on that whole
list there. It's distributed, the commodities are
distributed throughout that list.
MR. LEE: I guess it depends on how you do a
commodity. If you have a couple of hundred commodities --
MR. GRIMES: As in anything in life, you can do
something in the extreme, and make a mess out of a perfectly
good concept. The GALL actually represents a
three-dimensional model, and there is, in my view, an
optimum balance between the level of detail that you go into
to describe components and systems and the applicable aging
effects in the level of detail that you put into the
description of the programs.
You can go overboard with commodities, but you can
go overboard with systems and then lose the picture about
the aging management programs.
So, hopefully we'll be able to reflect on the
Hatch experience and identify some appropriate balance.
DR. SEALE: Good luck.
MR. LEE: The next presentation is actually a
mechanical presentation, Chapter 2 on containment, and I
think this might be a good place to break, if you want,
unless you want to start getting into technical discussions.
Do you want to continue or do you want to break?
From now on, it's all technical discussions of systems and
CHAIRMAN BONACA: Okay, then let's break now and
resume at a quarter to 1:00.
[Whereupon, at 11:18, the Committee recessed for
luncheon, to be reconvened this same day at 12:45 p.m.]. AFTERNOON SESSION
CHAIRMAN BONACA: Okay, let's resume again, the
Subcommittee Meeting on License Renewal. We are now
reviewing the GALL report.
MR. KANG: My name is Peter Kang, and I'm with the
License Renewal, and to my left is David Jeng from DE, and
Jim Costello from Office of Research.
And Jim Davis is on the DE staff, and Joe
Braverman is from BNL. They were the ones that reviewed the
content and also we had a lot of coordination among
ourselves and NEI.
Okay, for Chapter 2, Containment, so far, we have
NEI comments on the following five items, and the first one
is inaccessible areas and the number one is -- the next one
is the protective coating monitoring and the maintenance
program issues, and then visual examination, BT-1 versus
BT-3 for cracking, and then elevated temperature for
concrete, and the last one is for settlement.
As for the inaccessible area, GALL recommended
aging effects of inaccessible area to be further evaluated,
and our basis, our technical basis for the evaluation is
based on NUREG 1611, which states the plant-specific aging
management -- aging effects of inaccessible areas should be
reviewed, even if accessible area doesn't show any sign or
indications of degradations.
And also, it further identifies four aging
effects. Three of them is a concerned aging effects for
concrete inaccessible areas.
And this is due to -- this is -- aging effect is
increasing in porosity and the permeability and the
cracking, spalling, and scaling due to leaching of calcium
hydroxide and aggressive chemical attacks and the corrosion
of embedded steel.
And the one concerning for steel liners or steel
structures is a loss of material due to corrosion.
So, those are the inaccessible areas. And we had
-- the last NEI response told us they are still evaluating
whether they should agree with the Staff or they disagree.
And also for this area, we have developed aging management
program for IWE-4 for steel and IWL for concrete, and IWF
for inspection of support components for BWR containments.
So, the aging management program, it has provided
for -- has developed and it will guide how you evaluate,
what to look for, and what is the technical basis.
So, also the next one is protective coating
monitoring and maintenance program. This is to --
CHAIRMAN BONACA: Before you move to that, do you
want to --
MR. KANG: Do you want to talk about the first
CHAIRMAN BONACA: I think to see that you're
recommending inspections of the inaccessible areas, right?
MR. BRAVERMAN: Either inspection or there is some
guidance in the GALL section, particularly Chapter 3, which
provides agreed-upon criteria, which, if they can
demonstrate, then they can show that that's not a
significant aging effect.
For example, you know, for concrete aging effects
below grade, which is not inaccessible, if they could
perhaps monitor the aggressiveness of the groundwater and
show periodically that it does not have aggressive chemicals
beyond a certain threshold, and then that's one way to
CHAIRMAN BONACA: But do you have to have any
indication of an adverse environment in an inaccessible area
before you go to inspection, or does the NUREG directs to
simply implement an inspection, or the management step that
MR. JENG: We want the -- I'm David Jeng. We want
the applicant to address these particular four areas which
Peter just mentioned, locations where it's inaccessible, but
it doesn't indicate degradation going on. It's a standard
position that we wanted, to address this one, considering
CHAIRMAN BONACA: But I'm saying so, if the
applicant can say that there is no indication that the
environment present in the inaccessible location could
possibly cause a certain degradation --
MR. JENG: That could be one way.
CHAIRMAN BONACA: All right, I just wanted to make
sure. So that's considered?
MR. JENG: Yes.
CHAIRMAN BONACA: All right, thank you.
DR. LEITCH: Since this is the first issue we're
speaking about, I'd just like to make sure that I follow
through the GALL report.
Which particular issue are you talking about?
MR. KANG: A.1.1, yes. That's for the concrete,
yes, and then there is a steel.
DR. LEITCH: There are a number of concrete
elements under that.
MR. KANG: Yes, sir, that's page -- the first one
DR. LEITCH: 2-A-4.
MR. KANG: The bottom one.
DR. LEITCH: The bottom one?
MR. KANG: Yes, sir.
DR. LEITCH: Okay, now --
MR. KANG: And then clearly --
DR. LEITCH: That then refers us to Chapter 11,
MR. KANG: S-2 is Chapter -- yes, S-2; in other
words, a structure, Group Number 2, yes.
DR. LEITCH: Okay. And in the further evaluation,
it says yes.
MR. KANG: Plant-specific, yes.
DR. LEITCH: Okay, I understand.
MR. KANG: Okay.
DR. LEITCH: I just wanted to make sure I had the
right place, and understood it.
MR. KANG: That's only for the concrete, and the
steel area is in the BWR or the steel inaccessible areas is
DR. LEITCH: Okay.
MR. KANG: That has the steel elements and similar
DR. LEITCH: Okay, thank you.
MR. KANG: Yes.
Any other questions on the first?
MR. KANG: Second one is to minimize the loss of
material from corrosion. GALL recommends the protective
coating monitoring, and the maintenance program, to be
provided for carbon steel surfaces inside of containment,
such as steel liners and penetrations and hatches.
And this also the same title program ANP has been
developed in S8 in Chapter 11 sections. Any questions on
MR. GRIMES: I'll point out that there is still a
controversy with the industry on whether or not protective
coatings is a component or a mitigation feature for other
So we have an opportunity to clarify that point.
MR. KANG: Okay, the third one is the adequacy of
visual examinations between a VT-1 versus VT-3 for cracking.
That is resulted from stress corrosion cracking or cyclic
This area we're talking about -- components we're
talking about is in the penetration sleeves and penetration
bellows or just similar metal welds.
DR. UHRIG: Could you distinguish between the VT-1
and VT-3? What are the differences here?
MR. DAVIS: VT-1 is the most intense. You have to
be within two feet in a well illuminated surface, where VT-3
is the second. I'm not sure why they put it third, but you
have to be within four feet with the same light, and that's
DR. UHRIG: Those are visual, still?
MR. DAVIS: With VT-2, then, you're six feet away,
you can be six feet away, and you don't need as much
DR. SHACK: Does VT-1 in this case involve any
sort of resolution of a gray line?
MR. BRAVERMAN: I believe there is some
requirement about the size of character that you have to be
able to distinguish.
DR. SHACK: Detect, yes. And the code calls for
the VT-3 then, and you're asking for the VT-1?
MR. KANG: Yes. That's the main issue, yes, and
the VT-1 with some supplement test as well.
So this AMP, Aging Management Program for
examination categories has been addressed in IWE, as well as
Appendix J. This is S-4, I think.
DR. SHACK: When you guys endorsed IWE, was there
any kind of a restriction that VT-3 was not very good for
I mean, the code calls for it all the time. And,
you know, you're just never going to see cracks with it.
MR. DAVIS: You're not with the VT-1 or 3.
DR. SHACK: Well, you have a better chance.
MR. KANG: Okay, the next one is since loss of the
strength in the annulus can occur, it does occur due to
elevated temperature for concrete components.
And the GALL recommends plant-specific evaluation
should be implemented for any portion of those concrete
components that exceed the temperature limits.
And the temperature limit is being 150 Fahrenheit
for a general area, and 200 degrees for local areas.
So, this is a region of interest is dome, wall,
and the basement and the annulus area. Any questions?
MR. KANG: Okay, the next one is settlement
issues. This one is original licensing basis required to
monitor all the licensee to cracks due to settlement and the
reduction in the foundation strength due to erosions.
And then if no signs of a settlement or settlement
problems were found for ten years or a decade, the staff
gave approval to discontinue the monitoring.
However, for those plants controlled what we in
the GALL report identify here is for those plants
controlling their settlement by using de-watering system,
and GALL recommends the continued operation of those GALL
dewatering systems be verified for the duration of licensing
renewal. That's all we are asking.
CHAIRMAN BONACA: I have a question I want to ask
about. The GALL report specifically speaks of PWR concrete,
reinforced or pre-stressed, and steel containment, but also
when it goes to BWR containment, it separates Mark II and
III concrete, and Mark I and II and III steel containments.
Okay, doesn't Mark I also include certain elements
of concrete that goes with the containment structure? There
is no indication of anything regarding concrete for Mark I
MR. JENG: The Mark I containment there are two
kinds. One is just one particular plant, New Brunswick, was
made of concrete containment, whereas most of Mark I
containments is steel shell containment with backup by the
CHAIRMAN BONACA: That's right; there was backup
concrete. That was the question I had. It seems like when
I look at the tables, and this was a comment by consultant
who reviewed that, is that for Mark I, there is only a
review of the steel portion. There as no review
specifically addressing the concrete portion.
There are backups to the steel that are concrete.
MR. BRAVERMAN: I think the concrete that backs up
the steel in the Mark I steel containment is not considered
part of the containment system; it's other concrete
structure, and so that's handled under Chapter 3.
CHAIRMAN BONACA: Okay, so you will be talking
about that when you talk about Class I structures?
MR. BRAVERMAN: Right.
CHAIRMAN BONACA: I understand.
MR. COSTELLO: In the classic Mark I, the pressure
boundary is --
CHAIRMAN BONACA: Is steel.
MR. COSTELLO: Is steel, right.
CHAIRMAN BONACA: I understand. Thank you.
MR. KANG: Okay. There were several licensing
renewal issues associated with this chapter. And most of
them are addressed in GALL, and most of them are in the
process of being resolved or already has been identified.
For example, first, the 40 and 41, those are
concrete issues. Those issues have been identified and
covered in the GALL to 2A-1 for PWR and B, 2.2 and 3.2 for
BWR, Mark II and III containment.
And then 42 and 107 this is settlement issues, and
dewatering systems. We are addressing this one, so those,
already we did, and transgranular stress corrosion cracking
of containment bellows, this we'll be addressing under
cracking due to stress corrosion cracking or cyclic loading.
And also IWE and IWL inaccessible area, that was
the first bullet on that item. Okay, and then there is a 50
and 84 has been deleted. So, also, let's see -- IWE and IWL
operating experience, new -- all our aging management
program addresses operating experience, so it should cover
And also 87, we have a containment temperature
issues, and this is also addressed, so pretty much we
covered on this license renewal issues.
MR. SHACK: This is also closer to the format that
I assume is going to be adopted for the rest of GALL then,
when you'll have a sort of generic reference to Section 11
and the only thing that will appear will be the additions or
MR. KANG: For plant-specific basis, right? Yes.
CHAIRMAN BONACA: Next, Chapter 3. Hai-Boh Wang
is going to make the presentation.
MR. SHACK: While we are waiting, what do people
actually do with the inaccessible areas when they -- what
are their options? When you have the corrosion or you have
to inspect the inaccessible areas, what do they actually do?
MR. JENG: For instance, in the case of Oyster
Creek the shell, the sand cushion areas they discover some
water leaking through the sand cushion, pipes, and they did
not see actual corrosion going on on the shell proper but
because of this indication -- they went in to evaluate the
shell, whether they lost the material by UT and several
different kind of examinations to check the thickness.
They took an externalized area and checked the
thickness, where that had changed from the original
thicknesses and the minimum thickness by design, so this was
implemented, so there is something one can do to ensure that
current licensing basis is fully still met.
CHAIRMAN BONACA: I have a question on Slide 28.
We talked about cracks due to settlement and reduction in
foundation strength due to erosion.
If you have erosion taking place on the basemat,
that is the time dependent effect which was not really
covered in a time limited analysis because it wasn't planned
to be there. I mean it was just found to be there.
MR. JENG: This is unique -- in the case of, say,
Seabrook plant there original design called for permeable
porous concrete layer below that containment mat.
MR. SIEBER: That's right.
MR. JENG: The idea was to use that layer because
of it being porous to get the groundwater to seep through as
part of design configurations, and a couple decades later
they found out that due to duration of this porous concrete
there is more loss of the material than they expected and
this is the type of situation we want to make sure we cover.
If you are having such a special design then we
want the Applicant to address what situation is rate of
degradation, what potential loss of material beyond your
We want them to address it on a specific plant
CHAIRMAN BONACA: Yes. The question I am asking
is regarding the addressing -- what criteria do we use?
I mean if you know that you are pulling out "x"
pounds a year or hundreds of pounds a year of concrete,
okay, that has been leached out or lost through erosion I
guess, how do you develop criteria for what is acceptable I
mean since it is an age-dependent effect that continues to
So I would say a few pounds is okay and a hundred
pounds is okay, but then what are the criteria there?
MR. JENG: Okay. In the context of the license
CHAIRMAN BONACA: Yes --
MR. JENG: -- what particular criteria we are
going to use, that will be based on the engineering
principles, adequate safety strength, loss, and they are
mostly covered in the Part 50 SRP, basic coverage, but one
has to go on a case-by-case basis.
I cannot answer you specifically what we should
CHAIRMAN BONACA: Okay.
MR. JENG: -- depending on the plant situation,
the degree of erosion and what measures are being taken to
mitigate the situation and one has to make a judgment at
that time to stop and make an adequate judgment.
CHAIRMAN BONACA: So it is not a time limited
analysis. It is more like monitoring the erosion and --
MR. JENG: Yes, continue monitoring one case or
some intensified inspection, checking to take a sample piece
to check the strength's variability and relaxing. Such are
the possible approaches but the specific disposition should
be determined on the particular case situation.
MR. GRIMES: Dr. Bonaca, I would like to point out
that one of the attributes of an Aging Management Program
that we look for is the acceptance criteria to the extent
that they can define particular acceptance criteria or
inspection techniques but we put a heavy reliance on the
corrective action process that evaluates specific findings
to determine whether and what kind of corrective action is
warranted to ensure function, so there's for a number of the
system walkdowns for example there's a general inspection
practice that says look for indications but then the
acceptance criteria is dependent upon what kind of
indication is found against an evaluation that the structure
or component can continue to perform its intended function.
CHAIRMAN BONACA: So you would at some point,
somewhere there should be some criteria on what you are
looking for, so far as consequences of the erosion, and you
expect the licensee to submit those and to present them as
part of the plan, the management plan?
MR. GRIMES: As part of the description of the
program we would expect them to identify acceptance criteria
to the extent it is practical.
For example, David mentioned that for the shell of
a MARK I Taurus there is an evaluation of shell thickness
and there is a minimum thickness associated with the ability
of the containment to continue to be a pressure-retaining
CHAIRMAN BONACA: Okay, thank you. My name is
Hai-Boh Wang with the License Renewal and Standardization
On my left is Jim Costello from the Office of
Research, Richard Morante from Brookhaven Lab and David Jeng
from Division of Engineering, NRR.
On my right is Thomas Cheng from the Division of
Engineering, NRR and Jim Davis from NRR -- they will be able
to answer any tough questions from the committee.
Now this group of structures covers all the
structures in the scope of license renewal except the
containment. That means the containment internal is part of
it and all the other structures, steel and concrete and
liner, plus component support from pipe support to reactor
support -- it covers the various areas.
That means there's a lot of NEI comments.
Here I have a list of four but the five previous
ones listed on page 28 also are applicable to this group of
structures, plus some others we'll discuss tomorrow also
apply to the group of structures.
We don't want to repeat our comments -- just some
unique ones to bring up here.
The first one was application of the structural
monitoring program. Now NEI back in '96 proposed a
structural monitoring program in a document called NEI 96-03
that tried to cover the structural monitoring program for
both the maintenance rule and the license renewal, submitted
it for Staff review.
The maintenance folks thinks the program is
wonderful. They accept it, but license renewal considered
the program less depth, less substance for what we need, so
they made a lot of comments, sent it back and asked them to
They said they are going to revise it but they
never did, so eventually they still want to push existing
maintenance structures to be as part of our license renewal
monitoring program. Now we do not accept that so we created
in Chapter 11, S(6) as our version of the structural
management program, which is evolved from the maintenance
rule but a little bit more, because the maintenance rule
only goes to the system and structural level, so license
renewal wants to go to the component level.
Now that is a major difference. There's other
differences as well, so in our opinion if any Applicant can
address their program, Aging Management Program, similar to
our structure management program we will consider its
However, if they differ from ours, they have their
own specific management program different from ours, the
Staff will take it for review to make sure it complies to
our structural management program or equal to it.
CHAIRMAN BONACA: Could you give us an example of
where you didn't find 96-03 sufficient for license renewal?
MR. WANG: First of all, it goes by structures and
not components and theoretically if the structure is missing
a wall the structure stands. The maintenance rule
theoretically says okay -- for license renewal is not okay
and plus the maintenance rule does not care about seismic
CHAIRMAN BONACA: These are the main differences?
MR. WANG: There's others. I didn't bring the
list. There is a long list.
CHAIRMAN BONACA: Sure.
MR. CHENG: This is Tom Cheng. I would like to
add something to it.
I think the Staff accepts the existing program
developed for the implementation of maintenance rule.
However, they needed 10 elements documented in the GALL and
also in the SRP, so they need to meet those 10 elements, so
that is the difference also.
CHAIRMAN BONACA: So NEI 96-03 really was
developed for the maintenance rule?
MR. WANG: Eventually. They never submitted it,
so this wasn't -- the Staff never was endorsing that
document per se.
CHAIRMAN BONACA: Okay.
DR. KUO: I believe I can add to it.
The maintenance rule finally they had for
implementation of the maintenance rule they had 93-01,
Revision 2. That is the NEI guideline that they are going
with, and another point I want to clarify is that, yes, the
licensee can have a program to meet the maintenance rule and
at the same time meet the license renewal rule, as long as
they can meet the 10 elements that we specified in the GALL
It doesn't mean that we will not accept the
programs for the maintenance rule at all. As long as they
can demonstrate that they meet the 10 elements in the GALL,
in the SRP criteria we will accept that program.
In fact, we have done that in the review of Oconee
CHAIRMAN BONACA: Okay, I understand now. Thank
MR. WANG: The next bullet is shrinkage and
aggressive environment of masonry walls.
Formation of walls -- there's a lot of
safety-related equipment on support on masonry wall or the
masonry wall could be a missile protection device so it
needs to be functioning and we want the Applicant or
licensee to have a program to manage their aging.
NEI questions if they already comply to the NRC
Bulletin 80-11, which is Masonry Wall strengthening program,
back in 1980 as it should be adequate, and the Staff
proposed Chapter 11, S(5) the masonry wall program, which
more or less complied to 80-11.
If the licensee can follow the procedure of that
bulletin, our program of the 10 elements, the program should
be considered acceptable.
MR. MORANTE: On this particular program I would
like to add that in addition to 80-11, the bulletin, there
is an Information Notice 87-67, which reported the results
of field inspections of masonry walls after the
implementation of 80-11 and they did find some problems with
maintaining the valuation basis that was established in
80-11 and the program that we have defined in Chapter 11,
S(5) here is based very heavily on the findings of that
reported in that Information Notice.
Recommendations were made for periodic monitoring
for new cracks in the walls and also administrative controls
to ensure that the valuation basis is not invalidated by
adding new equipment to the plant that could potentially be
hit by a wall that prior to adding it the wall was outside
the scope or reclassifying systems from nonsafety to safety
as a result of some future review.
What we have tried to do is incorporate within
this Aging Management Program S(5) is the definition of the
scope from both 80-11 and any subsequent walls identified
under A46 program and a management program which reflects
the insights that were identified in Information Notice
CHAIRMAN BONACA: Okay.
MR. WANG: The third bullet, the stress corrosion
cracking of fuel pool stainless steel liner. It mainly is
the spent fuel pool.
NEI says each plant has a specific program to
manage that cracking, mainly with the leak monitoring
program. If the leakage exceeds a certain amount they will
do something about it and it will be on a case by case basis
when the Applicant submits to the Staff review and seeks the
adequacy against the 10 elements.
CHAIRMAN BONACA: What was the difference between
NEI and the Staff again?
MR. WANG: We don't have any Staff. We just say
the Applicant has to submit a program for us to review
against the 10 elements.
CHAIRMAN BONACA: Okay. This was an NEI comment.
MR. WANG: NEI comment says the Applicant/plant
already has their program -- we don't have to bring nothing
up. Okay? There is no new Aging Management Program
CHAIRMAN BONACA: And for example if you look at
the 10 elements you would expect to see for the program the
acceptance criteria, corrective action --
MR. WANG: Right. GALL -- detection of aging and
so forth, so forth.
The last one was the loss of material --
CHAIRMAN BONACA: Let me mention just for
curiosity here, if you had a leak -- that's what they are
going to find. They are going to have leaking from stress
corrosion cracking so you would expect to see what the
recovery actions will be also, how you recover the pool.
MR. WANG: Jim?
MR. MORANTE: Would you repeat that?
CHAIRMAN BONACA: Yes. I am saying that as part
of these criteria that you would expect to put in the
program you would want to know how the licensee -- not only
he would monitor and trend leakage, the detection of the
aging effects, and the acceptance criteria is related to the
corrective action, but also the recovery action I imagine on
how do you recover from such an issue.
I mean you have a liner with a side of spent fuel
and it's leaking so --
MR. MORANTE: Well, any Aging Management Program
that would be defined and adequately met the 10 elements,
one of the attributes, one of the attributes is any
corrective actions that they would have to take to resolve
I would like to point out one thing to Hai-Boh,
that the current version of the GALL tables in Group 5 of
3(a), on this particular item there had been significant
discussion back and forth between industry and the Staff.
Agreements from 1557, the Staff basically accepted
existing leak chase monitoring systems as an adequate
methodology for managing aging of the liner at that time.
If we have had a change in position it's a very
Just to clarify, if you were to look in the GALL
Chapter 3(a) right now the indication is further evaluation
on this particular item.
Stress corrosion cracking of liners, stainless
steel liners, and the identification is that the basis for
it is that the current systems that are used by the plants
are considered effective programs to monitor this.
MR. WANG: So on page 3(a), 5-9.
MR. MORANTE: Yes.
MR. WANG: On -8 and 9.
MR. MORANTE: I know we have gone back and forth a
few times on this.
CHAIRMAN BONACA: Okay. I mean I am trying to
understand the extent of the understanding of the Staff -- I
think it would be challenging to have to fix a hole in the
liner just because you have got fuel inside that, spent fuel
and water, so you would have to have some corrective
actions? I don't know.
MR. GRIMES: Dr. Bonaca, I think this is an
example of an area where we would not expect the program to
specifically define corrective actions for all of the
possible ways that you might develop cracks in the liner. I
would expect that the quality assurance program would
evaluate the specific results and it is conceivable that
there are a variety of different ways that they could take
corrective action that would depend on the specific
For example, I would not expect that this program
description would include things like how to try and protect
the fuel and still get at the liner to repair it.
There are some real challenging underwater welding
techniques that probably would have to be evaluated on a
case-specific basis before you start talking about trying to
repair a crack in the liner.
In some cases they may identify ways to live with
cracks in the liner and still be able to satisfy their
CHAIRMAN BONACA: Yes. I asked the question
because it seems to me that in many of these issues of
defense-in-depth they are looking at ways to recover what
margin you have and that would be an issue that goes to
I would not consider the liner in the pool the
same level of importance as a liner in a tank that doesn't
do anything else but keeps the water in, and so it would be
a different significance there and I was wondering if in
fact there will be any criteria.
You are telling me that there aren't.
MR. GRIMES: The criteria would basically go back
to the description of the intended function and ability to
continue to maintain seismic loading conditions and other
design loading conditions. An evaluation of a finding that
there is a crack in the liner would then be cranked into an
evaluation of the intended function under all the loading
conditions and a corrective action would spring from that
CHAIRMAN BONACA: Sure. Okay, thank you.
MR. WANG: Bullet Number 4 is the loss of material
of concrete elements for water controlled structures, mainly
we are talking about the intake channel or the intake
structure or a water containing dam, concrete dam.
If you walk down the plant you will see the
channel, the intake channel of the concrete also cracks.
Sometimes they have chunks of concrete missing and something
should be done. We ask a question.
NEI disagrees. If the Applicant follows NUREG
Guide 1.1247 the problem should be resolved if the structure
is under NRC jurisdiction. If the structure is under
Federal Energy Regulation Commission, FERC's jurisdiction,
FERC has their own regulation, their own program to take
care of it.
The Staff accepts that and puts it into a table,
MR. SIEBER: 3(a)(6)(9), right? I think in Tab 11
it also allows the Army Corps of Engineers' process is also
MR. WANG: Yes, for the dams.
CHAIRMAN BONACA: Okay. Any other questions from
the members regarding structures and components, support?
MR. WANG: Since the components fall under ASME
Section 11, IWF jurisdiction.
It is under the jurisdiction of ASME Section 11,
IWF, all the inspection and maintenance. Correct me if I am
MR. MORANTE: Well, Chapter 3(b) probably comes
closest to covering things you would call commodities.
It is intended to cover support for many different
systems in the plant.
The first part of Chapter 3(b) covers supports
that would be within the scope of ASME Section 11 IWF. That
would be Class 1, 2, 3 and MC piping and component supports.
That is all incorporated in B(1); B(2), sections
B(2) through B(5), cover other types of supports within the
plant that would be outside the scope of ASME and cover a
wide range of different components that are supported in the
We attempted to identify those aging effects and
aging mechanisms that we believe to be appropriate for these
different classes of supports and to identify how they might
For the most part, once you get away from supports
on ASME class systems, the only existing program that can be
credited in most cases other than a boric acid corrosion
program for things inside containment basically goes back to
the structures monitoring program which we anticipate for
most plants will be based on their maintenance rule program,
and so the writeup in Chapter 11, S(6) is expected to apply
to a large number of structural items within the plant that
are not covered, say, by ASME code.
Does that answer your question?
CHAIRMAN BONACA: Yes.
MR. WANG: The next slides will cover the license
There are eight of them, but there is a ninth
one -- it's 98-041 -- aggregate. I don't remember too many
cases in the history of the American nuclear industry where
too many reactions with the aggregate happened. Maybe once
or twice, the maximum. That can be taken care of by a
structural management program as well.
039 is a one-time or baseline inspection of
structures. NEI was against that one, thinking the
maintenance rule has inspection program that should cover
license renewal required. We agree. Our intention was
since the scope of license renewal and maintenance rule does
not coincide 100 percent, there are certain areas license
renewal does not cover the maintenance rule or maintenance
rule does not cover license renewals.
So in license renewal the licensee or the
Applicant should develop a site specific program or whatever
to give the Staff some assurance that is the component or
structures or systems can perform their intended function
through a baseline inspection, one time inspection.
CHAIRMAN BONACA: When would the inspection be
MR. WANG: Any time before the 40 year is up.
CHAIRMAN BONACA: This is one that you would want
to perform shortly before you enter the 40th year?
MR. WANG: Yes -- or if -- our contention is if
they do it at, say, 15 years or 20 years, since the plant's
been there for 20 years, there is no degradation, no
deterioration of the structure, the component, it would be
hard to assume under 20 years the component would degrade
such that it could not perform its intended function.
If, for instance, after 20 years they found quite
a few degradations, we'd assume at 40 years we would need
them to do it one more time, another baseline inspection.
CHAIRMAN BONACA: So this will be a little bit
different from the other one-time inspections that you do.
You do the baseline that you would do on all
structures to verify that --
MR. WANG: This one we merged with the structural
monitoring programs, because from time to time you have to
monitor the structure and if you find anything degraded you
are going to mend it.
CHAIRMAN BONACA: And so this is going to be -- I
mean you said that NEI was violently opposed?
MR. WANG: Yes.
CHAIRMAN BONACA: And what is it now?
MR. WANG: Now it's the structural monitoring
program, part of the structural monitoring program.
CHAIRMAN BONACA: But it is going to be done?
MR. WANG: Right.
Freeze-thaw damage of concrete has been discussed
previously and different settlement in containment and
things we are talking about, other structures other than
containment, this seems odd but we do, containment internal
structure is part of this structural group so that is
applied to this structure.
Reinforcement corrosion -- that means corrosion in
embedded steel or corrosion of reinforcement is concrete.
That one's been -- the structural monitoring program will
take care of that too.
CHAIRMAN BONACA: For reinforcement corrosion, do
you, are you looking for indications? Are you looking for
the environment or are you looking for inspections?
MR. MORANTE: All of the above.
In the long history of discussion between the
Staff and industry, which culminated in NUREG-1557, where
there are many agreements documented, these aging effects
and aging mechanisms were identified and also identified
were bases, technical bases for considering these to be
non-significant, and in some cases plants have and can
justify the non-significance of certain types of degradation
based on meeting these criteria, which may have to do
with -- which would typically involve the quality of
construction and in many cases especially for inaccessible
areas would involve the quality of the groundwater.
The big concern is for things that might be
exposed to the groundwater or attack of the concrete by
aggressive groundwater that then might cause corrosion of
MR. DAVIS: What happens is when the concrete
drops below pH of 11.5.
Then the rebar starts corroding or if the chloride
is at a very high level, say like 500 ppm.
It's very difficult to measure that so what NEI
has proposed is that if the groundwater drops below a pH of
5.5 then that will be an indication that the concrete will
drop below 11.5 and they want to use that as their
CHAIRMAN BONACA: So there are very specific
criteria for the monitoring -- water and pH.
DR. UHRIG: There's been a lot of experience with
corrosion, rebar, in bridges.
Has any of that technology carried over in terms
of I thought there were some electronic techniques of
looking at it.
MR. DAVIS: There are very definite ones and they
use cathodic protection on bridges, but that has to be set
up ahead of time and you can't backfit it.
DR. UHRIG: You can't retrofit it, no, but there's
cathodic protection on many plants.
MR. DAVIS: Yes, but not on the rebar.
DR. UHRIG: Okay, not on the rebar.
MR. DAVIS: The problem that you have is if all
the rebar is not grounded you are going to start getting
straight current corrosion which is worse than what you are
trying to fight in the first place.
DR. UHRIG: Okay, thank you.
CHAIRMAN BONACA: But you feel that there is
sufficient industrial experience to deal with, to provide
for a life of 60 years?
MR. DAVIS: Yes, there's been some studies done
and some very good correlations between the groundwater pH
and the condition of the rebar.
CHAIRMAN BONACA: I mean there should be a lot of
industrial experience for structures and how they have
MR. WANG: Any other questions?
MR. GRIMES: I would like to add I think we sort
of blew by the inspection provisions. General plant
walkdowns will see evidence of staining if you have
corrosion occurring inside concrete and that is clearly an
indication that something needs to be fixed and so we would
rely on that as well as part of general structural
MR. WANG: Other questions?
MR. WANG: License renewal issue number 091,
functions for complex structures, was merged into 057,
crediting maintenance rule program according to the memo, to
the ACRS memo here that says 091 and 057 are merged into
We do give credit to the maintenance rule where
the maintenance rule can apply to license renewal 100
The only place -- when the maintenance rule does
not cover we need the specific Aging Management Program from
the Applicant to take care of it.
CHAIRMAN BONACA: Okay.
MR. WANG: The last one, 98-100, aging review
related to dams. That one we think either if the dam is
under NRC jurisdiction, Reg Guide 1.127 should take care of
Otherwise the FERC regulations or in the Corps of
Engineers rules will take care of that -- the dams that
belong to the Corps of Engineers, that is.
CHAIRMAN BONACA: Okay. This would be like the
dam that was at Oconee?
MR. WANG: Yes.
CHAIRMAN BONACA: Okay. I am trying to
MR. WANG: I think it was somewhere -- I forget
which dam, the dam was downstream that belonged to the Corps
of Engineers and the other one belonged to the FERC.
MR. GRIMES: But that dam wasn't part of the
licensing basis. We recognized when we developed the
position for Oconee their emergency power supply dam was
within FERC jurisdiction and when we consulted with the NRC
dam safety officer -- I really like that title --
MR. GRIMES: Maybe before I retire I can be the
NRC dam safety officer -- we recognized that the FERC
program and the Corps of Engineers are comparable in terms
of the program attributes so we acknowledged the Corps of
Engineers as an acceptable Aging Management Program at the
CHAIRMAN BONACA: Thank you.
MR. WANG: That completes my presentation.
Are there any other questions from the committee?
CHAIRMAN BONACA: Any questions from members on
MR. SIEBER: I do have a question and I may have
missed it because there was a lot of information in the GALL
report but there are some plants that have cooling pond
impoundments that are earthen. I don't recall seeing that
MR. MORANTE: Directly in the GALL tables?
MR. SIEBER: Right.
MR. MORANTE: You're right.
MR. SIEBER: Should it be? That is your ultimate
heat sink -- with an earthen dam that should be addressed by
some kind of Aging Management Program.
MR. MORANTE: The way it is currently handled is
that for that type of -- it is not in the GALL tables per
MR. SIEBER: Okay.
MR. MORANTE: But if you look at the Chapter 11,
S(7), those types of water control structures there is a
footnote at the end which identifies that any water control
structure such as a dam or an embankment that is under the
jurisdiction of FERC or Corps of Engineers is automatically
accepted but if it is under jurisdiction of the plant that
we expect a program comparable to the FERC or Corps of
Engineer program, but you won't find it specifically in the
MR. SIEBER: Thank you.
CHAIRMAN BONACA: I have a general question here,
more about the thrust of all these presentations.
All the presentations address each one of the SRP
sections and then the GALL section, focusing on the NEI
comments or the industry comments and how they were dealt
To some degree that implies that the only
difference between the previous SRP and GALL report that we
had and the current we are reviewing now are the
interactions between the licensees and the NRC, but I
thought that we also had been folding into the SRP and GALL
the experience from the two previous reviews.
I think as we go through piece by piece I would
like to understand how that experience has been used.
MR. WANG: I do want to address one thing about
the general inspection, which we do have a couple
experiences, at Calvert Cliffs and Oconee.
CHAIRMAN BONACA: The first question I have,
again, is is the main difference between the previous SRP
and GALL report and the current one that we are reviewing
the NEI interactions? Is that the main difference?
MR. GRIMES: The main difference is the
interaction with NEI has now taken place with experience
from Calvert Cliffs and Oconee to temper the dialogue.
CHAIRMAN BONACA: I'm sorry, would you repeat
MR. GRIMES: The main thrust of the changes to the
SRP and the extension of generic aging lessons learned into
Aging Management Programs is that the dialogue that we have
had with NEI has been tempered by the experience from
Calvert Cliffs and Oconee.
Where before we had argued about these 104 generic
renewal issues on a theoretical basis. We have now been
able to go back and hold a dialogue with the industry about
improvements to the Standard Review Plan and the extension
of the generic aging lessons learned into a description of
program attributes that is no longer theoretical but now has
I think throughout the presentations that you have
heard today, they may have gone unnoticed, but there were a
number of occasions where we said "like we found at Oconee"
or the program attributes as they were presented by Calvert
I think the backhanded answer that I gave you was
that, yes, the major changes here are the dialogue with the
industry, but the Calvert Cliffs and Oconee experience has
contributed substantially to a more civil and productive
MR. LEE: I just want to add the way NEI commented
on GALL, what they did was they formed four or five teams by
discipline. I was told at one point there was like 50
people commenting on GALL and those people are people from
PG&E, Oconee, Hatch -- those are the license renewal plants,
so when they commented they already looked at the experience
from their plant applications and then from our side we have
the NRR Staff that actually did a review too.
CHAIRMAN BONACA: The reason why I am asking that
question is the whole presentation is articulated around
issue, NEI comments, disposition.
The implication is that that is the major driver
of the changes we have seen from SRP Rev.-something to this
SRP revision, okay? I think there is more than that.
You are telling me that that is folded in. I am
only trying to understand if we as a committee are missing
some elements. There may be some issue, some major change
in the SRP and I have not gone by the two versions item by
item to check what major version there is.
There could be some major change that is not being
monitored by the status of the NEI comments, so that is my
MR. GRIMES: And I would say that when we get
toward -- later in the presentation, we will talk about the
extent to which we also had constructive input from the
Union of Concerned Scientists, which provided us with a
broader view about the completeness of the guidance, the
completeness of 20 years' worth of assembling nuclear plant
aging research results, and I think we have got confidence
that GALL was a good tool before and now it is a better tool
We have used the industry comments in order to
focus your attention on the particular areas where there
were controversies in the guidance and whether or not we
were going far enough or too far, and so we intentionally
used the industry comments as a way of focusing on guidance
features, but we would hope that when you apply your
experience to looking through GALL that you will find that
we have done a very comprehensive job of identifying program
attributes, identifying applicable aging effects and
providing constructive insights for the Applicants on how
they are supposed to address areas where we think programs
may need to be augmented to address aging effects.
CHAIRMAN BONACA: I appreciate that.
You understand that your presentations are
supposed to help our reviews.
MR. LEE: I just want to add one more thing. On
some of the slides you see we added this item called the
item of interest, okay? Those might not come from NEI so if
find certain things we should do, if they are significant we
put them on the slide.
CHAIRMAN BONACA: Okay, thank you.
Noel here has got a good suggestion. What don't
we take a break now before we start these last two sections
and we are running ahead of time anyway, so let's break
until five after, and then we will resume and start the
CHAIRMAN BONACA: Okay, let's resume the meeting.
Before we start with the next presentation, I
spoke with Dr. Kuo and we talked about my question before.
The intent of my question before was to make sure
that -- you know, we have reviewed the SRP that we received
in August and the GALL report and so on.
There are substantial differences, particularly in
the GALL report, between the current version and the one we
Every member has taken some portions and reviewed
them. On the other hand, if there are major differences
there, it would be interesting to us to understand where
those differences came from. It may be purely editorial
differences. It may be a reorganization of the GALL report
and I believe that that is where it comes from -- just a
belief supported by a few observations.
Then it could be that there are major elements
removed or changes or whatever and clearly for us the
presentation that the Staff provides is a help. They are
helping our review.
So Dr. Kuo has agreed to tell us a little bit
about that and give us some understanding so that we can
again be helped in our review.
DR. KUO: Let me try. I think there are three
major differences between this August version and the
December 6 version that you have already seen.
The first one is format. In terms of format the
GALL report had a major change in that in the technical
evaluation column we tried to simplify it as much as we can
and then we created two new sections, Section 10 and Section
11. These two sections are the collection of all the common
programs, so we tried to not have specific evaluation in the
main tables, and all the big programs are going into Chapter
10 and Chapter 11.
CHAIRMAN BONACA: Good.
DR. KUO: So basically your review will be most
beneficial to concentrate on Chapter 10 and Chapter 11.
The main table is simply a catch-all on the aging
effects and then when it comes to the technical evaluation
column it says refer to either Chapter 10 or Chapter 11.
CHAIRMAN BONACA: I see.
DR. KUO: Okay, and then --
CHAIRMAN BONACA: That is mostly a format.
DR. KUO: That's really the area where you have
the major programs that manage aging.
The second area that is changed is that we have
incorporated the comments from NEI. You heard about that.
We also have incorporated the comments from UCS.
We have reviewed five reports submitted to us from UCS and
we have incorporated some of it and we are going to actually
in this update put in a few more.
We also have incorporated some lessons learned
from the review of the two applications, Calvert Cliffs and
For instance, in Chapter 10 the three programs it
lists there, Ee, EQ, fatigue, and pre-stress -- you know, it all
reflects the practices or the acceptance that we had used in
these two application reviews.
Then there is Chapter 11. I already mentioned it,
but Chapter 11 basically is the collection of all the common
aging programs so just to avoid repetition -- so these are
the three major areas that I see the differences between the
two versions, the December 6th and the August 31st.
CHAIRMAN BONACA: Okay, thank you. Any questions?
MR. LIU: The other major differences, at December
6 you do not have Volume 1 of GALL. Volume 1 was created as
a bridge also between GALL and the SRP.
CHAIRMAN BONACA: Yes. Thank you.
DR. KUO: From Volume 1 you can actually go from
GALL to SRP.
CHAIRMAN BONACA: That is the guide. Any other
questions from the members regarding the differences
DR. SEALE: There won't be a revision of Volume 1?
DR. KUO: Not that I see right now.
DR. SEALE: So that is still valid?
DR. KUO: Still valid, correct.
CHAIRMAN BONACA: Okay, thank you. Appreciate it.
DR. KUO: You're welcome.
CHAIRMAN BONACA: And with that, let's proceed
with the presentation on Reactor Vessel Internals and RCS.
MR. DOZIER: Good afternoon. This presentation
is, as you said, on the reactor vessel, the reactor vessel
internals, and the reactor coolant system.
Before I get started, one of the things that you
asked about was the experience and the lessons learned from
other things and how that was really carried forth in the
GALL report, so I am very pleased to introduce this team.
On my right is Omesh Chopra. Omesh Chopra is from
Argonne National Labs. He's been involved from the original
NPARSE studies. He was involved with that, the GALL 1 that
was done around 1995 time period and he continues on with
Chapter 4 as well as several chapters within the GALL
report, so we have his experience.
Gene Carpenter is our BWR VIP expert and he will
be here to answer your questions earlier for the BWR VIP
programs but along side with reviewing Chapter 4 he also
reviewed the BWR VIPS and he is involved with the Hatch
application, so he has that three-pronged thing.
Mike McNeil from the Office of Research -- he's
been involved with license renewal about a year and a half
and has been involved with several of the generic safety
On my left is Barry Elliot. He was primarily
involved with the PWR sections of GALL. He's been involved
with all of the applications that have been sent in so far.
My name is Jerry Dozier. I am from the License
Renewal and Standardization Branch. Prior to coming here
five months ago I was involved in the original drafts of the
Calvert Cliff applications and the technical review of the
Arkansas Nuclear 1 application.
With that, I'll get started with Chapter 4.
The NEI comments for of course the reactor vessel
was pretty big. It was approximately 70 pages so a lot of
the comments that you hear, they are in this chapter.
A lot of those comments were very good and
especially in articulating the program attributes that the
plant could go and implement. They were very good comments
in helping to do that and NEI provided very constructive
comments in making Chapter 4 better.
On the other hand though, there were a lot of
things we agreed on. The items that are listed in front of
you are those issues that our opinions diverged.
The first one was neutron irradiation
embrittlement and basically on it there were two different
things that we disagreed on.
One was the threshold value. The NRC was using
the 10E to the 21 neutrons per centimeter squared. NEI was
proposing using 10E to the 17th. We got the 10E to the 21
basically from 10 CFR 50, Appendix H -- I'm sorry.
MR. DOZIER: We had the lower threshold value and
ours came from 10 CFR 50, Appendix H is where the 10E to the
17th came from.
They wanted to raise that threshold to 10E to the
Also in the region of interest we were concerned
with anything that reached the 10E to the 17th value whereas
in their case they wanted to use the definition that was in
10 CFR 50.61, which primarily dealt with the beltline region
or basically those components within the area around the
core. That is an area of disagreement.
MR. SHACK: Their position to me doesn't seem
unreasonable. If I made it 10 to the 17th for ferritic
materials and 10 to the 21 is a little generous but I could
make it 10 to the 20 for austenitics.
MR. ELLIOT: This is Barry Elliot.
This really has to do with internals. That is
this issue here, this first one and there are two parts of
the issue that you have to remember -- from discussions of
Calvert Cliffs and Oconee I am sure you will remember that.
There are two separate issues. One is the cast
stainless steel issue and the other is the raw stainless
In the case of cast stainless steel there is a
synergistic effect of neutron irradiation embrittlement and
thermal embrittlement and so we were very, very reluctant
there to drop back, because we know very little about the
MR. SHACK: But there is a ferritic element there
too and so I mean --
MR. ELLIOT: Right, exactly.
MR. SHACK: -- so it is ferrite.
MR. ELLIOT: And for the raw stainless steel there
just isn't enough data yet to drop back from 10 to the 21st.
We probably could drop back but that is the whole
point of the internals research program, to find out how far
back we can drop both for the raw issue and for the cast
stainless steel issue.
MR. DOZIER: Another part of that that is driving
NEI is Babcock & Wilcox did a study and found that their
inlet and outlet nozzles did reach greater than the 10E to
the 17th in 48 effective full power years, so I think in the
back of their mind that is probably one of the strong
MR. SHACK: I certainly have no problem with 10E
17 for any ferritic material. I think that is absolutely
without question and inlet and outlet nozzles which are part
of the vessel.
MR. ELLIOT: The criteria is 10 to the 17th and
any component that reaches 10 to the 17th would have to be
considered for neutron irradiation embrittlement and whether
or not it is limiting for the vessel. That is within the
context of the current regulations.
DR. KRESS: Fluence is the product of the flux and
the time. Flux is about the same. Does this represent
10,000 years difference?
DR. SEALE: Yes.
MR. SHACK: Well --
DR. KRESS: I mean that is a big difference, man.
DR. SEALE: Of closure.
MR. SHACK: It's more a region kind of difference.
MR. ELLIOT: Yes, it's a region of high you are
above the core and how far you are from the core.
The internals, some of them, are right there, and
they get tremendous flux compared to the vessel.
DR. KRESS: Yes, but for that particular region
that has the high flux it is a 10,000 year difference.
MR. ELLIOT: That is why I said this issue is not
really a vessel issue.
This is really an internals issue because there is
a tremendous difference in flux between the vessel and the
DR. KRESS: Yeah, I am sure of that.
DR. SHACK: You are not going from 10 to the 17th
to 10 to the 21 in time, you are doing that all in --
MR. ELLIOT: You are doing it in flux here.
MR. SIEBER: All in flux.
CHAIRMAN BONACA: So you are saying this is only
MR. ELLIOT: Yeah, the first one here is an
internals issue. That is why I wanted to make sure.
CHAIRMAN BONACA: So NEI never made --
MR. ELLIOT: It is not a vessel issue.
CHAIRMAN BONACA: Okay.
MR. ELLIOT: There is no question that 10 to the
17th is for vessels. The only issue here is on the first
one, is the internals, which get a much higher flux than the
vessel, therefore, reach higher fluences much sooner.
CHAIRMAN BONACA: Yeah.
MR. ELLIOT: And so this is the issue here.
CHAIRMAN BONACA: But you quoted an issue with the
B&W nozzles, those are not internals.
MR. ELLIOT: They would have to address it as part
of the vessel embrittlement program.
CHAIRMAN BONACA: Okay. That's right. So it
seems like it is coming also in the way of the vessel
MR. DOZIER: Right. And that was one of the
issues, too, is that, okay, yeah, that was -- that does have
that fluence level, but, (1), it is not in the beltline
region, and (2) actually that material is not the most
susceptible to neutron irradiation embrittlement.
CHAIRMAN BONACA: Is this issue still open?
MR. DOZIER: Yes.
CHAIRMAN BONACA: So this is one of the few open
MR. DOZIER: Yes, all of these issues are issues
of disagreement. This one in particular is open.
MR. ELLIOT: I want to just make something clear,
make sure you understand, the vessel, any vessel material
that exceeds 10 to the 17th is required to be evaluated.
And as Jerry said, that is not an open issue. The open
issue is the internals issue.
CHAIRMAN BONACA: Yeah.
MR. CARPENTER: This is Gene Carpenter. Just as a
point of information, we are already seeing E to the 21
levels in some of the internals, specifically the core
shrouds of BWRs.
CHAIRMAN BONACA: So, you are relaxing some of
DR. SHACK: No, no. 10 to the 21, everything is
suspect, you know. It is just at 10 to the 17th, which
again, you know, in the beltline of those internals, it is
really a question of how many components are affected. If
you looked at internals that have reached 10 to the 17th,
that goes up and down a long way, whereas 10 to the 21 --
MR. ELLIOT: I mean that is just, 10 to the 21 is
the beltline region for the internals, they all get that in
the first 40 years. The question is how high up do you have
to go before you reach 10 to the 17th. There are components
that can go pretty high up and still get 10 to the 17th in
DR. SEALE: 10 to the 21 is one neutron per atom,
right? I mean that gives you an idea.
MR. DOZIER: Another area of divergence was in the
area of crediting two different programs. One of the things
that NEI really wanted us to do was to give the minimum that
is required to perform the aging management, and we agreed
with that. However, a lot of times two programs is actually
For example, in chemistry control, which they
would want to just say, if they have chemistry on a
particular component, they just want to say chemistry
control. However, we have the problem of detection. So we
feel like that chemistry control, as well as ISI, is a
duplicable aging management program.
Another example would be boric acid corrosion, and
boric acid corrosion, it would just be the walkdown looking
for the crystals. However, if you credit ISI, you have the
pressure test, and, also, if it -- as well as the visual
inspection. So if it is pumped up, even if it is behind
something like insulation or can't be seen, we can still
discover that degradation mechanism.
So we felt like that a lot of times, even though
there was one program covered, we needed two. And there was
a lot -- there was some resistance to that.
The third item, NEI primarily wanted flexibility
in GALL and SRP, so that as time went on they could adapt
new technologies. They could, if ISI changed, it would be
automatic that it was okay.
However, we had the problem that we had to meet
the 10 elements and justify what we was really reviewing.
So in order to do that, we had to provide the details of
what code, what year code we was looking at, the paragraph,
as well as the non-destructive technique that was being
used, and we had to have detail so that you could see
exactly why we was approving that program.
One of the issues, like I said, with NEI was,
well, say ISI changed, how do we handle that? Well, we had
to base our decision on what we really evaluated, what we
looked at, and that is what is documented in GALL.
The next item dealt with small bore piping. Small
bore piping, in the current licensing basis, in the current
ASME codes, volumetric examination of small bore piping is
not required. However, in the industry, there is -- there
has been problems with this because of thermal and
mechanical loading on the piping. So it is a problem that
is occurring even in the current licensing basis.
We feel that it will even be a worse problem in
the extended licensing period. So we are asking for them to
take a look at some of the small bore piping in the most
susceptible areas to make sure that those won't be a problem
in the extended period.
CHAIRMAN BONACA: I believe this was an issue, in
fact, on the --
MR. ELLIOT: This is on both Oconee and Calvert
CHAIRMAN BONACA: Oconee and Calvert Cliffs. In
both cases there were folded in an inspection program.
MR. ELLIOT: Yes. In the case of Oconee, they
have a program that runs, you know, right through the
CHAIRMAN BONACA: That's right.
MR. ELLIOT: And Calvert proposed some program.
CHAIRMAN BONACA: And so you would have a selected
number of locations?
MR. ELLIOT: Yes. Oh, the GALL report doesn't
pick out the locations, that is up to the applicant, and it
is for us to review the locations. But we recommend that it
be inspected, some limiting locations basis.
DR. SEALE: Is that consistent with recent
developments? This strikes me about that if you are
successful in your position, it strikes me as in place where
the use of a little bit of risk insights might be
MR. ELLIOT: I think that is a very good point,
that is an excellent point. And, in fact, that is what ANL
did. In the next application, which was a PWR application,
which is ANL 1, that is exactly how they handled this
DR. SEALE: Okay.
MR. ELLIOT: That is a very good insight. And we
are discussing that right now to see how they did it.
CHAIRMAN BONACA: So the risk insights would be
used to identify the locations?
MR. ELLIOT: To find the locations that are
susceptible, and most risk, of course.
DR. SEALE: Where do you look for the floor to be
MR. ELLIOT: Are you telling that, or did they
telling you that?
MR. DOZIER: The next issue was void swelling.
Void swelling is primarily the change in dimension of some
internals, and it is primarily a concern in the baffle
former assembly region. We feel that it is an issue. Right
now there is no conclusive evidence. There is some industry
research going on now with EPRI, but we have not got
conclusive evidence that it is not an issue. And so until
we can resolve the issue, we are asking the applicants to
follow the industry efforts in that area to see really where
it is. But until we have conclusive evidence, we feel that
that the issue should stay in GALL.
CHAIRMAN BONACA: Now, remember also for the other
plants that were reviewed, they committed to inspect.
MR. ELLIOT: The other plants have committed to a
program and to implement the results of the program. And in
the case of Calvert, they have actually started inspecting
some of these things for the irradiation stress corrosion
cracking, not for void swelling, though.
MR. DOZIER: IASIA intergranular irradiation
assisted stress corrosion cracking was another similar
issue. They feel like it is really not an issue. However,
we have seen IASCC in both PWRs and BWRs. And, again, there
is an industry effort to determine whether or not it is
truly an affect or not, but we don't have conclusive
evidence that it is not, and again -- so it is staying in
GALL, our position is to stay in GALL.
MR. McNEIL: I think it putting it fairly mildly.
In fact, I would say the body of experimental data
available, and NRC is a member of an international
consortium that is looking this, is that IASCC does occur in
PWRs, but that I think based on the data that have been
collected is not seriously arguable. The question is how
important are its consequences.
MR. DOZIER: As a matter of fact, it has been seen
in the PWR, like the control rod drive mechanism area, where
it is very high strain, in a high strain area, along with a
high fluence field, so it has actually occurred.
GALL and SRP did incorporate these Generic Safety
Issues, and, as you can see, several of these are actually
old carryovers. When I showed the NEI comments, some of
those were issues a long time ago that just really hadn't
gone away yet. And we have addressed them in our documents,
however, they may not be totally "resolved."
Okay. Going through some of these, 98-004 was
pretty much just an editorial thing. They didn't want early
detection. So basically now we say, the GALL report
recommends some program to detect a failure mechanism,
ensure that the component, tuned in function, will be
maintained during the period of extended operation. It
really don't talk about early detection because they were
really having problems with what does "early" mean.
Another is thermal aging and embrittlement of
cast. And what we did there was we made a new chapter in
Chapter 11 that specifically gave them criteria that they
could look at evaluate, which looked at the casting method,
the molybdenum content, as well as the ferrite content. So
we gave guidance in that area.
Number 31, IASCC, I talked about above.
Stress relaxation of internals, that dealt with
the baffler former bolts and the loss of pre-load due to
stress relaxation there.
Primary water SCC of high nickel alloy. One of
the real concerns there still is when the dimineralizer
resins gets into the primary water and contaminates that
It is kind of interesting, Number 34, it was SCC
of PWR reactor coolant system, because in the latter
comments, they were wanting chemistry alone, but in the
earlier days they wanted ISI alone. And so we, I guess we
played with there and are resolved with both. But we
wouldn't go with just ISI alone because when the reactor is
shut down, there may be high oxygen or also potential for
contaminations to get into the line and promote SCC.
Degradation of Class 1 piping, we talked about
earlier. Embrittlement, we talked about earlier.
Ultrasonic inspection of reactor vessel, we
resolved a lot of that through the BWR VIPs. Actually,
since we did mention the BWR VIP word, if you would like for
Gene Carpenter to address your question earlier on BWR VIPs,
now may be an appropriate time, if you would like.
CHAIRMAN BONACA: Yeah, it would be interesting to
know if there is any plan to fold in information into the
GALL report. That was my main issue.
MR. CARPENTER: The BWR VIP program has been
folded into the GALL pretty much in toto. Let me give you a
quick background on the BWR vessel and internals project.
It was an outgrowth of the BWR fleet response to Generic
Letter 94-03, which was the core shroud cracking which was
discovered at Brunswick back in 1994.
They responded to that as a group of utilities
instead of as individual utilities. They came in with
several reports. We reviewed those and found them to be
applicable and it gave us reasonable technical assurance
that they would be able to adequately determine if there was
cracking of the core shrouds and what they could do if there
The BWR vessel internals project, instead of going
away after that, they expanded their scope of operations and
they looked at basically all of the reactor vessel
internals. They expanded it further to take a look at the
reactor vessel itself. And now they are looking at Class I
piping attached to it.
So it was a project that I thought would go away
maybe in 18 months and I am still doing it almost six years
Since that time they have come in with some 80 BWR
VIP reports, 12 of which are specifically applicable to the
license renewal space, and those are the inspection
evaluation guidelines. And they are, in order, BWR VIP 18,
which deals with core spray, and 25 which deals with the
core plate. 26, top guide. 27, the standby liquid control
system. BWR VIP 38, which is the shroud support. 41, which
is jet pumps. 42, the LPCI coupling. 47 is the lower
plenum. 48 is the vessel internal diameter attachment welds
49 is the instrument penetrations. 74, which deals with the
reactor pressure vessel. And 76, which goes back to the
original issue, core shrouds.
Of those, we have completed six of the
evaluations. Three more are presently in the concurrence
chain and we expect to complete the three final ones once we
get some responses to some open items from the BWR VIP.
CHAIRMAN BONACA: I didn't hear about the core
MR. CARPENTER: The LP -- LPCI coupling core
pressure coolant injection?
CHAIRMAN BONACA: Yeah.
MR. CARPENTER: That is 42.
CHAIRMAN BONACA: Okay. No, I thought the core
MR. CARPENTER: Oh, that is 18.
CHAIRMAN BONACA: 18, okay, I didn't hear. All
right. So that is also addressed.
MR. CARPENTER: Yes. We have already taken care
of that one. It is on the streets now and it is part of the
CHAIRMAN BONACA: So there is pretty much a
complete set for all the internals.
MR. CARPENTER: We expect to have all the reviews
completed, assuming that the BWR VIP responds to those open
items well before the Hatch SC is issued.
CHAIRMAN BONACA: And we are planning to review
them for the Hatch application.
MR. CARPENTER: That is correct.
CHAIRMAN BONACA: In February.
DR. SHACK: So something like 74 would then be the
actual -- it is the inspection guidelines, but it is really
-- the 05 would then be the technical basis document.
MR. CARPENTER: 74 is the document that has
subsumed the original BWR VIP 05, which was reviewed several
years ago, yes.
CHAIRMAN BONACA: How have they addressed the
issue? I mean these are all -- I guess it is just one
vendor? I mean all the vessels were fabricated by?
MR. CARPENTER: The vessels were fabricated by a
variety of vendors, CE, CB&I, et cetera. And they have went
in and they have looked at each vessel manufacturer, from
those manufactured several to those that manufactured one,
and they have evaluated what are the concerns there, how
they can do the inspections for each and every one of them.
It is a generic program, but it is a generic program that
has looked at each of the 36 vessels.
CHAIRMAN BONACA: Okay. Thank you.
Any other questions on the BWR VIP?
CHAIRMAN BONACA: Thank you.
MR. DOZIER: I would like to add to that that NEI
much less comments on the BWR section than the PWR, and we
attribute that, because of the buy-in and the working of the
issues within the BWR VIP program. And so I think that was
a big success that that was going along with the license
renewal effort, and we could pull some of the issues into
the BWR VIP program. So I think it was a good success.
Issue 38, visual examinations. That primarily
deal with cast austenetic stainless steel. Again, we gave
specific requirements for molybdenum and ferrite content to
give a little additional guidance on that.
44, void swelling, we talked about.
DR. SHACK: What is the context of that? Is that
because you don't trust the UT of the cast stainless?
MR. ELLIOT: We don't trust the UT, but the issue
is thermal embrittlement for the piping. And to resolve the
issue for the piping, now we are just talking about piping,
I want to talk about -- unless you want to talk about
internals, but let's start with the piping. In the piping
issue we have defined what is susceptible and what is not
susceptible. And for the ones that are not susceptible, the
existing programs are adequate.
For the components that are susceptible, we allow
them to do one of two things, either develop an inspection
program which will detect cracks, which we don't have right
now, or to do a flaw tolerance evaluation to see if the lows
are low enough on the piping that a visual examination would
be adequate. It is sort of like, almost a like before break
type of flaw tolerance evaluation.
For the internals, it is a whole different story
and it needs an entire different program. We discussed this
before. We could go through this, I could talk for a half
hour on that one, but, you know, that is --
DR. SHACK: No, I just wanted to get the context
of this one, that's all.
MR. ELLIOT: Okay.
MR. GRIMES: There is enough time on the schedule.
DR. SHACK: I have heard Barry get loose on this
one before. You know, we don't want to unleash him.
MR. ELLIOT: Well, Allen is here, too, so Allen
can contribute also.
MR. DOZIER: Yes, I do want to mention, these were
the primary team of reviewers, but there were also several
others such as Mr. Hiser that were actively involved in the
Number 58, definition of the beltline region. We
talked about that a little earlier with the fluence level.
And, of course, we are not so much concerned with beltline
region, we are more concerned of the components that reach
the fluence level.
59, bolt cracking. We added a section in Chapter
11 that specifically dealt with the bolting issues. We also
addressed the baffle former bolts which were -- one of the
big problems with that was that you could only look at the
head of the bolt. The real problem, though, was between the
head and the shank. And so there was a big concern actually
with how to handle these baffle former bolts. But there has
been numerous failures, numerous operating experience to
justify our issue there.
Use of early detection, I have talked about that.
Use of codes, again, we actually --
CHAIRMAN BONACA: Use of early detection, I mean
concern of early detection. I mean --
MR. DOZIER: Right. Well, what we did in the
original GALL was we used that word, you know, we want early
detection. And they say, well, what does that mean, early?
Does that mean two weeks before? Does it mean -- what
really does that mean? But our real concern was that it
maintain its function during the period of extended
operation, and so that is what we really said.
CHAIRMAN BONACA: Okay.
MR. DOZIER: Because that was easier to define and
CHAIRMAN BONACA: I understand.
DR. SHACK: Barry, can I just come back to this
beltline region again? You made the remark before that the
NEI wanted to focus on the most limiting case of
MR. ELLIOT: No, no, I said that -- no, no, excuse
me. It is not that NEI wanted to focus on limiting a
portion of it, it is that the focuses on the limiting point
of embrittlement. When we do a pressurized thermal shock
evaluation, or if we do a pressure temperature calculation
for the PT curves, you look at the limiting materials to see
how much embrittlement -- you look at all the materials, but
it is the limiting material which gets closest to the
screening criteria. It is the limiting materials that
determines the actual pressure temperature limit.
So, if a component has a very high fluence, it
doesn't take a lot of copper or nickel to become limiting.
If it has a very low fluence like 10 to the 17th, let's say,
then it probably won't ever be limiting, because it just
won't get enough fluence compared to the high copper areas
to become the limiting materials.
DR. SHACK: Okay. But you are still focusing then
on limiting material?
MR. ELLIOT: No, we focus on all the materials,
but the limiting material determines how close you are to
the screening criteria. And the limiting material
determines your pressure temperature limits. But we look at
every material, we want every -- when the licensee submits
an evaluation, they make an evaluation of all the materials
that have a fluence greater than 10 to the 17th.
It is just that the ones with the highest amount
of embrittlement are the limiting ones, and they affect the
PTS screening criteria and the pressure temperature limits.
MR. DOZIER: Item 68, use of codes. For ISI, we
used, in the August version, we used the August '89 edition,
and in the March version we will also include the '95
edition of the code.
85, reactor vessel fluence, we have talked about.
Pressurizer heater penetrations, those are nickel alloys.
And, basically, what we are asking for all nickel alloys is
to find the most susceptible locations and to determine
whether an augmented inspection program is needed or not.
92 was the structures and components that are
presently within a scope. If you really read that, what
that really dealt with was the internals, and that one was
primarily addressed by the BWR VIP program.
And then 93, we have talked about ISCC before.
DR. SHACK: Let me just come back, I mean the
issue here was that they were arguing that irradiation did
not play a role in the core shroud cracking, or what was the
MR. DOZIER: They felt like IASCC was really not
DR. SHACK: In the core shroud?
MR. DOZIER: Anywhere. Even though actually we
have had, in the PWRs we had problems, like I said earlier,
in the control rod drive mechanism area, because of the
stress and the fluence level. And, also, in BWRs, we saw it
because of high oxygen content in the coolant. But they, as
I say, it is a thing we think is an issue, they don't.
MR. GRIMES: Actually, I think to be fair to the
industry, I think they were trying to develop a rationale to
say that there may be an aging effect, but it is not an
aging effect that warrants an aging management program. And
so they were trying to characterize the extent to which an
applicant would have to be into explaining the extent of the
effect and how it would be managed.
And, actually, if you look across all of these
issues, they are fundamental throughout the industry
comments, this sense of whether or not there is a necessary
regulatory burden being imposed on the extent to which the
licensing basis is going to have an additional commitment to
perform inspections or to manage an aging effect. And they
we are looking to push the state of the art to what they
believed was the realistic limit. And we are just, we are
not ready to do that.
And I would like to put a different perspective on
Jerry's description of the extent to which these issues are
unresolved. I think they are resolved because we were asked
to make our expectations about license renewal clear, and we
have done that.
MR. DOZIER: Right.
MR. GRIMES: And the fact that we drew a line on
our expectations that may require additional effort on the
part of license renewal applicants, Calvert Cliffs and
Oconee have demonstrated that meeting that threshold is not
insurmountable or unnecessarily costly. But to the extent
that it changes the effect of the licensing basis in a way
that is going to add regulatory burden, I am sure that that
is part of GALL being a living document. In the future we
will see some of these things, you know, end up being cut
back because we determine that the regulatory burden is no
And so I want to stress that, particularly for
vessel internals, which I consider an evolving art form,
that, you know, we have made our expectations as clear as we
can based on the state of the efforts on behalf of all of
the Owners Groups to come up with aging management programs
for vessel internals.
MR. CARPENTER: It should also be noted for the
BWR in particular, that the BWR VIP is presently involved in
cooperation with the staff on some very significant research
into IASCC and they are spending quite a bit of money on it.
They haven't said that, no, IASCC is not an issue. They are
still looking at that and we are -- this is one of our
long-term issues with them.
CHAIRMAN BONACA: Let me ask a question, just
about an example. Some BWRs have had, in fact, crackings of
core shrouds and repairs rather than replacement. That is
their experience, others have not experienced that. How
would you address the changes to that kind of operating
experience into a program? Would you expect a different
kind of inspections, more frequent inspections?
MR. McNEIL: I would like to make one comment on
that point, that there are some systematics in the cracking
of core shrouds. Core shrouds that are made of 304 crack
faster than those that are made of 304L. Core shrouds that
had what by today's standards would be called bad water
chemistry histories crack more rapidly that those that have
had good water chemistry histories. And so it is possible
to rank the core shrouds, and, to a degree, to rationalize
the degree to which we have cracking.
In other words, you can plot up the core shrouds
and get where we would have guessed the cracks would be and
the cracks are in those core shrouds that we would have
guessed them to be from this reasoning.
CHAIRMAN BONACA: So you would, in fact, then that
might justify a different kind of inspection process or how
aggressively you want to go after it because of that.
MR. CARPENTER: Precisely correct. As a matter of
fact, that is what the BWR VIP program was, that they
basically binned the various reactors based on the three
types of core shrouds, those that had good water chemistry,
good materials; those that had poor materials and/or poor
water chemistry; and those that had both. And they also
included age and the amount of radiation that they had
CHAIRMAN BONACA: So this would be a good example
of how plant-specific experience is being reflected in the
programs that they are being used in, and this is in GALL.
MR. CARPENTER: Yes. Yes. As a matter of fact,
right at this time I think there is only plant that is still
classified as a Category A plant, which means that they
didn't have to perform the inspections in accordance with
the program and what we approved. And that one is about to
become a Category B, which will bump it into the next level,
and then about 10 years later it will become a Category C.
CHAIRMAN BONACA: Okay. Very good. Thank you.
DR. SHACK: Now, if they go to hydrogen water
chemistry, do they all become A's?
MR. CARPENTER: If they go to hydrogen water
chemistry, they get certain benefits from that immediately,
both in reduction in crack growth rates and in reduction in
crack -- pardon me, inspection frequencies and scope. No,
they don't go back to being an A. You don't get that
MR. McNEIL: I think there is a difference here
between the B's and the P's, and that the B's have had a lot
of IASCC over a number of years, in many, many different
parts. This has to do with, of course, the water chemistry,
particularly in the older days when the water chemistry in
the B's was bad by today's standards.
It appears that the IASCC begins to kick in on the
P's at a much later level, that is, we are beginning to see
IASCC. We have got lots of experience in IASCC in B's, and
everybody agrees that it happens. General Electric talks
about it all the time, for God's sake, they are the people
that make them. In the P's, we are beginning to see IASCC
in relatively high stress, high fluence components. It is
obviously going to get -- obviously, many more will go into
Bin C, as you would call it, as we go into the license
But the fact that the average owner of PWR is
seeing relatively little IASCC, and also because neither we
nor industry groups have so far, despite the best efforts of
Argonne, generated a really major database on this subject
makes it a much foggier and more -- and the details of the
matter a little more -- significantly more controversial.
MR. DOZIER: Any other questions here?
CHAIRMAN BONACA: No.
MR. DOZIER: The next is items of interest. The
Union of Concerned Scientists has been very much involved
and informed of the license renewal process. As a matter of
fact, everything that we send to NEI, the UCS is also on the
letterhead, so they are being disbursed all of our
information. They have also attended our workshops and
provided comments. In the December 6th, they referred --
asked the question, have we considered other sources, for
example, UCS reports? And they provided those to us.
Argonne and BNL, BNL took the electrical portions,
Argonne took the mechanical, analyzed those five reports.
Basically, in that analysis, they would identify a specific
component and an aging effect and see if GALL addressed it
or not. And then also if inclusion would be appropriate
There were two components that were identified and
those were the jet pump sensing line and the separator
support ring, which were added to the August version.
When we sent back the comments from the December 6
workshop, we did notify Union of Concerned Scientists that
we had used their input and acknowledged their contribution
to the license renewal effort. And, also, we may be sending
out a letter that actually provides that matrix for him to
review on a piece by piece of exactly why we said each part
should or should not be in GALL and why.
MR. GRIMES: Jerry's slide says that we sent a
letter to UCS, but I confess, through the best efforts of
the staff to try and get a response to UCS, there are two
recent significant events that caused me to hesitate. The
first is we got the UCS comments on GALL, which started off
describing our efforts to more clearly explain the GALL
contents as a bait-and-switch. And the second thing is we
just issued a response to the UCS 2206 petition on Hatch,
which wasn't very kind to the UCS views about either
conformance with the licensing basis or the relative
importance of rad waste systems to plant safety.
And so in order to ensure that we maintain a
constructive and useful dialogue with UCS, I am going to
consider how we present the results of our evaluation more
carefully before we send it to them, and also to provide an
avenue that is going to maintain a constructive dialogue
throughout the Commission meeting, which UCS will be a party
I would also like to address a comment that Dr.
Wallis made, I believe, at the October 30th meeting, which
implied that perhaps we were endorsing the UCS evaluations
in some way. And I want to emphasize that we don't
necessarily agree with the results of the UCS evaluations,
nor did we need to, nor are we endorsing their findings by
reviewing the results of their work and the carefully
considering it in terms of whether or not GALL captures the
combination of aging effects and the need for aging
We do think that it was a valuable contribution,
an important piece of looking across all of the engineering
evaluations that could contribute to a complete explanation
of how aging effects should be managed.
CHAIRMAN BONACA: Okay. Thank you.
So I guess this completes your presentation?
MR. DOZIER: Yes. If there are no more questions?
DR. UHRIG: Was there not -- it is characterized
as five reports from Union of Concerned Scientists. Was not
one of those an NRC report?
MR. DOZIER: Actually, it was. It was a NUREG
requirement that primarily they -- it was very well
referenced, actually, and if you looked at, for example, the
table on it, it was straight out of a NUREG anyway.
DR. UHRIG: Well, it looked to me like a
preliminary draft that had a warning across the top that
this is preliminary, and then that was slashed out.
MR. LEE: I think it referred to the report, I
guess the staff report on EG.
DR. UHRIG: Yes.
MR. LEE: Back before we had GSI-168 on EQ, the
staff had an action plan on EQ, and that was the study for
DR. UHRIG: So that was an NRC report?
MR. LEE: That's correct.
DR. UHRIG: Okay.
MR. DOZIER: I guess, really, the analysis of
those reports, primarily, if you look at the references,
though, it would reference back to a lot of times NRC
CHAIRMAN BONACA: Any more questions for the
CHAIRMAN BONACA: None. So I thank you very much
for the presentation.
I think this concludes the presentations for
today. This takes us one hour of their time, it is a speedy
Before we adjourn, we have on the agenda a
discussion of whatever we heard today. Clearly, we will
have one to wrap up tomorrow. But I would like to give a
chance to the members to go around the table and express
some of, you know, their perspectives on what we viewed
today. And if there are any specific questions we should
ask of the staff now, or any recommendations regarding what
should go in the -- well, we will take care of that for the
full committee presentation tomorrow morning.
With that, I will start on my left here. Bill, do
you have any?
DR. SHACK: No. It seems to me that they have
made a considerable amount of progress in incorporating a
vast amount of information here. I haven't seen anything
that particularly disturbs me in terms of omissions or
things. But, again, it is just an enormous amount of
material to absorb, but nothing particularly strikes me
CHAIRMAN BONACA: Bob.
DR. UHRIG: Well, I was sort of hit by this
statement the reactor vessel surveillance program is not a
TLAA. I guess it is a matter of semantics in some respect
because, clearly, this is an issue that has to be and is
addressed. I don't have a problem, it is just that the way
it is stated here sort of didn't make too much sense.
Whereas, the next one where it came up, the Commission, the
staff basically, the tendon pre-stress management is not a
TLAA, that statement, and they rejected that statement,
whereas, the other one, they accepted.
But, basically, there is an aging management
process here. I agree with Bill, a tremendous amount of
MR. GRIMES: I believe that we are treating the
containment tendon the same way. And as a matter of fact, I
would offer that we are our own worst enemy in this respect
because when the rule was constructed, we talked about aging
management programs to manage aging effects for a scope of
structures and components, and then we tried to separate out
time-limited aging analysis, but then we offer as the third
option that you can use an aging management program. So,
does an aging management program for a time-limited aging
analysis mean that it is not a time-limited aging analysis?
DR. UHRIG: That was what was confusing me, and I
finally concluded it was semantics.
DR. SEALE: Well, in the first comment, though,
the identification of what should be a TLAA, and in that
case the question was that you may not need a list, but,
rather, you ought to go back and look at current licensing
basing documents as the starting point. But once you do
that, then you will have TLAAs in your eyes, whereas, the
NEI people had objected to that. So you require a TLAA
MR. LEE: I guess the rule defines TLAA, that is
criteria, that is laid out in the rule, okay, why the
criteria is a calculation. So when it comes to it, we have
the assurance program. NEI is saying there is no
calculation anymore. And that is why, just by the strict
definition of TLAA, NEI says it is not TLAA. You still
manage it, okay, it is just a matter of putting a label on
it, okay. For the tendon assurance program, in that case
you actually have a calculation, you have to project the
tendon, the pre-stress loss, okay, that is part of your
program. It is not the only piece of the program. But NEI
is looking at the other side, saying, hey, it is the
program, and that is why it is not a TLAA.
CHAIRMAN BONACA: Well, I mean the tendon really
is not a calculation for 40 years, it is a calculation, a
limit. So if you bump into it, --
DR. KUO: No. If I may add, the design of a
tendon is that it starts with a 40 years prediction.
CHAIRMAN BONACA: Okay.
DR. KUO: Okay. Actually, it accounts for the
loss, pre-stress loss for 40 years. So the tendon is
tensioned to a much higher level and allows the pre-stress
loss over the 40 years. But in many of these tendons, the
pre-stress loss actually is much more than what was
predicted, okay, in some cases they have to retension it
during the first 40 years, okay. Therefore, they view that
as a program, instead of a time-limited aging analysis.
So, in this case, yes, your question is correct,
it is a TLAA because it was designed for 40 years to start
with. There is a calculation that was done. However,
because this pre-stress loss over the years, they actually
had a program, the program actually in one time is in the
tech spec, so they view that as a program.
MR. GRIMES: I would to cut to the chase, and Dr.
Uhrig is quite correct, this is a semantic issue. And so
long as we have a clear rationale that says that we have
identified the intended function and that we have a
reasonable assurance that that intended function will be
maintained, whether you call it a time-limited aging
analysis or a program, that is what we consider important to
the clarity of the guidance.
DR. UHRIG: Well, that was the conclusion I came
to is that the bottom line was it was being adequately dealt
DR. SEALE: Yeah.
CHAIRMAN BONACA: Okay. Thank you. Graham.
DR. LEITCH: I have no real comment. I thought
the presentations were helpful as far as my understanding of
the entire process and the resolution of the NEI comments
particularly. I think I have a much better appreciation
now. I guess we are going to hear some more about it later,
about where Chapter X and XI fit into the process and I
found the comments -- the discussion very helpful.
CHAIRMAN BONACA: Thank you. Bob.
DR. SEALE: Well, you assigned me Chapter IV, and
I am still mulling over all of the juicy details in that
one, and, believe me, it seems to be quite a bit, and I do
want to see what X and XI have in it, too, as you go through
it with us. But I don't think there is anything
inconsistent from what we have heard in other related kinds
of presentations. It sounds like the consistency is there.
In listening to the NEI disagreements, I don't,
for the life of me, at this point, see any places where I
feel that you are being unreasonable in taking the position
you take. I guess it is always desirable to try to get what
you can, but it is also important that you resist that where
you think that it is appropriate.
And in the UCS comments, well, I may want to take
a look at a couple of those in a little more detail. Maybe
I can get some additional information from you on those.
But other than that, I don't have anything at this point.
CHAIRMAN BONACA: Okay. All right. All set.
MR. SIEBER: You assigned me Chapters II, III, VII
and VIII. The stuff discussed today, I thought it was all
pretty good, but the one issue that we talked about during
the break, about not including earthen dams and the tables,
I think it would help the GALL report organization if it
were in. Other than that, the presentations were good and
it took a lot of time to read all this stuff.
DR. UHRIG: On the subject of dams, the ones that
I am most familiar with have built in leak detection
systems. These are not under NRC jurisdiction, but --
MR. SIEBER: There are some dams that were modern
dams and some that are not.
DR. UHRIG: Yeah, that's true.
MR. SIEBER: This is not only a dam, for example,
impoundment for an ultimate heat sink, it could be a dam on
a river that sits right next to your plant, which we had,
that was built in 1920.
DR. SEALE: What about, I guess I would call them
berms rather than dams? The things around waste water
retention basins and things like that.
MR. SIEBER: Dikes. That is in there. I think
there is a reference to that in Chapter XII.
DR. SEALE: Okay.
MR. GRIMES: That is a helpful comment. We can
look at clarifying that. There are dams and impoundments
that are relied on so that safety functions can be performed
for ultimate heat sink, but there are also -- my experience
was the Heriman dam above Yankee. There are dams and
impoundments whose failure can seriously jeopardize your
plant if you haven't -- don't have curbs and water-tight
doors and things like that.
MR. SIEBER: If it is an upstream dam that fails,
you might have a flooding problem. If it is a downstream
dam that fails and you are on a river, the river level may
go low enough to cause you to lose suction on pumps.
MR. GRIMES: This is an area where, you know, GALL
reflects only the experience that we had at Oconee where we
concentrated our efforts on the FERC program and how that
stacked up against the attributes of an effective aging
management program. And I learned more than I ever wanted
to know about dams in that process.
But that, along with extending that experience to
the Corps of Engineers program. So there is obviously going
to be some room for us to learn more about embankments,
impoundments, you know, and other kinds of water-retaining
DR. SEALE: They occur in the strangest places,
too. Palo Verde flooded.
MR. GRIMES: Well, I got to watch the Palo Verde
lakes grow in the middle of the desert.
DR. SEALE: Yeah.
MR. GRIMES: But one of the other things that we
-- one of the other experiences that we had was we were all
set to go look at an underwater wier, and I was going to get
my scuba certification and everything to go down to Oconee
and find the water control structure that was relied on to
capture the heat sink when they changed the licensing basis
and they didn't rely on it anymore. So we missed a big
opportunity for me to learn about underwater wiers.
But that would be useful for us to clarify that
area. So that is good feedback.
MR. SIEBER: All it would really amount to is a
MR. GRIMES: Right, yes.
MR. SIEBER: Put it in there and refer back to
DR. KUO: Well, actually, Ronda just handed me a
page from the Gall report that is page 7, C3-3, and Item C3,
the title is "Ultimate Heat Sink." And there is a statement
there, it says, "A pump with AMPS shall be provided to trend
and project, one, deterioration of earthen dams and
impoundments." Okay. It was referenced. We don't have a
table for that.
MR. SIEBER: That is all it suggested.
CHAIRMAN BONACA: Thank you, Jack. Tom.
DR. KRESS: I pretty much agree. I didn't
specific problems with my sections. I still have to digest
a lot of it.
CHAIRMAN BONACA: Okay. In general, I also --
part of the review I felt comfortable with. I think that
tomorrow we will talk about those seven criteria that we
selected and that will be the time to reflect on those,
because we want to address them probably in our report.
But I seem to be -- the document seems to be
well-integrated. It will definitely lead the staff to
develop a comprehensive understanding of technical issues.
So we will talk about those tomorrow.
I still have three issues I raised before. One is
we will at some point need to maybe talk about doing the
main meeting in two weeks. Understand the EOPs are
referenced the FSAR, are considered to be part of the
current licensing basis. If they are, then there should be
more explicit guidance on their use. If they are not, then
we have to ask the question, does the rule emphasis on CLB
represent too narrow a box? I mean we need to just reflect
on that, understand it and just throw it one way or the
The second issue that we need to clarify is
voluntary commitments. There are many voluntary commitments
that were voluntary because the industry said, well, if we
don't make it voluntary, the NRC will come up with some
requirement, and then the accident management was on those.
Are these voluntary commitments in general still valid
during the period of extended operation? If they are, there
ought to be some mention somewhere in the guidance that that
is a fact. Information simply clarifies the issues.
If they are not, then we have to understand what
that means. Does it mean that we are allowing for the
plants to be less capable during the period of extended
operation? That is an issue that we need to hear about.
And, again, I mean I am not prejudging, I think it is just a
And the third one that I would like to, you know,
that I think is important is more to the effect of the value
of the guidance. How will future experience be folded in
the GALL II report? I think if you look at how much
information we got from two applications that went into
GALL, there was quite a bit.
You know, we are likely to have, after five or six
applications, a lot more information that is not going to be
in the GALL II report, and that to the degree to which the
GALL II is going to be a big help to facilitate both the
application and the review, you know, I would be interested
to know -- and I am sure there are no plans yet, -- but, you
know, how do we use this valuable information? How do we
make it available? I mean --
DR. SEALE: The question is, how much smarter can
Chris afford to get?
CHAIRMAN BONACA: For example, there are many
places where we talked about it before. There is, you know,
statement in the GALL that says you need more, but there is
Now, we heard that that's due to the limited
amount of experience to date, and there will be more
experience, there will be answers to those questions of, you
know, what "more" means.
And at some point, it will be valuable to
understand how it's going to be made available. I mean,
either -- if the NUREG is not a proper vehicle, certainly,
for example, the NEI documents could be updated, revisions
could be made. I don't know. But that's an issue we maybe
want to hear about.
Beyond that, I'm quite impressed by the amount of
guidance that is available there to the industry. With
that, I don't have any more comments.
DR. SEALE: I'll make one other comment before,
but I don't want Shack to get too cocky about it.
DR. SEALE: I think our Committee is often making
comments about the quality of some of what the support staff
has gotten from the National Laboratories and places like
that. Some of it hasn't been too laudatory on occasion, but
I think the people, the Brookhaven people and Argon people
that worked on this report really have done a good job and
have performed a real service. I think that's worked out
DR. UHRIG: This looks ahead to tomorrow. When we
get into the electrical components, there's the issue of the
unresolved GSI-168, and I think there's going to be
different results if it's resolved one way, versus resolved
Perhaps you could address that issue tomorrow.
MR. GRIMES: Okay.
CHAIRMAN BONACA: Yes, we need to hear about that,
and also we have a consultant report focused on the issue of
cabling, and he raised a number of issues. Clearly, it's a
very sensitive area.
I mean, at the last meeting, we were presented
with a number of samples of cable material --
MR. GRIMES: I'll be happy to get my crystal ball
out tomorrow and do the best I can.
Also, I would like to mention that at the
conclusion of the meeting tomorrow, I would intend on going
back and summarizing what feedback we've gotten during the
course of the two days, what actions we intend to take, and
I'd like to agree on a set of topics that you'd like us to
cover for the full Committee.
CHAIRMAN BONACA: Absolutely.
MR. GRIMES: And we can get some idea about the
level of detail you'd like us to cover.
CHAIRMAN BONACA: Yes, particularly the format
somewhat different in the sense that the full Committee
doesn't need to look at all the issues, but more focusing on
some of the ones we raised, and then on the seven issues
that we took as general criteria for our review.
MR. GRIMES: Yes. I would like to point out that
we would also want to reflect back on the public comment,
the specific questions that we raised in the Federal
Register on public comment.
And one of those dealt with how do we treat codes
and standards. You noted that we added an explanation
that's a very general description of the treatment of the
ASME Code and the reliance on the regulatory process, the
50.55(a) changes to control the way that 50.55(a) affects
the licensing basis.
And we sought input on how we should treat other
codes and standards in terms of their evolution in the
future, recognizing that we're trying to project the program
features, you know, a decade from now, that would last for
20 years beyond that.
So we'd like your thoughts in that area as well in
terms of whether the ACRS has a particular view that you'd
like to share with us that we could sponsor in the way of
CHAIRMAN BONACA: Okay. Paul, do you have any
MR. DUDLEY: I think it's fairly well covered, and
well laid out on what needs to be done tomorrow.
CHAIRMAN BONACA: Okay, so we're going to resume
the meeting tomorrow at 8:30, and we have an understanding
of what we are going to do, okay. With that, if there are
no further questions or comments from the public, the staff,
I will adjourn the meeting for today.
[Whereupon, at 3:23 p.m., the Committee was
recessed, to be reconvened on Friday, October 20, 2000, at
Page Last Reviewed/Updated Tuesday, July 12, 2016