Plant License Renewal - October 19, 2000

                             UNITED STATES
                              Thursday, October 19, 2000
                              U.S. NRC
                              11545 Rockville Pike
                              Room T2-B1
                              Rockville, Maryland
     .                         P R O C E E D I N G S
                                                      [8:30 a.m.]
               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
     Robert Uhrig.
               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     presented the ACRS with an overview of the draft guidance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.
               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,
     as well.
               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
     the subcommittee.
               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
     new plants.
               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
     ensure consistency.
               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
     guidance consistent.
               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
     rulemaking yet?
               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
     address that.
               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
     that issue.
               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
     review plan.
     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
     this chapter.
               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
     2000, also.
               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
     August 2000.
               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
     compromise there.
               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
     that later.
               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
     examples given.
               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
     single plant.
               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
     the other.
               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
     screening process.
               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
     license renewal.
               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
     of that.
               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
     licensing basis.
               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
     licensing basis.
               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?
               [No response.]
               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
     previous presentation.
               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
     and addressed.
               MR. MITRA:  These issues are not -- it's there
     since '97.  So we would have heard if they have any problem
     with that.
               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
     about EOPs.
               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
     feedwater system.
               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
     they review.
               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
     management review.
     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.
               Any questions?
               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
     conforming changes.
               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
     quality SER.
               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
     after ten.
               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
     Chatper 10.
               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
     existing analysis.
               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
     management program.
               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
     captures that.
               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
     environmental effects.
               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.
               Any questions?
               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
     options mean.
               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?
               [No response.]
               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
     the GALL.
               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
     your plant.
               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. 
     All right.
               MR. LEE:  I guess we spent a lot of time on that
     already, and we did not receive any comment from NEI for the
     April version.
               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
     guidance, right?
               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
     of stops.
               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
     isn't anything.
               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
     restricted area.
               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
     them, yes.
               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
     those things.
               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
     boiling event.
               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
     non-seismically-qualified systems.
               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
     in there.
               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
     management programs.
               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
     the comments.
               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
     some type?
               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
     GALL now.
               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
     systemlike approach?
               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
                                                     [12:45 p.m.]
               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
     address it.
               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
     you're recommending?
               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
     plant-specific situations.
               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
     is 2-A1-4.
               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?
               [No response.]
               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
     this one?
               [No response.]
               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
     the difference.
               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
     detecting cracking?
               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?
               [No response.]
               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.
               Any questions?
               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
     design basis.
               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
     take place?
               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
     review --
               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
     do --
               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
     revise it.
               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
     201 --
               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
     or SRP.
               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
     recent one.
               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
     design basis.
               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
     wrong --
               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
     be managed.    
               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
     renewal issues.
               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
     the reinforcement.
               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
     monitoring technique.
               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
     survived aging.
               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
     inspection activity.
               MR. WANG:  Other questions?
               [No response.]
               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
     same time.
               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
     practical experience.
               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
     presentations again.
               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
     had before.
               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
     between --
               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
     steel issue.
               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
     synergistic effect.
               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
     the internals.
               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
     current license.
               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
     was such.
               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
     injection sparger.
               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
     spray sparger.
               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
     Hatch review.
               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?
               [No response.]
               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
     to articulate.
               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
     contention here?
               MR. DOZIER:  They felt like IASCC was really not
     an issue.
               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
     longer necessary.
               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
     renewal thing.
               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
     into GALL.
               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
     management programs.
               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
               [No response.]
               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
     where appropriate.
               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
     Chapter XI.
               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
     legitimate question.
               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
     no criteria.
               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
     other ways.
               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
     additional guidance.
               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
     8:30 a.m.]


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