Plant License Renewal - October 20, 2000
UNITED STATES
NUCLEAR REGULATORY COMMISSION
***
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
***
SUBCOMMITTEE ON PLANT LICENSE RENEWAL
Friday, October 20, 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 second day of meeting of the ACRS
Subcommittee on Plant License Renewal.
I'm Mario Bonaca, Chairman of the Subcommittee.
The 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 G1104, Standard
Format and Content for Applications to Renew Nuclear Power
Plant Operating Licenses, and NEI 95-10, Revision 2,
Industry Guidelines for Implementing the Requirements of 10
CFR Part 54, the License Renewal Rule.
The Subcommittee will gather information on
relevant issues and facts and formulate positions and
actions as appropriate for the deliberation by the full
Committee. Mr. Noel Dudley is the cognizant ACRS Staff
Engineer for this meeting.
The rules for participation in today's meeting
have been announced as part of the Notice of this meeting,
previously published in the Federal Register on October 4,
2000.
A transcript of this meeting is being kept, and
will be made available as stated in the Federal Register
Notice. It is requested that speakers first identify
themselves, and speak with sufficient clarity and volume so
that they can be readily heard.
We have received no written comments or requests
for time to make oral statements from members of the public.
We will now proceed with the meeting, and I call upon Mr.
Christopher Grimes, Chief of the License Renewal and
Standardization Branch to begin.
MR. GRIMES: Thank you, Dr. Bonaca. I think my
introduction to yesterday's meeting was sufficient for the
purpose, and so I'll introduce Rani Franovich, who is going
to lead the next section on Engineered Safety Features.
MR. FRANOVICH: Good morning. My name is Rani
Franovich. I'm a Resident Inspector from the Catawba Plant
in Region II, and while I was on rotational assignment to
the License Renewal and Standardization Branch, my
assignment was to resolve or coordinate the resolution of
NEI comments on Chapter 5 of the GALL report, and the
associated section of the Standard Review Plan.
Chapter 5 is on the engineered safety features of
plants. And to my immediate left, I have Dr. Jim Davis from
the Division of Engineering in NRR, and to his left, I have
Chris Parczewski, also from the Division of Engineering in
NRR.
To my immediate right, I have Dr. Vic Shah, who is
from Argon National Lab, and to his right, I have Chuck Hsu
from the Office of Research.
I think it was made pretty clear yesterday that
one thing we can do assist you all is clarify what has
changed significantly from the last rev, the 12/99 rev of
the GALL report. So I have modified my presentation to
accommodate that request.
Before I go through with my presentation with
slides, let me just highlight those areas that you might
want to focus your attention on:
Section E of Chapter 5 used to be fan cooler
systems for PWRs. We received comments from NEI that some
of the components in that section, predominantly fans, were
active components and scoped out of the license renewal
rule.
So when we deleted those items, we had only two
items remaining, and they were both plant-specific aging
management programs. So since there was no longer much
value-added, we deleted that section.
We added a section which we then called Section E
to address external surfaces of carbon steel components and
bolts, and aging mechanisms associated with those.
And that was a generic change to multiple
mechanical sections or mechanical chapters of the GALL
report. And specifically, we added external surfaces of
carbon steel components, which has two aging mechanisms.
One is boric acid corrosion of external surfaces.
We had this in here before, but only for borated
water systems. We added it for non-borated water systems
because of the potential for external systems to leak onto
non-borated water system piping or components.
We also added atmospheric corrosion of external
surfaces for PWRs and BWRs, and for those two aging
mechanisms, the aging management programs are in Chapter 11,
M-5, the Boric Acid Corrosion Program, for the first one,
and then for the atmospheric corrosion aging mechanism, in
Chapter 11, we have Program S-8, which is the coding
program.
For closure bolting and high pressure or high
temperature systems, we also added generically in multiple
chapters, atmospheric corrosion, stress relaxation, and
cyclic loading stress corrosion cracking as aging
mechanisms. And the aging management program that addresses
those aging mechanisms is in Chapter 11, Program M-12, which
is the Bolting Integrity Program.
Another change to Chapter 5 was more of an
internal recognition that for Section Bravo, which is the
Standby Gas Treatment Systems, we used to have an aging
management program reference to NRC Reg Guide 1.52, which
effectively provided controls for humidity.
However, since this system is in standby mode most
of the time, we removed that reference because humidity
would not be controlled unless the system was operating.
There are some additional changes to Chapter 5
that I'll bring to your attention as I go through the rest
of my presentation.
Do I have any questions on what I've presented so
far?
[No response.]
MS. FRANOVICH: Okay. The more significant
comments that we received from NEI on Chapter 5 are fairly
generic in nature and apply to other mechanical chapters as
well.
One of NEI's comments was that they didn't feel
that one-time inspections were needed for certain aging
mechanisms. And for Chapter 5, this applied primarily to
water systems that had chemistry control programs associated
with them.
NEI felt that chemistry programs were adequate, in
and of themselves, and that one-time inspections did not
provide any additional value.
However, the Staff felt that in order to establish
the premise that water chemistry control programs are
effective, one-time inspection would suffice. Another
option could be presented by an applicant, but a one-time
inspection would be adequate.
So, we decided to keep one-time inspections in the
GALL report.
DR. SEALE: There are already existing inspection
requirements for many of these systems. I can envision a
situation where the alternative might be to augment the
requirements of an existing program with additional
requirements that are focused on some particular aspects of
aging, perhaps not to be used or invoked on every
inspection, but, say, every third or every fifth or
whatever.
Has anyone done anything along those lines?
MS. FRANOVICH: Let me defer that question, but
before I do, I can answer that if an applicant wanted to do
that, the Staff would review the proposal and perhaps --
DR. SEALE: I would think so. I was really
wondering if anyone had made those -- had seen fit to use
this as an opportunity to essentially supplement the
inspection requirements?
MR. LEE: This is Sam Lee from License Renewal
Standardization Branch, NRR. We actually discussed with NEI
at the public meeting, exactly the option you are talking
about.
Okay, they are think -- they have a thing about
how do they come about doing that? Because they need to
revise the procedure, perhaps, to address that, to actually
supplement their existing maintenance by looking at aging
effects.
DR. SEALE: From an economics point of view, it
makes a great deal of sense to do it that way, really, I
would think, if it's a legitimate, inspectable need.
MR. GRIMES: This is Chris Grimes. I'd like to
add that during the review of the first two applications, we
ran into some circumstances where there was a question about
whether or not a one-time inspection would be sufficient, or
whether or not it would need to be conducted on a periodic
basis.
And that was, I think, a more difficult decision
for us, in circumstances where we were really looking for a
verification that the aging effect is not occurring to the
extent that it needs to be managed.
And I think that for these circumstances, even
though there are existing -- there may be existing
inspection requirements for particular systems, the concept
of a one-time inspection is to specifically look for
evidence of a particular aging effect that you want to make
sure does not need to be managed. So even though you may
have inspections of ISI inspection requirements, this
concept is to go in and over and above that inspection, to
specifically look for a particular aging effect.
And I think that the industry concern is that --
not the concern, but their view is that you don't even need
to do one-time, because if it isn't going to occur and
doesn't need to be managed, their quality assurance process
will pick it up if evidence occurs much later in plant life.
And we simply want to memorialize that in a
specific commitment to go look at least one time. So for
our purposes, we're going to make a distinction between
one-time inspections to verify that aging does not need to
be managed, from augmented inspection activities to
periodically look for any evidence of an aging effect that
may warrant some action in the future.
DR. SEALE: So you're really touching both bases?
MR. GRIMES: Yes, sir.
MR. DAVIS: This is Jim Davis from the staff. In
doing the reviews, I notice that they are now saying when
they are going to do the one-time inspection. And then
they're committing to, based on the outcomes of inspection,
and make the decision whether to do periodic inspections.
MS. FRANOVICH: Thanks, Jim.
DR. SHACK: Can you send me to a specific example
in Chapter 5 where you have a one-time inspection.
MR. SHAH: D-2, Section D-2.4, D-2.5.
CHAIRMAN BONACA: Sorry, can you repeat that?
MS. FRANOVICH: It's page D2-4, we have an item
D2.1.1 through D2.1.7, piping and fittings and high pressure
coolant injection and various other ECCS type systems. And
if you look on the associated right-hand page, the aging
management program that is provided is the water chemistry
program.
And then in the evaluation and technical basis
column, it really references where that program is described
in Chapter 11.
MR. CHOPRA: Maybe I can clarify that. This is
Omesh Chopra from Argon National Labs.
One time in GALL, one-time inspection is asked for
in situations where normal ISI either asked for only a leak
test. There is no inspection. For example, in certain --
one case would be pitting and crevice corrosion.
The program relied on is just water chemistry.
ISI is just leak test. So, one-time --
DR. SHACK: I have a simple-minded question. I
just want to see where in the document it says do a one-time
inspection.
CHAIRMAN BONACA: Right.
MR. CHOPRA: One-time is to verify the
effectiveness of the program.
DR. SHACK: Where does it say that?
DR. SEALE: It doesn't.
MR. GRIMES: Chapter 11, under the Water Chemistry
Program.
MS. FRANOVICH: In the Table under Further
Evaluation column, it reads, yes, detection of aging effects
should be further evaluated, and what that implies is the
Water Chemistry Program, as described in Chapter 11, is not
in and of itself sufficient. Further evaluation is
required, and a one-time inspection is an acceptable means
of providing the further evaluation.
DR. SHACK: Okay, got it.
CHAIRMAN BONACA: And that's in Chapter 11.
MR. SHAH: There is one other place where we
require the one -- we recommend one-time inspection, the
refueling storage tank where there is a concern for the
cracking from the inside, but the ASME section requires only
visual inspection from the outside. That's another place,
Section D-1.
MS. FRANOVICH: Any other questions on one-time
inspections?
MR. GRIMES: For Dr. Shack's benefit, on page 11,
M-25, under Program Description for Water Chemistry, towards
the bottom of the paragraph it says as set forth below, and
acceptable verification program may consist of a one-time
inspection of selected components and susceptible locations
in the system.
CHAIRMAN BONACA: And under monitoring and
trending, also there is a reference, okay.
DR. SHACK: So, every time an XM-11 is called, you
may well be set up then for a one-time inspection also.
MR. GRIMES: Correct.
DR. SHACK: When you're relying on water
chemistry, you want the verification inspection?
MR. GRIMES: No.
MS. FRANOVICH: I believe there are exceptions to
that, but in general, if the applicant would like to take
credit for water chemistry control, we, the Staff, think
it's fair to ask them to establish the effectiveness of that
program before they credit it.
So, for the most part, I think you'll find that
that's the case, but there are exceptions.
MR. SHAH: There are cases where the ASME Section
11 --
DR. SHACK: If you're already doing Section 11
inspections --
MR. SHAH: So you don't need it. So it is only
where we have mentioned; that is only place we need a
one-time inspection.
DR. SHACK: Now, suppose you're looking at MIC
problems? Is it the same sort of thing, that you're relying
on water chemistry to control MIC, or you're allowed a
one-time shot?
MR. SHAH: We have a separate program called open
cycle water chemistry program and that program addresses
that.
MS. FRANOVICH: Shall we go on?
CHAIRMAN BONACA: Yes, but I would like to make
just a comment. This is valuable. You pulled that thing
and it went through, and I think it would be good for the
full Committee presentation to have an example like this, so
that there's an understanding for the members of how it went
through.
Because without that kind of guidance, at times it
wasn't easy to review the Staff and see how you came from
the SRP to a program and down to the detail, and this was
very valuable.
MR. DAVIS: In addition there's the 89-13 Generic
Letter that tells you what you're supposed to do to avoid
fouling, one of which is heat exchanger efficiency.
DR. SHACK: Okay, you actually have a performance
measure you can look at, and that --
MR. DAVIS: Right.
DR. SEALE: One of the problems with this seems --
just listening to this, is that sometimes it's hard to
figure out which string to pull in order to identify this,
and I guess at this point, you're at -- probably loggerheads
is not an appropriate word -- but there is some negotiation
between Staff and NEI as to whether or not one-time
inspections are needed.
And that's probably a discussion that is specific
to individual inspections, rather than the principle of
one-time inspections.
But nonetheless, somewhere in this, it would seem
to me desirable to get some kind of reaction from NEI to the
idea that, okay, you are going to have one-time inspections.
How easy is it for a given utility to dig the
requirement as you envision it being applied, out of these
documents, so that when they come in with their initial
plan, one -- the first set of RAIs is not dominated by
requests for additional one-time inspection program needs
and that sort of thing.
MS. FRANOVICH: I think that in the meeting we had
with NEI, one of the things, as Chris mentioned, that we
discussed is actions that they're doing currently, and have
done in the past, the recent past, maintenance activities,
modifications to the plant, where they can take advantage of
that activity, ongoing, to do inspections, document them so
that they are retrievable and auditable, and say we did this
inspection at this time, and did not see any indications of
corrosion or aging degradation.
In fact, at Catawba, in their current refueling
outage, they are cleaning a lot of service water piping
that's buried, and one of the things that the license
renewal folks can do -- have asked them to do, is an
inspection while they're doing that, that's documented, so
that when they submit their application next Summer, that's
something they can provide to the Staff, if needed.
So I think that is probably a little bit
negotiable to avoid, you know, high costs for doing this.
DR. SEALE: Well, and that's exactly the reason
that it ought not to be an item of extended discussion, but
rather prompt agreement one way or the other so that if the
opportunity to do these things arises, you just go ahead and
do it and get it out of the way.
MS. FRANOVICH: Right. As far as I can recall
from our meeting, that was an idea that sounded appropriate
to us. If they had an opportunity to do it in their normal
maintenance and modification processes, that would be fine,
as long as it's documented and auditable.
DR. SEALE: As long as it is truly a competent
inspection.
MS. FRANOVICH: Agreed.
MR. GRIMES: This Chris Grimes, but, Dr. Seale, I
understand the point that you've made about making sure that
the guidance is clear in terms of what the expectation is,
and as we go through our efforts to improve the packaging of
the guidance, that we look to call out --
DR. SEALE: Italics.
MR. GRIMES: Big stars on the page or something
like that, but I'm sure that there are --
DR. SHACK: Hyperlinks.
[Laughter.]
MR. GRIMES: I was warned that I'm not allowed to
use hyperlinks until we go totally electronic.
DR. SEALE: That's more room in Hilbert's space.
MS. FRANOVICH: Okay, the next item I want to talk
about was touched on yesterday as a result of Bill Shack's
question about the use of GALL and whether or not an
application that does not list all of the SSCs that are in
the GALL report is, indeed, complete.
NEI raised the same question. They were concerned
that the GALL report would be used by the Staff for scoping
implications.
And we made it very clear that the GALL report
neither implies what should be scoped under the rule, nor
does it impose additional requirements. All it is is a
compendium of what the Staff has previously evaluated and
made a determination on.
So, I think we laid NEI's concerns to rest about
the scoping question.
MR. SIEBER: Does it say that someplace in here
that you aren't supposed to rely on GALL as the scoping?
MS. FRANOVICH: Yes, it does.
MR. LEE: It says it in more than one. Also about
the application of GALL, that it's not a scoping document.
MS. FRANOVICH: It's clearly articulated.
MR. SIEBER: Thank you.
MS. FRANOVICH: Sure.
Our next item I want to mention was another fairly
significant NEI comment. Inservice testing, at one time,
was in the GALL report in the December '99 rev it was in the
GALL report in Chapter 5 as well as other chapters.
And NEI was concerned that inservice testing was
referenced as an aging management program because its
objective is to reveal problems, failures, of active
components.
So, when we heard that comment and discussed it,
we agreed, and decided to remove reference to inservice
testing from the GALL report.
In addition to that, for Chapter 5 specifically,
NEI was concerned about the reference to Appendix J leak
rate testing for containment isolation valves, saying that
that is testing an active component's function and it's not
appropriate because they're not within the scope of license
renewal.
So we also removed Appendix J testing from Chapter
5 of the GALL report as well, however, we left it in Chapter
2, Structures, as it pertains to penetration seals and
equipment and personnel hatches.
DR. SEALE: There is a systemic possibility for
difficulty here, it seems to me, especially if you go to an
inservice inspection program that is risk-informed, as a lot
of people have.
They have used these to decrease the number of
active inspection that they do by -- to some 25 percent of
what they were at one time.
And they have a menu that's relatively structured
in defining or in deciding what it is that you expect. On
the other hand, if you have an aging problem, it's almost
implicit that there is, if you will, a kind of -- well, let
say, the likelihood of a threshold.
And so there may be things which, based on your
risk-informed sampling process, or inservice inspection, you
might not do, but which, based on concerns about other
longer-term aging processes, you might want to look at.
The question I have is, if I decided that there
was a problem that had to do with a component or system area
that was already receiving the tender loving care of an
existing inservice inspection program, could I lay on top of
that, a one-time inspection requirement to look at this
other odd-ball or, let's say, different kind of aging
mechanism?
MS. FRANOVICH: Aging mechanism, and I feel that
that would be acceptable, but I will defer to Dr. Kuo, Dr.
Lee, or Chris Grimes.
DR. KUO: Yes, I would like to add to it and just
give you a little background of why -- how this one-time
inspection first came up.
When we had our review of the applications in both
Calvert Cliffs and Oconee, there was a time that the
applicant wanted to say that we don't have any aging effects
on certain systems such as water, surface water systems,
because we have this effective water chemistry program. So
we don't see any corrosion. There is no need to do
anything; that there is no need for aging management, and
there is no such aging effect.
DR. SEALE: And, in fact, you and I know that
there well may, in fact, be something that has a 20-year
horizon on it where it only looms after that.
DR. KUO: Correct. Okay, that's why we say, okay,
if that's the case, then we want to have a confirmation, why
don't you do a one-time inspection to confirm that? If
that's, indeed, the case, yes, we agree, water chemistry
program is sufficient.
And for that reason, the Calvert Cliffs applicant
actually did a one-time inspection for their other water
storage tank, and they found no indications whatsoever, any
corrosion. We said, okay, we accept that, and that is one
example of one-time inspection that really served them well.
MR. GRIMES: I'd like to add to that that I'm not
concerned about how risk-informed ISI might evolve in the
future, because I think that risk-informed decisions on
changing frequency or sample sizes are driven by equipment
reliability consideration that are on a much shorter
frequency than the evolution of aging effects.
DR. SEALE: And hopefully equipment and
reliability reality.
MR. GRIMES: Correct. We would expect that even
though the frequencies in sample sizes might change, that if
aging effects are occurring which do have long, much longer
evolution times that the aging effects will be manifest in
time to take corrective action that may result in further
changes to the inspection scope and frequency for that
purpose, simply because they have now identified a
degradation that needs to be managed in a different way, and
so we expect that ISI can work in concert with an effective
corrective action program to make programmatic changes that
will address aging effects.
So I still think that even risk informed ISI is an
effecting Aging Management Program as it evolves.
DR. SEALE: Well, my only concern is once you do
get a good ISI, risk informed ISI program you still want to
look for wet spots on the floor.
[Laughter.]
MS. FRANOVICH: And I think, just to add, in our
discussions with NEI we heard a lot of "we have never seen
aging mechanisms in this system" and when asked, well, have
you looked? -- well, no, but we just haven't seen it, so
that was another impetus for doing the one-time inspections.
DR. SEALE: When I was 55 I didn't think I would
ever have a knee problem.
[Laughter.]
MS. FRANOVICH: Okay. Going on, those were the
significant NEI comments on Chapter V, some of which or
actually all of which had implications for other chapters in
the GALL report.
The license renewal issue that is addressed in
Chapter V, and my understanding is that the license renewal
issues are a list of issues that arose from a 1997 NEI
comment period on the GALL report at that time.
MR. LEE: The SRP at that time.
MS. FRANOVICH: Sorry, the SRP at that time. I
don't believe the GALL report existed at that time.
The license renewal issue applying to Chapter V
was 98-083, stress corrosion cracking of carbon steel.
The Staff was asked to develop a position as to
whether or not this aging mechanism was viable for this
material.
The Staff concluded that yes, this is a viable
aging mechanism for carbon steel if certain strength
characteristics of the material are present.
When it came to bolting, we determined that the
strength characteristics of bolts would make them
susceptible to SCC so we have added an item in Chapter V and
other chapters as well, the Bolting Integrity Program, to
address stress corrosion cracking of bolts.
When it comes to valve bodies, the strength of the
material is such that SCC really is not a viable aging
mechanism so that is not addressed in the GALL report, so
that is how we have handled that license renewal issue.
There are several items of interest I want to
discuss with regard to Chapter V. A couple of them have
generic implications for other chapters and these items of
interest are more or less items that were identified by the
Staff and contractors as this project has evolved, changes
we have made to improve the product.
One is at one time general corrosion and loss of
material for stainless steel in borated water systems was in
GALL in several mechanical system chapters. The Staff
determined that that is really not an aging mechanism, a
viable aging mechanism in that environment, so multiple
items were removed from the GALL report that addressed this
general corrosion and loss of material of stainless steel
and borated water systems.
With regard to Chapter V specifically, when we
removed the Aging Mechanism Program reference to Appendix J
testing from Chapter 5 for containment isolation valves we
discovered that the treatment in GALL of treatment isolation
valves was really no different from the treatment of valves
in other applications, noncontainment isolation
applications.
As such, we decided to delete a number of
containment isolation valves from Chapter V and address them
in the system-specific sections throughout other chapters of
the GALL report.
We also opted to remove penetration seals and
equipment and personnel hatches from Section C, which was
the containment isolation barrier section for Chapter V and
relocate them to Chapter II on structures, where Appendix J
testing was more common to that chapter, so we have no
reference to Appendix J testing, leak rate testing, in
Chapter V at all anymore.
Another item that we added to Chapter V and other
mechanical system chapters as well is atmospheric corrosion
of carbon steel components, external surfaces, and I touched
upon that when I went over the changes that were significant
to highlight from the 12-9 Rev. to the current Rev. of the
GALL report.
MR. SHACK: Is that based on field experience?
MS. FRANOVICH: Let me defer to Omesh or -- the
question is was atmospheric corrosion of external surfaces
of carbon steel components added because of field
experience?
MR. CHOPRA: These items were covered in Calvert
Cliffs application and Oconee application so we decided to
add it.
MR. SHACK: Oh, so this is a lessons learned from
the Calvert Cliffs?
MR. CHOPRA: Right.
DR. SEALE: Saltwater will do it.
MR. DAVIS: This is Jim Davis from the Staff.
In addition, the NEI guidance documents discuss
the loss of material for carbon steel and they say carbon
steel immersed in an aqueous environment with oxygen present
causes corrosion when about 90 or 95 percent of the
corrosion that we are seeing is in the atmosphere and it is
not immersed in a fluid.
DR. SEALE: Salt air.
MR. DAVIS: Salt air or just humid air.
DR. SEALE: The Navy knows about that.
MR. DAVIS: That was one reason it was added, to
make sure that it is understood that atmospheric corrosion
can occur.
DR. LEE: That first bullet on your slide there,
corrosion and loss of material for stainless and borated
systems, was deleted. Could you say again why that was
deleted?
MR. DAVIS: Because corrosion of borated solutions
doesn't corrode stainless steel. There is that code case in
616 now that says if you have stainless steel fasteners in a
bolted connection you don't have to remove the insulation to
do your system leak test because nothing is going to happen.
We have a lot of history on that.
DR. LEE: Okay, thank you.
MS. FRANOVICH: That concludes my presentation on
Chapter V. If there are any other questions --
[No response.]
MS. FRANOVICH: Then I think we can move on to
Chapter VI.
DR. SEALE: Sometimes it might be nice to hear
about your overall impressions of your loan assignment and
so on. We are very interested in the opportunities that
people from the regions get to have the opportunity to look
at other parts of the organization and so on.
Some people from the regions have made some
extraordinarily helpful contributions to some other tasks
that they have had assigned up here.
MS. FRANOVICH: Cross-pollination is good.
DR. SEALE: Yes, we appreciate your being with us
today.
MS. FRANOVICH: Thank you. Perhaps at the break I
could chat with you.
DR. SEALE: Okay.
[Pause.]
CHAIRMAN BONACA: Okay.
MR. MITRA: Good morning again.
CHAIRMAN BONACA: Good morning.
MR. MITRA: This is Eskay Mitra from License
Renewal Branch. I am the technical lead on GALL, Chapter VI
and with me are three gentlemen who have significant
contribution in Chapter VI writeup.
To my immediate left is Paul Shemanski of NRR
Staff, Mr. Jit Vora next to him is from Office of Research,
and to my right Mr. Bob Lofaro of Brookhaven National Lab.
With that, we have had a number of conversations
and discussions and meetings with NEI regarding Chapter VI
electrical components and I can declare victory that almost
99 percent of the comments we have resolved and the one
percent we didn't is very insignificant.
Most of them are resolved, some of them are partly
resolved, so I am not going to even mention those not
resolved because they are so insignificant.
The first comment is on treatment of inaccessible
and buried non-EQ cables. Actually this is two different
issues.
One is inaccessible cables, which are those cables
that are in conduits or in trays or a location which is hard
to access. Buried cables are generally medium voltage.
When an acceptable condition is identified for a
cable or a connection in the inspection sample a
determination is made as to whether the same condition is
applicable to inaccessible cable in connections.
The program also includes inaccessible which is
directly buried medium voltage cable within the scope of
license renewal that are exposed to significant moisture
simultaneously with significant voltage.
This topic was not addressed in the original GALL
document. We had, as I said, a number of discussions with
NEI and then we added these inaccessible buried cable in
GALL Chapter XI, Section E-1 and Section E-3, respectively.
Section E-1 is treatment of inaccessible cable and Section
E-3 is the medium voltage buried cable.
Number 2, comments, the bullet we have,
elimination --
CHAIRMAN BONACA: Before you move on, I
misunderstood. You said there were two issues here. One
was inaccessible cables --
MR. MITRA: Yes.
CHAIRMAN BONACA: And the other one was? I missed
something.
MR. MITRA: The other one is buried medium voltage
cable which is --
CHAIRMAN BONACA: Okay, but in your bullet it
specifically talks about non-environmentally qualified
cables.
MR. MITRA: Non-EQ cables.
CHAIRMAN BONACA: Non-EQ cables, okay, and what
was the disagreement with NEI or the comment from NEI?
MR. MITRA: The comment was that it was not
included in the first original GALL documents.
CHAIRMAN BONACA: Okay.
MR. MITRA: And we discussed about including it
with NEI and we mutually agreed to include it and we
included it in Chapter XI, Section E-1 and E-3.
CHAIRMAN BONACA: Okay, and there, just to give us
a summary, what kind of inspections are suggested in those
sections?
MR. SHEMANSKI: Paul Shemanski from Electrical
Branch.
Basically it is -- not a one-time inspection but
it is an inspection conducted every 10 years -- once every
10 years, so theoretically the first inspection would be,
say, Year 41, and the second inspection would be at Year 51,
and we feel that is appropriate because in general these are
slow-acting aging mechanisms for cables and by having
multiple inspections, one every 10 years, that allows the
opportunity to develop at least two datapoints and perhaps
some trending could be done, so these are primarily 10-year
visual inspections.
CHAIRMAN BONACA: These are non-environmentally
qualified so they are pre-IEEE standards or simply --
MR. SHEMANSKI: Basically the same type of cables
physically. The main difference is that these cables while
they may be exposed to a harsh environment they are not
required to perform any mitigating functions during the
harsh environment, so these in essence are declared non-EQ
cables. For the most part they are essentially the same
type of cables that are used on the EQ master list.
It doesn't make any sense to buy specialized EQ
cables and then a lower grade cable for non-EQ so in essence
these are the same type of cables physically as you would
find on the EQ master list.
CHAIRMAN BONACA: We asked a consultant to review
some of the issues on cables and he will provide you with
his feedback.
One comment he had made was the 10 year inspection
as again progresses could be accelerated, I mean to have a
more frequent inspection interval, if I understand it.
Could you comment on that?
MR. SHEMANSKI: Well, as a result of going through
the Oconee application, for non-EQ cables Oconee initially
did not identify the need for a cable Aging Management
Program. However, after an inspection down at Oconee and
further discussions with them Oconee agreed with the Staff
that a cable Aging Management Program should be developed,
so we worked very closely with Oconee on this issue as to
what would constitute an acceptable Aging Management
Program.
Of course, one of the elements was how often do
you conduct your inspections, and after many discussions we
felt a 10 year interval was an appropriate number, again
based on the fact that in general the aging mechanisms tend
to act fairly slowly with the exception of cables that might
be in hot spots for example but that is one area that they
will be looking for to identify any hot spots that would
lead to more accelerated degradation, so it was a mutually
agreed-upon test interval, 10 years.
Again by doing it every 10 years you would
experience two of these inspections during the renewal
period so perhaps you could do some trending. That second
datapoint would perhaps tell you if the aging is
accelerating.
As experience goes on, perhaps in the future maybe
that interval will have to be shortened, but for right now
we feel generally comfortable with a 10 year inspection
interval for these cable.s
CHAIRMAN BONACA: For example, Oconee already then
is trending now, starting now or is it going to trend
starting at 40 years?
MR. SHEMANSKI: Well, basically the way the
program is set up they would do their first inspection at
Year 40 or Year 41 --
CHAIRMAN BONACA: Well, there's isn't much
trending you can do with the two.
MR. SHEMANSKI: Yes, it's kind of minimal to do
trending but it's --
CHAIRMAN BONACA: Trending can maybe only tell you
something after 50 years.
MR. SHEMANSKI: Yes, the first inspection at Year
41 would basically give you baseline data and then when you
conduct your second inspection 10 years later you might be
able to get a little better feel to see if the aging is
staying relatively the same or accelerating.
DR. SEALE: It is going to be fascinating if you
have any hot spots after 40 years that you didn't have
before.
MR. SHEMANSKI: Yes. That would be quite unusual.
However, there are occurrences. Back in the mid-'70s I
recall one plant where they went through an outage. They
removed some insulation in the upper drywell, didn't realize
it until two years later when the cables started to degrade
so -- although they are rare, it is conceivable that could
happen.
Generally you would not expect a plant to all of a
sudden develop hot spots.
DR. SEALE: I certainly hope you could find a
direct cause like that if you had that problem.
MR. SHEMANSKI: Right. In that case it was fairly
easy.
DR. SEALE: Yes.
MR. SHEMANSKI: Right.
MR. GRIMES: This is Chris Grimes. I would like
to add that in addition to the specific inspections provided
to look for the condition of inaccessible cables, non-EQ
cables, we do expect that operating experiences are going to
continue to provide a feedback as events like Davis-Besse
provide experience and lessons across the industry.
Also, as several renewal licenses come into play
then there will be some experience that can be shared across
the industry for inaccessible cables.
If future experience in the future indicates a
need, then we would expect that the program would evolve and
change as the need arises.
DR. UHRIG: You indicated that these are medium
voltage. What do you mean? 440 volts? Are these power
cables to pumps and motors?
MR. SHEMANSKI: These are -- first of all, the
event occurred last October at Davis-Besse, and it was on a
4160 medium voltage cable buried -- well, it was underneath
the turbine building in a four-inch conduit. I believe it
was hooked up to the component cooling water pump and it
basically failed.
It was a catastrophic failure and the failure
mechanism was due primarily to moisture which somehow was
trapped inside a four-inch diameter PVC pipe and we don't
know exactly how long the moisture was in there, but
ultimately it got into the insulation and resulted in cable
failure, so that was what got our interest in terms of in
that case an inaccessible medium voltage cable subject to
significant moisture.
DR. UHRIG: And this is a cable that is feeding
current to a motor operating continuously or is this one
that is called upon as needed?
MR. SHEMANSKI: These component cooling water
pumps are continuously operated.
MR. SIEBER: That is more severe than --
MR. SHEMANSKI: Yes, right. Yes, the combination
of moisture ingress into a cable which is energized is where
you get into trouble.
DR. UHRIG: Do you have any different problems
with cables carrying sensor measurements, signal cables as
opposed to --
MR. SHEMANSKI: In terms of moisture?
DR. UHRIG: Yes, or the failure mechanism.
MR. SHEMANSKI: Well, those primarily for the most
part are in a dry environment so the main stressors there
are radiation and temperature.
However, I think as a result of our work on
GSI-168 we generally found that cables which are, I&C cables
which are exposed to between 20 to 90 percent moisture are
generally not affected.
If the moisture is above 90 percent, then we would
probably have some concern, but typically those cables are
not subject, the I&C cables are generally not subject to
moisture conditions, submergence, for example.
The Davis-Besse event was unique in that the cable
was actually a fairly long run, nearly 200 feet. The cable
was buried underneath the turbine building underneath the
concrete floor running through conduit. Somehow groundwater
perhaps got in, so that was sort of a unique situation.
DR. UHRIG: You mentioned GSI-168. This is
scheduled to be resolved in the near future.
Do you anticipate that the method by which it is
resolved will have an impact upon the license renewal
activities?
MR. VORA: This is Jit Vora from Office of
Research.
Dr. Uhrig, last Friday the Staff had the
opportunity to brief you about the state of the GSI-168 and
then qualification of low voltage I&C cables and provide and
discuss the test results which involve for the current
license term of 40 years and for the renewed license
consideration for 60 years.
Now with regard to the license renewal, the EQ is
considered as a time-limited aging analysis and the time
limitation is because the long-lived passive components such
as cables is not qualified to a specified life of 40 years.
What actually happens with the requirement of 10
CFR 54.21(c) it provides the three options to demonstrate
the qualification during the new license period and the
licensee must comply with one of the requirements and put in
place appropriate an Aging Management Program for renewed
license consideration.
Now since the CLB involving the EQ carries forward
during the license renewal term, whatever is the outcome of
the resolution of GSI-168 for the current license term will
carry forward.
One of the important things which you have time to
achieve within the next couple of months is that we are
evaluating various pros and cons of the various options for
the resolution of GSI-168.
An important part we need to do is actually
disseminate the research results and to hold an open public
meeting and dialogue about the research results, publish the
technical report and findings and get the feedback from the
IEEE, from the industry and the institution, so this is our
program for the next couple of months -- the resolution of
GSI-168 -- but in the bottom line, in the Part 54.21(c)
provides the appropriate method to address any EQ issues for
the license renewal consideration.
DR. UHRIG: The presentations at these public
meetings will be similar to what we received a couple of
weeks ago?
MR. VORA: Primarily focused on the test results
for the six LOCA tests that we accomplished through
Brookhaven and Wylie Laboratories and actually provide the
results.
Now the one portion of the test program which
involved cables and some of their experience during the 40
year and 60 year have already been discussed and
disseminated and the appropriate NRR interactions are taking
place with the industry. We also had a meeting with NEI and
we are also getting some feedback about experiences from the
operating nuclear power plants, so it was a very good
dialogue and discussion, and hopefully we will have similar
discussions with other test results too.
DR. UHRIG: We have a consultant's report here
which I just got hold of yesterday addressing some of the
issues, and it makes a point about separating the radiation
that is induced here sort of before an incident and after
the incident, as far as the testing procedure is concerned,
whereas, it seems to be, in the work that you alluded to, it
was sort of lumped together.
Do you think this will have significant -- would
give different results than you obtained with the Wiley
testing?
MR. VORA: From my experience actually, and we are
talking about a simultaneous versus the sequential?
DR. UHRIG: Yes.
MR. VORA: And we actually, when we actually
develop and design our test program for this current series
of tests, we factor into the results which are obtained by
Sandia where they are done actually, the simultaneous
pre-aging. And the program which we developed actually was
according to what were the original qualifications which
actually were conducted by the supplier and the
manufacturer. So we tried to stay within those areas and
those profits and parameters. And that was the idea, was to
see about the value at the original qualifications and did
not make any other changes in that regard.
Bob, do you have anything else?
MR. LOFARO: This is Bob Lofaro from Brookhaven
Lab. In regard to the issue of radiation sequencing, as Jit
mentioned, there have been some studies done which looked at
the differences in variation of sequences. In other words,
if you perform radiation aging prior to thermal aging, or
simultaneously with it, would that affect the condition of
the cables.
DR. UHRIG: That is the issue that is being raised
here.
MR. LOFARO: Right. And some work has been done
actually by Sandia some years ago where they actually looked
at the difference. And what they found is that for some
cables, there could be some difference. For other cables,
it made no difference at all. So it really depends on the
materials that you are looking at.
In the research program that we looked at, we
studied the aging techniques that have been used in the past
to qualify cables and looked at how adequately they really
simulated the aging that these cables see in actual nuclear
service. And what we found from the data that we could
gather, that the pre-aging techniques where you used
sequential thermal and radiation aging did an adequate job
of representing the aging on these cables.
So from our results, we feel that there is some
evidence to show that the sequential aging of the cables is
adequate.
MR. GRIMES: Dr. Uhrig, this is Chris Grimes. I
would like to add that, as a result of the recommendation by
Dr. Seale, we contacted the Los Alamos National Laboratory.
Jim Koons is the contact that we talked with, and he is
working in the polymeric materials aging program for the DOE
weapons program. And we found out, we learned a lot
actually about work that they are developing to explore
silicone chemistry and silica structure that is primarily
for sealing materials, but it is also contributing to models
that they are sharing with Sandia. And we already have a
Sandia contact through the Office or Research that has been
contributing to the exploration of the cable aging effects
and the implication of the test results and ways to
understand what the test results mean from the standpoint of
the reliability and uncertainty and cable qualification.
I expect that there is probably going to be more
in the future in the way of an improved understanding of
what the aging mechanisms are. The weapons program is
providing information that might improve the modeling and
future research. But I think I would go to the bottom line
on your question, it was, could the results of this work
affect license renewal? And my expectation is it will
probably affect the current license requirements as well as
license renewal at some point in the future, but right now
we don't see any concern about the existing programs that
are relied upon for cabling aging effects.
DR. UHRIG: Well, virtually, all of the plants
that are coming in are the older plants, for the simple
reason that they will need licensing sooner, and all of
those are the so-called exempted plants under GSI-168. And
most of those go back to the old DOR, Division of
Operational -- Operating Reactors regulations in effect in
the early '80s. And the testing there is minimal, as I
recall.
This was the genesis of my question here as to
whether it would really have an effect upon the licensing.
As I recall, in the Oconee, there was a specific testing
program that was laid out in respect to cables, if I
remember correctly.
CHAIRMAN BONACA: Yes, to inspect cables, yes.
They agreed to a program, and also for Calvert Cliffs, I
believe.
MR. GRIMES: But both of those plants also have
programs to maintain compliance with 50.49 in terms of the
qualification basis for their plant. And, as you mentioned,
for the plants that were licensed under the DOR guidelines,
I would expect that they would go back and look at the
qualification basis for their cables and incorporate the
results of the research work in terms of challenging whether
or not those qualification tests were sufficient.
MR. VORA: This is Jit Vora. I might add
something, that is a very good question. And during our
research program, when we evaluated some of the older
plants, what we have found out, that we believe that most of
the plant inventory, it was not required for them to do any
pre-aging of the cables. They actually, on their own
initiative, have done, first of all, the pre-aging of the
cables on their own initiative.
The second thing which came out from the research
result, we had actually tested some naturally aged cables,
one were 10 years old naturally aged cables, and 24 year old
naturally aged cables. And in both of the instances, these
cables which were actually originally came out from the DOR
guideline plants, they performed as good or better that the
artificially aged cables, and actually, these cables
actually, in the testing program that we implemented, using
the latest requirements, more stringent requirements. So I
think they gave us a confidence about the vintage of the
older cables, and I think they did okay.
DR. UHRIG: Thank you very much.
CHAIRMAN BONACA: Just one last question. Going
back to the Oconee event, when they found that -- when they
had a problem with a cable buried under the turbine
building, --
MR. SHEMANSKI: That was Davis-Besse.
CHAIRMAN BONACA: I'm sorry, Davis-Besse. Did
they follow with inspections of other cables in the same
cable trays?
MR. SHEMANSKI: Yes, they did. As a matter of
fact, the cable that failed was last October, and it was on
component cooling water pump number 2, 4160 volt cable, and,
again, there was no indication. It was just a catastrophic
failure that failed, the cable basically shorted to ground
due to water ingress.
In addition, they have component cooling water
pumps number 1 and number 3, and what they did shortly
thereafter was they removed those cables. They did some
preliminary electric measurements to get baseline data, but
because of the component cooling water pump number 2 cable
that failed, Davis-Besse decided to replace component
cooling water pump number 1 and number 3 because all three
of these cables are basically in parallel underneath the
turbine building, and they were -- they wanted to find out
if component cooling water pumps number 1 and 3 also had
water in the conduits. They were both dry.
So, nevertheless, they did pull out those cables
and they were in perfect condition. They replaced them with
new cables. In addition, they identified --
CHAIRMAN BONACA: And they are still grounding,
however, in the same cable tray?
MR. SHEMANSKI: Well, not cable tray, these are
underneath. They are plastic, four inch diameter PVC tubes.
And they identify the potential for that same failure
mechanism to occur on other systems, I believe the makeup
water system and the service water system. They apparently
are designed in a similar manner where perhaps moisture
could get in. Nevertheless, they did run electrical tasks
on those cables and they appear to be in good condition.
They did some partial discharge testing and I believe some
power factor testing, enough electrical tests to give them
confidence that those cables are good.
So it appears to be a -- we had concerns as to
whether or not this was a generic problem, because the
moisture, through osmosis, got through the insulation, which
is not supposed to happen. But, anyway, according to the
root cause report they just sent in, it appears to be just
an isolated event that occurred at Davis-Besse.
MR. VORA: I might add one more item, for about 23
year old cable, and actually when the moisture actually got
into it, and before the water level going up and down, it
will go right through the EPR insulation on it. From the
experience, I think one of the things which I feel was very
important that they actually were able to use some
diagnostic and condition monitoring like the power factor
measurements and the partial discharge measurement, and to
develop enough confidence about their effectiveness to test
different types of cables. So I think that was very
beneficial I think to the entire industry to learn from this
experience.
And we are trying to disseminate that result,
discuss with IPEEE standards that this is one way, sometime,
if somebody wants to evaluate the medium voltage buried
inaccessible cable, the electrical techniques might be one
way to go about doing that.
MR. SHEMANSKI: Just one more comment. Again,
this is another example of where we took recent operating
experience and tried to incorporate it into GALL and the
SRP.
CHAIRMAN BONACA: Thank you.
DR. LEITCH: In Chapter XI E-3, the description of
non-EQ inaccessible medium voltage cables, it speaks about
the cable should be tested once every 10 years. Would some
of your experience be factored into that testing? It
doesn't particularly describe how that testing would be
done, or what type of testing is intended there.
MR. SHEMANSKI: At this point we don't know
exactly what type of electrical measurements will be made.
We discussed this with Oconee, this particular aging
management program, although the failure occurred at
Davis-Besse. We worked very closely with Oconee to develop
this particular aging management program for medium voltage
cables. And the commitment we have now basically is that
they will test this cable, these 4160 volt cables, medium
voltage cables once every 10 years.
However, Oconee at this point did not commit to
the exact test that will be performed. As they get closer
to a testing time requirement, say year 41 roughly, at that
point they will make a selection as to which is the most
appropriate electrical test. They didn't want to tie
themselves into a particular test at this point like partial
discharge or power factor. Between now and the time these
cables are tested, perhaps better techniques, or newer or
additional techniques will be available. So they just -- we
just left it at the fact that these cables will be tested,
recognizing that the method will be determined shortly
before the test is conducted.
DR. LEITCH: Okay. Thank you.
MR. SHEMANSKI: In addition, they are also looking
for moisture. They have moisture monitoring programs trying
to see if moisture is getting into these conduits or
trenches, wherever the cables are installed. They have
moisture detection programs.
DR. LEITCH: I guess just one further curiosity
question is that the Davis-Besse thing, are they sure that
moisture got into cable number 2 and moisture did not get
into 1 and 3?
MR. SHEMANSKI: Yes. As a matter --
DR. LEITCH: I mean is that just hypothesized or
is there data?
MR. SHEMANSKI: No, that was an actual -- when the
failure occurred, that cable was removed from component
cooling water pump number 2, and the cable physically was
about 1-1/4 inches in diameter. You could actually run your
fingers down the cable and water would ooze out.
DR. LEITCH: I see.
MR. SHEMANSKI: So that cable was essentially
saturated. However, the cables in component cooling water
pumps number 1 and 3, which were just adjacent to the one
that failed, they were just -- they were dry. They were
removed, and they came out dry and they tested fine
electrically. So, it is sort of a mystery as to how water
got in across the conduit seal, somehow it was cracked.
Ground water got in.
DR. LEITCH: And presumably, that condition still
exists, right?
MR. SHEMANSKI: Well, the potential still exists,
I believe, yes. Yes.
MR. VORA: I think with this, because there is no
moisture underneath and the cable is removed actually from
component cooling water 1 and 3, they almost look like brand
new cable after 23 years of experience. So I think that
provides a confidence about the continuity for 40 years,
even for extended life. And, also, with the development of
the new diagnostic techniques, the combination of that
experience of the 23 years, and also the diagnostic
technique, I think you will see enough insight and tool for
the 60 year life if we need to look into it.
DR. LEITCH: Okay. Thank you.
MR. MITRA: I don't know if we answered Dr.
Uhrig's question about medium voltage cable. What about
definition? Medium voltage is anything within 2 kv to
15 kv, and anything less than 1,000 volt is the low voltage
cable, and over 15 kv is the high voltage, which is very
unique in a nuclear power plant. We almost don't have it.
DR. UHRIG: This is an IPEEE definition, or is
this an NRC?
MR. MITRA: No, this is IPEEE.
DR. UHRIG: IPEEE.
MR. MITRA: Yes. Okay. The second comment we had
about elimination of certain known EQ long-lead passive
electrical components, and we had considerable discussion
with the industry and we concurred. And we removed
following components from GALL since their aging effects are
not determined to be significant in first two applications,
which is Calvert Cliffs and Oconee, such that they will
result in a loss of component function and no aging
management programs are required for this following
components. One is -- number 1 is electrical penetration
assemblies, electrical busses, electrical insulators,
transmission conductors and ground conductors. These are
eliminated based on the actual experience, operating
experience.
CHAIRMAN BONACA: And you feel that that
elimination can be generic, irrespective of the environment?
MR. MITRA: Well, --
CHAIRMAN BONACA: I mean you have two
applications, but you feel that this conclusion of
eliminating that is applicable to all next applications
coming?
MR. SHEMANSKI: Not necessarily. The reason that
these components were put on the -- or we added them to
GALL, they originated primarily from the Oconee application.
As you recall, Oconee has the Keowee dam and they use the
hydro units for their emergency power.
CHAIRMAN BONACA: Yes.
MR. SHEMANSKI: So Oconee scoped in the
transmission conductors, ground conductors, large electrical
busses. And while they were identified in the Oconee
application, the aging mechanisms were not -- or aging
effects were not determined to be significant. So Oconee
concluded that they do not require an aging management
program on these components, and we agreed with them in our
safety evaluation report.
So we decided that there was really -- since there
are no current industry aging management programs for these
type of components, we decided to remove them from GALL.
However, there is a potential on some of these, for example,
there may be plants close to the ocean where salt-spray
could be a program. We may have corrosion on some of these
components that would be in scope, electrical insulators or
transmission conductors.
So, in general, most plants should not have a
problem in terms of requiring an aging management program
for these. However, on a plant-specific basis, as we go
through, as applications come in, some of these may pop up
in scope and perhaps require an aging management program.
CHAIRMAN BONACA: Okay.
MR. SHEMANSKI: Oconee is located up in a
mountainous area.
CHAIRMAN BONACA: No, I understand that. Just I
thought from the presentation that it was a generic
exclusion, which you are telling me it is not.
MR. SHEMANSKI: Right.
CHAIRMAN BONACA: I mean there will still be
operating experience, for example, the particular site and
that will point out whether or not there is some activity,
some review that has to be done.
MR. SHEMANSKI: Right.
CHAIRMAN BONACA: Okay. Thank you.
MR. MITRA: Number 3 is inclusion and recognition
of industry reports useful for aging management. Staff
concurred with NEI to add following industry documents to
the reference of Chapter XI: Sandia 96-0344, Aging
Management Guidelines for Commercial Nuclear Plants.
Electrical Cable and Terminations is September 1996, and
EPRI PR-109619, The Guidelines for the Management of Adverse
Localized Equipment Environments, which is published in June
1996.
The last comments was separation of discussion of
aging management program, non-EQ, and time-limited aging
analysis for EQ. It used to be addressed in one place
before the staff and NEI mutually agreed to separate EQ and
non-EQ components to prevent confusion. EQ electric
equipment are addressed as TLAA based on 10 CFR 50.49, the
aging management program in Chapter VI-B and X E-1, and
non-EQ electrical cables and connections are subject to
specific aging management program are addressed in Chapter
VI-A and XI E-1, E-2, E-3 and E-4.
Any question on industry comments?
[No response.]
MR. MITRA: We have our three license renewal
issues, 98-077, which is table consistent with the rule.
There is 89, intended function of regulation, and 97 is
system, where it says component level functions. These
issues are resolved on the basis that they are obsolete.
The NEI comments were that the table is in the previous
version of GALL, is taken from IPEEE 1205, Aging Assessment
of Class 1-E equipment, and it was mainly focused on aging
mechanism, but the license renewal rule not focuses the
effect of aging on structures on components. Therefore, the
tables are removed, so these issues are resolved.
That is all we have.
CHAIRMAN BONACA: Any other questions?
DR. SEALE: I assume that there is some
communication of the utility of these fault detecting
measurements that were used at Oconee -- or at Davis-Besse
with the rest of the industry. It strikes me that that is
pretty cheap, I would think, and something that might be
very useful to other people.
MR. VORA: I think you are absolutely right, Dr.
Seale. Both Paul Shemanski and myself, we are members of
the working group of the IPEEE subcommittees and working
group, both on the aging management and also with regards to
the operations, maintenance and surveillance of the
electrical equipment. And through that avenue, we are able
to disseminate the discussions and results.
And, also, we also had the morning report we
issued, we talk about the results of this effect. We also,
when we have our telephone conversation with the licensees,
that is one thing we didn't create, that once the report is
out, it should be widely distributed and available so we all
can learn from that experience and move on to the next step.
So I think it is a very good comment.
DR. SEALE: The only thing now, it would be nice
to know how good a predictor it is. That is, how much of an
early heads-up you get. Of course, it depends on the size
of the leak.
MR. VORA: Yes, sir. And I think what they did
actually, if I remember right, they used the double power
factor which is commercially available equipment, and they
did the partial discharge to that, and they are able to make
a correlationship in the value of the last factor and the
partial discharge. And then when actually they removed it
and they took these sets of cables into the laboratory and
they did some dissections and post-mortum examination and
testing. So I think they have a good collection of data.
And during our conversation, they did agree that
they would like to discuss this widely through probably the
course and standards activities. So it is happening, and I
think we are pleased with that result.
DR. SEALE: Actually, it has nothing to say here,
but INPO publishes some sort of things about -- we get
copies of that manual or that publication they put out about
every quarter, I guess it is, on things like that,
decontamination practices, other things, too. It strikes me
this would be the kind of thing that might be very useful in
propagating that experience.
MR. VORA: I think you are absolutely right. And
I think we got a couple of points on it, and we thought we
might be able to obtain some more data from the other
components. Even if they did not find any anomalies in
other two sets of cables, even that data itself was also
useful.
DR. SEALE: Sure.
MR. VORA: To put everything together in a package
for the future use.
CHAIRMAN BONACA: Okay. Thank you very much.
MR. MITRA: Thank you.
MR. GRIMES: Would you like to proceed with the
auxiliary systems discussion?
CHAIRMAN BONACA: I think so. I think we should
probably complete this presentation and then take a break at
that time.
MS. BLOOMER: Chuck.
[Pause.]
MS. BLOOMER: Hi. I'm Tamara Bloomer. I'm a
materials engineer in NMSS, Division of High Level Waste,
who for the summer was on rotation to license renewal. I
was charged with being the lead for auxiliary systems, which
is Chapter VII of GALL and associated section of the SRP.
Similarly to what Ronnie went through, I'm just
going to give you a brief overview of some of the major
changes that occurred between the '99 version and the 2000
version of GALL before I get started on the overheads.
In Section C(3), the cooling tower structural
elements were removed. They are incorporated in Chapter 3
of the GALL report. For consistency's sake, we found that
we were addressing them, looking from different angles, when
we put them in structures and how they're all going to be
dealt with the same way.
In Section E(4) -- actually, all of Section E(4)
was removed. The situation was the refueling water tower --
excuse me, the refueling water tank was moved to Chapter 5,
and with the removal of stainless steel items and
fluoridated water, and the carbon steel items moved to the
new additional section that was added, and bolting being
moved to that section, which is now Section I as well, there
was nothing left in Section E(4), and so that was removed
completely. So the E(4) you have now was previously E(5).
Liquid waste disposal system, which was the I,
Section I of Chapter VII, was removed. Liquid waste
disposal is not in scope, and due to the decision on the
hatch, 2.206 petition that was brought by the Union of
Concerned Scientists and the disposition of that petition,
we felt that it was best just to remove it from GALL as a
reference. Section I now is, in fact, the carbon steel
components section that was universally added in the
chapters for GALL.
A lot of other items changed that will change the
look of Chapter VII. Chapter VII originally was very large.
It is still a larger section, but it has decreased by almost
half, by moving a lot of the things into Chapter XI,
similarly changing a lot of the terminologies and the
consistency of terms -- things like the studs and nuts are
now closure bolts, so rather than having line items for
each, we have a line item that encompasses. That changes
the way the chapter looks itself. Also, filter housings
were added to Section F(1), F(2) and (3), which came from
Chapter V. There were other small changes that you can see,
but those are really the major ones.
Again, Chapter VII was a very large section. It
encompassed easily 45 pages of NEI comments. We had a large
number of staff involved in reviewing their comments, as
well as GALL itself, Chapter VII. There are four people
here, but there were over thirty reviewers from NRC staff.
Three of the reviewers here, you have already met, and I
will allow --
MR. TAM: Shin-Wing Tam from Argonne National
Laboratory.
MS. BLOOMER: -- were involved. The ones that I
have left -- in fact, some have been touched upon earlier
today. I'll just go over them briefly, and if you have any
questions.
The spent fool -- excuse me. Whoa.
[Laughter.]
MS. BLOOMER: The spent fuel pool cooling and
clean-up corrosion. NEI felt that the water chemistry
alone, again, would, is used to mitigate corrosion. And
therefore, a "no" in the "further evaluation" column and a
no need for one-time inspection was required. We have left
the water chemistry program that is referenced in Chapter
XI, and the use of a one-time inspection as a possible
alternative to, to look for corrosion.
The buried piping is an aging management program
that is now also in Chapter XI. NEI felt that buried piping
is treated differently in each plant and should be listed as
a plant-specific activity. We have incorporated a buried
piping AMP in Chapter XI, based on a NACE program --
National Association for Corrosion Engineers -- which uses
coating, wrapping, and cathodic protection, and feel that if
that is followed, this is something that has been reviewed
by the staff and is an appropriate AMP. There are other
alternatives, but they would be reviewed on a plant-by-plant
basis if they choose not to use this.
In the aging mechanisms for bolts, across Chapter
VII, it countered wear as one of those aging mechanisms.
Wear is not considered an aging mechanism in the internals,
and that should be the harshest determination of where aging
mechanisms occur. If it's not considered relevant there, we
felt that we should remove it from the rest of Chapter VII.
Boric acid corrosion parameters monitored. NEI
felt that the statement that we originally had in the '99
version of, "one or move studs are removed and examined for
evidence of boric acid corrosion," was too proscriptive.
And we have, in the boric acid corrosion program in Chapter
XI, clarified that and request a removal and examination
only upon evidence of leaking -- not necessarily evidence of
leaking at that bolt, but evidence of leaking in the area
for which the bolts would be susceptible.
The stand-by liquid control, which is a boiling
water reactor system, has sodium pentaborate as one of the
elements involved in the water. And we have found that
stress corrosion cracking is an issue. NEI felt that the
level of sodium pentaborate that is used in most of the
plants is insufficient to create this aging mechanism. But
we have, in fact, retained reference to that in the
evaluation and technical basis column, and say that sodium
pentaborate does have a susceptibility or decrease the
susceptibility for stainless steels to set up stress
corrosion cracking and therefore should be managed.
The diesel fuel oil system coating degradation.
NEI felt that failure of coatings was, does not result in a
lost of component function. Therefore, coatings should not
be managed. We have added an outer surface of above-ground
carbon steel tanks AMP to Chapter XI, which we require
inspection of the paint, coating, sealing, and caulking, and
possibly a one-time thickness measurement of the tank
bottoms inaccessible areas, so that you can see whether or
not any degradation is occurring in fact.
CHAIRMAN BONACA: You said there is one-time?
MS. BLOOMER: It's not listed specifically as a
one-time inspection in that program, but if we do a one-time
measurement and find that there is no decrease in thickness,
then we're not going to require anything further beyond that
point. If they in fact find that there is some corrosion
occurring, then of course a whole other set of plans come
into requirement.
Lastly, stress corrosion cracking of stainless
steel below 140^o F -- we have an operating experience
associated with an Information Notice 97-019 on safety
injection system weld flaw at Sequoia Nuclear Power Plant,
in which pipings had through-all cracking due to stress
corrosion and were used in environments less than 140^o C.
NEI felt that that was a site-specific evaluation, that it
is not a generic issue, and for stainless steel, we feel
that that may be a correct assumption and have therefore
removed that item, currently, from GALL.
The only license renewal issue that was relevant
to Chapter VII --
DR. SHACK: Just --
MS. BLOOMER: Yes?
DR. SHACK: Are those all controlled water
chemistry systems?
MS. BLOOMER: Are, which?
DR. SHACK: Where you've removed the stress
corrosion cracking of the stainless steel?
MS. BLOOMER: This is stress corrosion cracking at
less than 140^o.
DR. SHACK: Right.
MS. BLOOMER: Anything above that is still a
situation.
DR. SHACK: But are those all situations where the
water chemistry is controlled?
MS. BLOOMER: I'm not sure if that is an
exclusionary --
MS. PARCZEWSKI: Yes. The water chemistry is
controlled in this instance.
MS. BLOOMER: In all the systems that we use?
MS. PARCZEWSKI: Yes.
DR. SHACK: Because you can certainly get stress
corrosion cracking with stainless steel at 140^o F in the
wrong chemistries.
MS. BLOOMER: Again, that would probably be more
of a plant-specific basis, if the environment was different
than what a generic environment is going to be, and so it
wouldn't appear in GALL. It would be evaluated by the staff
in an application as plant-specific.
DR. SHACK: Well, one always gets concerned in
stagnant water systems.
MS. BLOOMER: Yes.
DR. SHACK: I mean, one has water chemistry and
one has water chemistry.
MS. BLOOMER: Correct. Correct, and there are
some instances of that that we had great debate with NEI
over, in GALL, where we felt that the water chemistry, other
than the borated water, other water chemistries may not be
sufficient in stagnant conditions to alleviate all types of
corrosion, including --
DR. SHACK: I mean, your borated one was general
corrosion, and I'm willing to grant you that the general
corrosion of stainless steel is not, not going to concern
me.
MS. BLOOMER: As well as [inaudible] borated
systems, borated water systems.
DR. SHACK: But the stress corrosion cracking's a
different beast.
MS. BLOOMER: And we do have stress corrosion
cracking in a number of areas in Chapter VII that have
maintained. Okay.
The license renewal issue that we find for Chapter
VII is failure detection that was brought up for the SRP in
'97. And it was based on the BG&E application and the use
of failure detection as an AMP. It was an open issue. We
felt that the program, the water-based fire protection
program in Chapter XI closes this issue -- that and the use
of the fire protection program with further evaluation for
specific systems is sufficient and removes the failure
detection limitation they saw.
And again, an item of interest that came up is the
water-based fire protection aging management program. The
ones that we have seen, we feel need further evaluation. We
have proposed possible other alternatives they can look at.
They are basing -- "they" being the plants that have come in
-- Conee as well as Hatch, and ANO are basing their fire
protection programs on guidance by NFPA. The staff feels
that NFPA alone is not necessarily sufficient unless they
agree to use specifics in NFPA. NFPA 13, NFPA 25 -- 25 is a
one-time inspection for sprinkler heads at or before 50
years. And that would be applicable to the extended period
for license renewal.
Similarly, we feel that internal visual
inspections are not sufficient for fire protection,
especially for wet fire, wet systems, and that you do need
interior inspections, either by ultrasonic or radiographic
or, in case of removal of a piece to inspect it and make
sure that the piping is not being corroding or there is not
[inaudible] involved.
We have listed -- these are not necessarily new
requirements that we've put in GALL. They are requirements
that came from the experience of working with the other
licenses.
DR. SEALE: Well, I'm sure our chairman would
point out that fire protection is in the category of "what
have you done for me lately?" --
MS. BLOOMER: Yes.
DR. SEALE: -- kind of thing. And so it deserves
some tender loving care from people who are a little bit
more objective, if you will, than merely being guided by
the, the simple comment. So I think everything you can do
to not let the fire protection program sort of slip away.
MS. BLOOMER: No.
DR. SEALE: That's very important.
MS. BLOOMER: GALL being a living document, NFPA
has comprised a task force to see what kind of aging
programs -- because aging was not something that they were
really looking at prior to this, and they're trying to
develop some aging programs that may be useful, not only for
the nuclear industry, but for a variety of industries. And
once that is determined and after the staff has reviewed it
and if we find it appropriate, that is something that may in
fact find its way into GALL as well.
DR. SEALE: Okay.
MS. BLOOMER: Are there any other questions at
this time?
CHAIRMAN BONACA: Thank you very much.
SPEAKER: We have one more section on steam and
power conversion.
CHAIRMAN BONACA: Yeah. I would propose that we
just complete that, and then we take a break.
MR. STRNISHA: I'm Jim Strnisha. I'm the lead
reviewer for steam and power conversion systems, and the
reviewers here with me -- you've met a couple of them, but
to my far left is George Georgiev, Department of
Engineering; Kris Parczewski from Division of Engineering;
Jim Davis, Division of Engineering; Omesh Chopra, Argonne
National Laboratory.
I'd like to start off first with the major changes
between GALL, the 12/99 version, and the current August
version.
The first part would be similar to what was
changed in Chapter V and Chapter VII. In there, we added
Section VIII, External Surfaces of Carbon Steel Components,
and we added Closure Bolting. And for External Surfaces of
Carbon Steel Components, Boric Acid Corrosion Program was
added. And that is in Chapter XI M-5. And we also added
the Coating Program, which is Chapter XI S-8. And for the
Closure Bolting, the Bolting Integrity Program in Chapter XI
M-12 was also added.
And one other re-format change that we made, which
is generic for all the other chapters, is the aging
management programs that were in the technical evaluation
block were moved to Chapter XI. Examples of those were the
water chemistry Program, Chapter XI M-11; the Flow
Accelerated Corrosion Program, Chapter XI, M-6; and the
Bolting Integrity Program. So you'll find those back in
Chapter XI. Any questions?
[No Response.]
MR. STRNISHA: Okay. n my overhead slide here --
two of the major issues here that are bulleted, one NEI
comment was, "one-time inspections are not needed with the
water chemistry program." The staff position on this is,
for superheated steam piping where corrosion is negligible,
the inspection is not needed. And on piping other than
superheated steam, where corrosion is a concern, the
inspection is invoked in that section.
DR. UHRIG: You're really talking about the B&W
plants with the superheat?
MR. CHOPRA: Um hmm.
DR. UHRIG: Those are the only ones that have
superheat.
MR. STRNISHA: Okay. Thank you. The other line,
the other NEI comment, "flow accelerated corrosion is
negligible for superheated steamlines." The staff agrees
with that. The reason I'm bringing it up though is, the
staff position is to leave superheated steamlines in the FAC
program, since the program conducts an analysis to determine
which piping is most susceptible to FAC. This approach
allows the program to evaluate and select piping to be
monitored. And that's the reason we're gonna leave that in.
DR. SHACK: I mean, is that true now for operating
plants that go -- I mean, they all have flow-assisted
corrosion programs. Is that piping in the FAC program now,
and they go through the analysis?
MR. STRNISHA: I believe it is.
MS. PARCZEWSKI: Yes. Actually, if it is
superheated steam, there would be no FAC. But however, if
all the other pipe, like construction pipe, there might be
some moisture present. So obviously, it does [inaudible] to
be included in the program. And we don't know exactly which
pipe carry pure, in the system pure superheated steam.
That's -- some of the include, as I say, safety precautions.
DR. SHACK: Okay, but then the plant makes a
specific analysis of its piping.
MS. PARCZEWSKI: Yeah, that's right.
DR. SHACK: As part of the FAC program.
MS. PARCZEWSKI: That's right. It's a part of the
FAC program.
MR. STRNISHA: As far as license renewal issues
and items of interest go, in this chapter we have none. So
that's the only slide that I have.
DR. SEALE: I might suggest to my colleagues that
as we look at an entirely different issue -- namely, the
consequence of various power upgrade proposals that people
are going to be coming forward with -- this is an area where
we ought to be very careful. You just reminded us.
[Laughter.]
CHAIRMAN BONACA: Okay. Any other comments or
questions?
DR. SHACK: Well, I just noticed in the actual
aging management program for FAC, you note that one means of
mitigation is to adjust the oxygen concentration. But
everybody carefully dances away from specific numbers. Is
that all -- it goes into your FAC program, and then it sort
of gets screened out at that point?
MR. PARCZEWSKI: Usually the FAC's reduced their
concentration [inaudible] concentration is about 40 ppb.
This is a number from EPRI program.
DR. SHACK: No -- I'd certainly buy that.
MS. PARCZEWSKI: Obviously, it's very difficult to
maintain in some cases. I understand, it's my
understanding, he did some of the plant, even they keep
adding oxygen, you know, to the -- keep them to the
[inaudible].
DR. SHACK: Well, and the Germans make a career
out of adding oxygen to water, to eliminate flow-assisted
corrosion. It's a bit trickier in nuclear reactors.
MS. PARCZEWSKI: After removing oxygen by hydrogen
you have different chemistry.
DR. SHACK: Right. Well, sometimes it's good to
remove it; sometimes it's bad.
[Laughter.]
CHAIRMAN BONACA: Okay. There are no further
questions. I thank you for the presentation. And we will
take a break, 15 minutes. We will resume the meeting at 25
of 11.
[Recess.]
DR. LEE: I'm going to describe the Reg Guide we
issued. Back in 1996, we usually draw up Reg Guide to
propose to endorse NEI Guidance document 95-10, Revision 0.
Since 1996, we have considerably developed the
implementation for license renewal. We have reviewed the
applications. We have reviewed topical reports, and then we
have to tackle the system program Gall & SRP. So since
then, the -- we got additional experience, and NEI has
revised 95-10. And the current revision is revision 2. So
in the draft Reg Guide, 1104, that we issued in office 2000,
we proposed to endorse revision 2.
Okay, right now, we are proposing to endorse
revision 2 with no exceptions. We realize that there might
still be inconsistencies between the Board, the SRP, and
95-10 because GALL & SRP were evolving when we were working
it through the office. And NEI was working on 95-10
separately. But NEI is expected to make conforming changes
to make it consistent. Okay. Unless there's other
questions, otherwise, I have NEI discuss 95-10.
CHAIRMAN BONACA: Any questions from the members?
DR. LEE: Yeah, I thought that in the review that
GSRP and the NEI document interfaced well. And clearly they
have different purposes, but they overlapped. We retrapped
all our raw materials from each other.
DR. SEALE: Truly complementary.
CHAIRMAN BONACA: Alright so we have now the NEI.
DR. SHACK: You passed.
MR. WALTERS: Good morning. I did, indeed. Well,
at least I hope I did. You got the light on. We just had a
license renewal workshop in Florida, and one of the benefits
is that you get to use presentations from that here. So
it's quite a time saver.
DR. SEALE: You mean you're telling them the same
story you're telling us.
MR. WALTERS: Told them the same thing. My name
is Doug Walters. I'm with NEI. I have responsibility for
renewal. It's a pleasure to be here today and talk to you
about NEI 95-10, which is our guidance document for
implementing the requirements of Tensia, Part 54.
Before I get into the remarks, I will just make a
couple of observations. First of all, I -- sitting in the
audience and listening to the staff's presentations, I want
to compliment them for the hard work that they put in on
developing GALL and the SRP, because we believe that if you
look at the significant events that have occurred over the
last year, certainly the top one is the fact that we had two
license renewal applications submitted and approved, and we
have three others under review. But second to that would be
these documents because they are extremely important to
furthering the stability, predictability, and efficiency of
the process that we think we need when we look into the out
years and the number of applications that are expected to be
submitted.
Also, I just wanted to make a comment about some
of what I heard, maybe to put in perspective our comments.
What we are concerned about when it comes to GALL, and I'm
at a very high level here, is that we ought to be capturing
lessons learned. And what we found acceptable on the first
two applications. And our concern is that GALL can become a
document that's a wish list. We'd like you to do X, Y, and
Z. And we looked very carefully when the GALL said further
evaluation required to see if there was a basis for why some
addition or enhancement to the program was needed. And
that's really what our comments focused on.
One-time inspections are not aging management
programs, by the way. I know you're aware of that, but the
purpose of the rule is to have aging management programs in
place to ensure functionality. And one-time inspections, as
an example, are not aging management programs. We don't
object to those necessarily, but that's where we're coming
from when we looked at GALL.
But I'm here today to talk about our guidance
document. It was actually developed back in '95, hence the
95-10 number. We have within NEI a license renewal task
force and a working group. They were the principal
overseers, if you will, of the document. It was actually
written by the task force, and it provides guidance to
whoever wants to use it for preparing or implementing the
requirements of the rule.
I'm going to go through the table of contents real
quickly. We start off with an introduction, then an
overview of Part 54. Then we get into the scoping process,
which is in Chapter 3, and I'm going to go through these in
a little more detail in a second. And then Chapter 4
provides guidance on preparing the IPA. In Chapter 5, we
address time limited aging analyses. And in Chapter 6, the
-- we have the -- the title of the chapter is "Renewal
Operating License," but this is where -- excuse me -- we
have incorporated the -- what we call the standard license
renewal application format. We met with the staff, I
believe it was earlier this year, and, again, using the --
principally the SERs that were written for Calvert and
Oconee and came up with a -- what we thought was a standard
application format. It's helpful for us because we know
where to put the information. After all, the application
really is a packaging issue. And it's also, we hope,
beneficial for the staff because they know how to parse it
out based on that format. And I'll talk a little bit more
about that.
Appendix A is merely a copy of the rule and the
statements of consideration. And then Appendix B is a list
that I will show you one page from of some groupings where
we've made some determination about whether the grouping or
the component group is active or passive.
Section One, as I indicated, is an introduction.
It merely goes through the other sections of the guidance
document. It talks about Section 3.1, et cetera, et cetera.
But as an overview, it talks about the guidance as being an
acceptable method for implementing the rule. We talk about
the basis for the guidance. In other words, we looked at
operating experience. We looked at the maintenance rule.
In this case, where we are today, we looked at GALL. We
looked at SRP. And we believe that, and I should say the
objective of the guidance obviously is that if you follow
it, you'll be successful. You'll get a renewed license.
It's not to say it's the only method. We always have that
caveat. But, as you saw, the intention is that this would
be endorsed by the Reg Guide.
The major elements of this section, again, it
outlines the subsequent sections. 3.1 is scoping. 3.2 is
identifying functions. We talk about Section 4, which is
really the IPA and the others as well.
You know, Section 4 is where you really get into
the demonstration. You've heard that terminology. How do
you demonstrate that the aging in adequately managed. It
talks a little bit about Section 5, which is the TLEAs and
how you dispose of those. And then it guides you to Chapter
6, which is the standard application format.
We have some other information in the introduction
and that's how you can utilize existing programs. And we
provide a little bit of guidance about using the maintenance
rule, for example -- well, strike that. It suggests that
you look at the scoping you did for the maintenance rule as
a starting point perhaps for license renewal. It also
recognizes GALL and the SRP and suggests to the user that
you need to look at those documents. But there is some
other information in there. And there's clarifications,
like the two over one issue that I have on the last bullet
there. Maintenance rule excludes structures based solely on
the seismic two over one. We don't do that. That's not an
exclusion that's allowed under renewal.
We also talk about resolution of GSIs. We point
that there are a number of ways that, if the GSI is
applicable, if you will, to renewal, that it can be
resolved. One is if you've submitted the application, and
you've addressed the GSI, but that GSI gets resolved before
your renewed license is issued, you could incorporate that
resolution. You can do a plan-specific evaluation to show
that the CLB can be extended beyond the end of the current
term until some further point in time. You could chose to
implement an aging management program to address the issue.
And example of that would be fatigue. You know, that's GSI,
but you can deal with that through an aging management
program or you could amend the CLB and basically take the
issue off the table.
Chapter 2 is merely a reference back to Appendix
A, which has the rule and the statements of consideration.
In Chapter 3, we get into scoping. We use --
well, the scoping requirements are spelled out in the rule.
We use the definition of safety related that's in 5049.
You've probably seen that before. Nothing new there. You
also have to scope in non-safety related -- SSEs, whose
failure could prevent a safety-related SSE, excuse me, from
fulfilling its function. And, again, that's I think fairly
consistent with what we've seen in the past.
The third requirement is regulated events. Fire
protection. EQ. PTS. Atlas. Station blackout. And you
go back and basically look at your documentation for each of
those regulations, if you will, and determine what you need
to deal with those events and those become part of the scope
of the rule.
We provide in the guidance, and this is also in
the SRP, a list of potential information sources. We do
have a disagreement with the staff on the use of PRA in this
area. But to us, this is a list of potential sources, and
quite frankly, I don't see that as a big issue from a
process standpoint. But we do have this list of information
sources that we suggest licensees consult when they do their
scoping process.
We also talk in Section 3--
CHAIRMAN BONACA: With regard to the list. You
know, I raised the question yesterday. The corresponding
list of the -- in the SRP has the EOPs as a possible source
of information. And, as you know, the EOPs also are a basis
in the maintenance rule.
MR. WALTERS: Right.
CHAIRMAN BONACA: And this list doesn't have any
reference to the EOPs.
MR. WALTERS: Right.
CHAIRMAN BONACA: Is it intentional?
MR. WALTERS: I'm sorry, is it intentional?
CHAIRMAN BONACA: Is it intentional, yeah.
MR. WALTERS: I don't know whether we actually
considered that when we initially developed the list. I
don't believe it belongs on the list, quite frankly. That
scoping criterion under the maintenance rule obviously is
not in license renewal. That's not to say though that the
equipment, and I think we have looked at this, by the way --
that's not to say that the equipment that scopes in under
the maintenance rule, under that criterion, doesn't get in
under license renewal. It just comes in perhaps under one
of the other scoping criteria.
CHAIRMAN BONACA: Yeah, I just--
DR. SEALE: Yeah, but in general, even with PRA,
PRA is on the docket, right?
MR. WALTERS: That's correct.
DR. SEALE: It seems to me that you have to be
sensitive to everything that's on the docket when you do a
license renewal.
MR. WALTERS: Yeah, no question.
DR. SEALE: So in essence, anything that's on the
document is -- maybe in finer print or fainter print on that
list, but it's a candidate.
MR. WALTERS: Yeah, it -- you could add. Yes, you
could put it on the list as an information source. But
whether the equipment would scope in or not would be
determined by the other scoping criteria.
DR. SEALE: Yes, very definitely.
MR. WALTERS: So, yeah, it could be on the list.
CHAIRMAN BONACA: I recognize that the license
renewal explicitly does not mention the EOPs, explicitly
mentions them. It mentions for equipment, which is not
safety-related. They say, however, that you will include
whatever is in the EOPs. And that's because the EOPs really
are a part of the licensing basis, if they're referenced in
the FSAR. I was thinking that there may be some peculiar
situation where you could have a -- you know, a component
for which the active element is being, in fact, under the
maintenance rule, monitored under the maintenance rule and
the passive components are ignored because the license
renewal doesn't look at them, okay. So that -- and I just
-- and I don't think it's a major issue. Most likely, most
components are -- but it seems to be some inconsistency
between the two rules.
MR. WALTERS: There is clearly an inconsistency.
CHAIRMAN BONACA: And I wanted to ask you your
perspective of that.
MR. WALTERS: Okay. We -- in Section 3, after you
do the scoping on the safety-related non-safety and the
regulated events, you look at the intended function, and at
this point, you could, according to our guidance, you could
look at this at a system level, even though the rule goes to
a structure and component level. You're going to see this
again when I get into Chapter 4.
You need to document the scoping process, and we
provide some guidance on how you do that. And, you know, we
do get into the information sources, and so I don't want to
leave you, based on your comment with the impression that
the items on the list are the only things that would be
looked at. Dr. Seale is very correct. You would be prudent
to look beyond.
Okay, the -- Chapter 4 talks about the IPA, and
this is where we get down into the -- we take what we
learned in Chapter 3, which is the scoping and the -- you
know, the big part of the bin, and now we're going to
identify what's subject to an aging management review. I
apologize that this is not clearer in your handout. That
was not intentional. But -- and this is fairly
straightforward, and you're familiar with the rule. Again,
here is the -- what you did in Chapter 3, then you go into
asking yourselves some questions about that bigger bin. You
say, well, let me pull out the stuff that's passive. If it
is passive, do I replace it periodically. If I do, then it
screens out, if you will. If it's not, then do I need an
aging management program--yes or no. If I do, then I move
over and I look at what programs I might have that manage
the aging. This, by the way, is obviously where GALL will
play an important role. The box that says demonstrate -- we
have guidance that suggests typical attributes of an aging
management program. Those have been adopted by the staff,
and you'll see those in the GALL report, the ten attributes.
I would just caution that, at least our position is, not all
ten attributes have to be satisfied in order for the program
to adequately manage aging. But that's -- this is where
GALL plays an important role, and we intend to rely on it.
Again, in Chapter 4, because we're now down at the
component and structure level, we've got another table,
4.1-1 that identifies typical intended functions for
components and structures. And, again, I think this -- you
should see the consistency between this and what's in GALL.
The next section in our guidance talks about the
aging management reviews. Again, you can make a dent --
what we provide are I think three methods to manage aging on
a -- or -- let me start over with that -- there are three
ways to disposition, if you will, the aging of a -- on a
structure or a component. One is you can to the
demonstration, which is you look at the aging effects and
you identify a program and you demonstrate that those aging
effects or that aging effect is managed by the program.
The other way to deal with aging management is to
reference a previous review. So if -- you know, if there's
a topical report, for example, that would be a way to make
the demonstration required by renewal. We also have a
guidance in 95-10 that talks about performance and condition
monitoring, which is -- it's discussed in the SOC. But you
need to do a plan-specific justification if you want to take
credit for performance and condition monitoring. And the
point is that -- at least what's concluded in the statements
of consideration is that the condition monitoring only looks
at the active piece of the component, and so there was no
generic conclusion that performance and condition monitoring
would necessarily reveal the aging effects on the passive
component. And so you've got to make that argument in the
application.
We recognize that in some cases, you may want to
do an inspection and so we provide some guidance in that
regard. We talk -- we very briefly provide guidance on what
a program, an inspection program should look like. We talk
about the fact that it needs to have a purpose that's tied
to the aging, if you will. You need to have a -- some
statement about the scope of the inspection, the method of
the inspection. How you're going to analyze the results,
and your corrective and follow-up actions. We also provide
guidance on sampling, population, sample size, and the
timing of the inspections.
Chapter 5 talks about TLAAs. Again, the I think
the important thing in this guidance is individuals or
licensees that use this to prepare a renewal application
need to know that a TLAA needs to satisfy all six criteria
that are delineated in the rule. And those are just listed
here.
We provided a table, 5.1-2, of potential TLAAs.
This is going to change I believe because of the GALL and
SRP. But these are some things that we came up with. You
may have seen a similar in the SRP.
Then we talk a little bit about how you can
resolve or address TLAAs. These are the options afforded us
in the rule. You can certainly verify that the TLAA, as it
is today, is valid for the period of extended operation.
You can take that TLAA, and project it to the period of
extended operation. Actually, I think I and II are pretty
similar. You can also address the TLAA through an aging
management program. You also, under this -- let me say,
under this guidance, we also provide some guidance on how
you addressed exemptions that you may have taken over time.
Lastly, we have Chapter 6, which, again, is the
standard application format. And the -- under the bullet
that says application format and content, that is the
standard format that we've come to agreement with with the
staff. I don't -- I think that's working fairly well. ANO
has used it. Turkey Point has used it, and we may have to
do some tweaking to it over time based on, you know, changes
to the GALL and the SRP. But, for the most part, it works
fairly well. We also in this section provide, excuse me,
provide guidance on the requirement that you need to update
your application and how you can go about doing that--fairly
straightforward stuff. I think, do we have copies of this?
I wanted to show you -- I mentioned at the outset
-- let me just -- this is the table of contents and Appendix
B. This is just a sample page from Appendix B. And I
apologize. I didn't have it in the package. But what this
shows is a listing of -- we call them structure component or
commodity groups, and whether the group is passive. And if
the answer is yes, like you see on reactor coolant pumps, we
say, yes, and it's the casing, then that's in the scope of
the rule. Or it requires an aging management review, more
precisely. But if the answer is no, and that fact that this
-- our document is going to be endorsed by the Reg Guide, we
can rely on this list as a tool. And that's very important,
and we were glad that we were able to reach agreement on
this with the staff.
Just in closing, I -- we do need to make some
conforming changes to NEI 95-10. I don't have those
identified today, but our guidance I believe will probably
the last document that gets updated. We need to see what
the final GALL and SRP looks like, and we will have some
conforming changes to make. But we do intend to do that and
in the time frame to support the staff's schedule to
finalize those documents.
DR. UHRIG: Would that be considered a Rev. 3?
MR. WALTERS: Yes. We will update it to Rev. 3.
CHAIRMAN BONACA: Yesterday, we posed to the staff
a question regarding scoping.
MR. WALTERS: Yep.
CHAIRMAN BONACA: The feeling at least some
members have that is still not very clear process. It's a
very -- you know, it's a time consuming process. A lot of
sources are being looked at. Is your judgement that
anything can be done to make it more -- to facilitate
providing additional guidance, or do you think that whatever
has been provided by now in the NEI document and the SRP is
a much as can be provided?
MR. WALTERS: Well, I believe that there are
certain areas where it could be streamlined, or less
cumbersome, perhaps. And I still don't understand, myself
personally, I don't understand why we can't just lift from
the maintenance rule scope, the safety related items and put
them the license renewal scope. And my comment is not only
that I -- that I see a - not a reluctance, but I'm not sure
within the staff we've figured that out, but even within the
utilities, they don't seem to have figured out how to do
that. And I quite frankly am perplexed by that.
So I think that's one area where we could, in
terms of scoping, we could make some real headway, if we
could come to agreement on those two scoping criteria.
CHAIRMAN BONACA: That would be a different
approach. But, still, you're saying it's an established one
and probably will lead to the--
MR. WALTERS: And it's inspected. It's -- but,
you know, plants have -- you know different vintage plants
have different ways of -- some have Q-lists. Some don't, so
I'm not sure that we can do much more. We'd certainly be
interested in -- you know, in looking at that. But--
DR. SEALE: You made a comment earlier about your
concern that the GALL report and the other documents didn't
become a wish list.
MR. WALTERS: Right.
DR. SEALE: And I think that's a very valid one.
I think the extent to which the staff has been able to work
with you and come to the kind of agreement that
characterizes the presentation you just made is -- indicates
that there isn't a dedication, if you will, to turning this
into a wish list. At the same time, I think the staff, very
rightly, feels that Calvert Cliffs and Oconee are not
everything. And in particular, there are about four
versions of different kinds of containments on water
boilers, and I think containment is one area for water
boilers where aging effects might have some significance
over the long haul. They want to look at it and kick the
tires for a while before they convince themselves that
they've got a complete product. And I think you do, too.
MR. WALTERS: I would agree with that.
DR. SEALE: And so I think meeting your or getting
your desired result of a non-wish list dominated process is
a two-way street. And so far, you've been able to do that
very well, and I think very efficiently. I think all of us
have been impressed with the fact that you got five plants
now that have gotten their renewals. And, but there's a lot
more work to be done.
MR. WALTERS: Yeah, I don't disagree with you, Dr.
Seale. It's a -- I think we've minimized the number of
wishes that are on that list. What I meant to say, though,
in all candor, is that when you talk to the people in the
field, and they say, well, but this is the program I've been
using for 12 years, and it was implemented specifically to
address -- I mean look at 89-13 just as an example. We
implement a program in response to generic letter 89-13 to
address fouling on heat exchangers. All of sudden, because
I want to do a renewal, I have to do something more. I'm
not suggesting that's what GALL says. That's an example, a
hypothetical example. And when you talk to the people in
the field, they say why do I need to do that. Why isn't
what I'm doing today good enough? They need that technical
understanding that if they're going to implement some new
action, there's some resulting benefit. And that's all I
was trying to get at. And that's a fine line; that's a very
fine line that we need to walk because, as you say, on the
other hand, we need to take a hard look at some of these
things, like containments. And in some cases, the -- what
the staff found, we agree with.
DR. SEALE: And there's some lessons learned?
MR. WALTERS: Yeah, no question.
DR. SEALE: For example, this technique for
checking out buried cables is something that everybody needs
to know.
MR. WALTERS: Sure.
DR. SEALE: I mean, it's an arrow in your quiver.
Whether you need it or not, you need to know about its
availability.
MR. WALTERS: We do. And there's no disagreement
with that. We just don't want renewal to be the
playground--
DR. SEALE: Sure.
MR. WALTERS: For that kind of, hey, why don't you
do this.
DR. SEALE: Yeah.
CHAIRMAN BONACA: One question we had yesterday to
the staff was regarding the fact that the GALL report
benefitted a lot from the first two applications. But there
are additional applications coming in, and there will be
more information that it will be helpful to the reviewers
and to the licensees to have somewhere what the experience
has brought in. For example, in many cases, we're pointing
out that when the guidance is you need more than what is
being done today, you go back into GALL and you find that --
thus specify what more means. There are not criteria. The
answer was, we don't have enough experience yet, because we
haven't had. Okay. So one question we asked of the staff
was, you know, are you planning to update the GALL report
frequently to reflect this additional information. We
didn't get any answer to that. I guess we're a little bit
ahead of time in asking those questions. Do you have any
insights on what -- you know a process by which the future
licensees can benefit from this information that I'm sure
Hatch will bring and other applications will bring? It will
not be documented in GALL.
MR. WALTERS: Well, yeah, that's a very good
question. I don't know what the staff said in terms of
whether GALL was intending, whether they were intending to
update GALL or not, but one of the things we're thinking
about, for example, is when the further evaluation is a
one-time inspection. Well, if five licensees do a one-time
inspection of the same thing, and I'll just use an example.
Supposed it's some buried commodity, and you could show that
your pH in the ground is the same as that utility over there
that did the inspection, and you had the same material and
the pipe was coated the same way, is there some way to
credit that inspection that was done by the first five
applicants, if I'm number 10. How are we going to do that?
I think we'll probably start some sort of library. We would
focus, I would think, on the enhancements or the additional
items you need to do. And then maybe at some point, it's
appropriate to go back to the staff and say, hey, we ought
to get this in GALL and update this.
CHAIRMAN BONACA: Well, the fact that the
presentation we had from the staff this morning they showed
that they, in some cases, they did exactly that. I mean,
when you pointed out that, you know, those are some
experiences that show that something--
MR. WALTERS: Right.
CHAIRMAN BONACA: Then they -- so. Yeah, okay.
But the important thing here is that -- you know, the
experience from this application is going to help out the
next people coming in and somehow they had to have open
communication of where that information fits.
MR. WALTERS: Yeah, one other thing that we might
do at NEI is we have a mechanism called an information
forum, where we can, and you've seen the charts with, you
know, the next 30 applications that are coming in. And
those individuals, those licensees are very interested in
getting involved in our working group and task force.
That's really not the right mechanism at this point. But we
might do is get those folks in what we call an information
forum, and meet with them maybe two or three times a year.
And if we do that, say, next year in the summer, we'll have
four applications that we have the benefit of learning from,
you know, with Oconee and Calvert, Hatch and ANO, plus we'll
have three others that have submitted, but we would be
looking more at the -- what was accepted and how did you
deal with certain issues. And we think that would be very
valuable for that next wave of applicants to have access to.
And we can do that through an information forum. So that's
another option that we have that we see.
CHAIRMAN BONACA: One observation we had when we
looked at the Oconee and Calvert Cliffs was that they spent
so much time being the first ones through the gate to look
at issues and so on as afford. I really concluded that they
were better plants because of the effort they made to look
at all the aging issues and management programs and so on
and so forth. I mean, clearly it was the depth of
understanding.
I guess the question I have is, you mentioned 30
plants coming in.
MR. WALTERS: Yep.
CHAIRMAN BONACA: There is more and more. You
know, looking at what somebody else did, and then somewhat
of a cookie-cutter approach, okay. You know, are we going
to lose some of the benefit because things are going to be
speed up and people are going to just simply copy
initiatives from other plants, or do you see still the
effort is such that the utility will get deep into these
issues rather than just making commitments based on what
somebody else did?
MR. WALTERS: The latter. We do believe that, and
we've had this discussion. Notwithstanding what's in GALL,
the obligation the applicant has is to still go look. It
just gives them a roadmap of where to go and what things
need to be looked at and what things don't. But, as an
example, if a -- even if a program is in GALL dispositioned
as not requiring further evaluation, if you read the SRP,
the application will merely say, I have that program and it
meets the attributes that were evaluated in GALL. But the
work that the licensee has to do to make that statement is
still the same work that -- I would argue is still the same
work that Calvert did, that Oconee did in looking at those
programs. They've got to make a certification. The benefit
to them is in the application they can just say I have the
program. But they still have to do this. We -- our
assessment is that the same amount of work has to be done,
but there are -- having said that there are some benefits.
I mean, you can go look at what somebody else did, and say
do I have -- you know, did I do it the same way. We have
some tools. We talk about tools that were developed by the
B&W owners group and we have tools that help us get through
that. But the digging you have to do and the assurance that
you -- or the demonstration -- let me say it that way that
you have to make is the same. The GALL helps us focus and
it gives us some benefit in what we put in the application,
but the work, at least in our discussions certainly the
applicants that will come in through 2002 is the same. And
I think they are better plants for that. There's no
question.
CHAIRMAN BONACA: One additional question we asked
yesterday was regarding something that probably we should
have asked you rather than the staff, which is the
commitment behind voluntary initiatives. As we spoke about
EOPs, we also spoke about severe accident management, which
is really a voluntary initiative. Now it was a voluntary
initiative, with the understanding that if it wasn't
voluntary, it would probably become, you know, part of the
licensing basis. So what's the perspective, from a
perspective of the industry. I mean, there isn't anything
in the documents that we have reviewed that says the
licensees will still commit to have, you know, committed
voluntary initiatives during the period of extended
operation. I mean, the question is, will these power plants
have a severe accident management in place, and will they be
able to implement those steps as they were in the first 40
years of operation?
MR. WALTERS: Well, certainly, there's no
requirement for them to do that, as you point out. But I
can't give you an industry position on that. But I would
say that I'd be surprised if those things just automatically
stopped after 40 years. I don't know what the implication
of those -- you mentioned the risk for severe accidents. I
don't know what the implications of that is if you go to--
DR. SEALE: Doesn't sound like a terribly wise
thing to do.
MR. WALTERS: Right. I mean, you know, it's--
CHAIRMAN BONACA: But what I'm saying, do you
think it would be wise to clarify the issue of voluntary
initiatives.
MR. WALTERS: In license renewal space?
CHAIRMAN BONACA: Yeah.
MR. WALTERS: No.
CHAIRMAN BONACA: Well, wouldn't you leave then a
number of issues that were negotiated in a certain way
hanging there?
MR. WALTERS: Well, let me maybe retract what I
just said. I don't think it's appropriate to address that
issue specifically in our guidance or in the SRP or in the
Reg Guide. I would say though that there may be some
voluntary initiatives that you credit in license renewal
space. Maybe, I don't know. But there could be it seems to
me. In which case those would carry their own kind of
commitment because they're credited in license renewal. But
if they're not, I don't see a reason that license renewal
should be dealing with voluntary initiatives.
CHAIRMAN BONACA: No, I'm not saying that you
should look at the additional commitments for those --
simply a statement that voluntary initiatives that were
considered important to safety and implemented over the
first 40 years of life should be maintained as we go into
the next 20. I mean, you know, there are severe accident
management guidelines which are intertwined with the EOPs
and the operator is trained on them routinely. And, you
know, when the question is hanging there, well, that's not
part of the core relicensing basis.
MR. WALTERS: Right.
CHAIRMAN BONACA: And, well--
MR. WALTERS: Well, I can't give you a
satisfactory answer. We've not really discussed that. But
kind of off the cuff, I would say that if we're concerned
about that, there are mechanisms that the staff has to make
them part of the CLB.
DR. GRIMES: I think -- This is Chris Grimes. I
think I'd like to jump in and provide staff perspective. I
think that our expectation in this area is relatively clear,
because in formulating the scope of license renewal and the
process, the statements of consideration for the rule say
that we expect the current licensing basis to carry forward
to the same extent and in the same manner as it is for the
existing license. And so, and we have recently endorsed
guidelines that have been developed on commitment
management, and we're in the process now of trying to
establish a process for crediting industry initiatives and
reflecting those in the regulatory framework. And so I
think that the Commission's expectation about the regulatory
process and how that in concert with a current licensing
basis that's going to continue in the same way that it
exists today I think that that is the process that we can
rely on. To say that if we see some indication of plant
performance or we see some safety concern about the plant's
readiness and capability to prevent or mitigate accidents
that we've got mechanisms to deal with particular questions
without having to cobble up something that might constitute
some confusion on doing things different after 40. So it's
-- we are constantly reminded that there's nothing magic
about year 40. You know, at year 39 and twelve months,
you're safe, and at year 41 -- or 40 and one month, you
suddenly become unsafe. There's no step change that we
expect to see.
CHAIRMAN BONACA: We heard many times that this is
not part of the CLB. This is not part of the CLB. This is
not part of the CLB. At times, I believe that clarity, you
know, it's a very important point. I mean, if in fact,
voluntary initiatives are there, then it doesn't take much
to say we'll carry on the voluntary initiatives. And, you
know, we will always assume that we will interpret whatever
is there in the same way. You know, I can remind you of
50-59 that everybody evidently when they wrote that they
thought was clear and it took 40 years to clarify. So--
DR. GRIMES: 30 years.
CHAIRMAN BONACA: 30 years, alright.
MR. WALTERS: Okay.
CHAIRMAN BONACA: I just wanted to hear about
that. Any other questions for Mr. Walters?
If not, I thank you very much.
MR. WALTERS: Thank you.
CHAIRMAN BONACA: I think that also NEI should be
commended for the work they did in support of the license
renewal.
DR. SEALE: So far, it's a win-win.
MR. WALTERS: Yep.
CHAIRMAN BONACA: Okay. I think with that we end
-- this is the end of the presentations. I think that we
should complete the discussion among the ACRS members that
we initiated yesterday afternoon and see if there are any
additional issues we want to raise now. And after that, we
will--
DR. SHACK: Did we invite the UCS people to see if
they wanted to make a presentation?
MR. DUDLEY: No, we have not. I did inform Mr.
Lochbaum that the issues of incorporation of the Union of
Concerned Scientists report would be included in the
presentations.
CHAIRMAN BONACA: Well, as we go through the --
around the table here, we will talk also about what we would
like to hear during the May meetings in two weeks. And,
Bill, you have a suggestion maybe or should we invite
Lochbaum to come and?
DR. SHACK: Well, you know, I think if we're going
to hear all perspectives, I think--
CHAIRMAN BONACA: That would be very much.
DR. SHACK: He has a different perspective on GALL
than we've probably heard today.
CHAIRMAN BONACA: Any other thoughts on that?
DR. SHACK: I think that maybe say no.
CHAIRMAN BONACA: It may be worthwhile to invite
him.
DR. KRESS: Certainly.
DR. SEALE: Well, I think if he wants to
communicate with the ACRS, we ought to give him an
opportunity to communicate with the ACRS, going through the
filter of commissioners. If he only talks to them, it
doesn't do us a whole lot of good.
CHAIRMAN BONACA: So that's a--
DR. GRIMES: Dr. Bonaca?
CHAIRMAN BONACA: Yep.
DR. GRIMES: And I will work with Noel to make
sure that the UCS comments on SRP and GALL have been
submitted so we can share those with you in advance of the
full committee meeting as well.
CHAIRMAN BONACA: Thank you. Going around the
table. Bill, do you have any additional comments than -- in
addition to the one you provided yesterday?
DR. SHACK: No. You know, it seems to me they've
made a lot of progress. You know, I do like the new format.
I know when it was initially discussed I was somewhat
skeptical, but I believe that the Chapter 11 is a very
helpful sort of thing. It -- everything comes together.
There is still maybe does to be a little bit of need to, as
I say, you had to go a ways to find where the one-time
inspections were required. That might be made more
transparent in some way.
DR. SEALE: Yeah.
DR. SHACK: Even if, you know, and even in the --
you know, the further evaluation, if, you know, if one-time
exams or one time inspections are one of the leading
candidates you might call that out in the particular one.
But -- and I assume that they will continue to trend
everything towards the Chapter 11 format; that is, there is
still some sections with large chunks of aging management
programs buried in the chapter and that will continue, but
to me, I think they've made a great deal of progress here,
and it looks good.
CHAIRMAN BONACA: Good. Thank you. Bob?
MR. UHRIG: I'm looking forward to the outcome of
the resolution of GSI-168, and in the light of that seeing
what impact it may have. It may have none or it may some
impact. We have the consultant's report, and, as you and I
discussed in the hall a little bit ago, he comes down very
strong on saying that condition monitoring really is not a
very good predictor of where things are going in the future.
And then at the end says, we don't have anything else. So
we're sort of stuck with it. And we were speculating if
there were other sources of information and one that
occurred to us was -- there's a lot of plants around that
are some power plants, some chemical plants, et cetera, that
have cables in them; have been operating for 40, 50 years.
And it strikes us that some organization, maybe the NRC,
maybe somebody else should undertake to look at some of
those cables, what they look like after 30, 40, 50 years of
operation. I understand there's been some of that already
done, but it certainly is not a comprehensive program. The
utilities that have older plants would certainly have access
to cables that -- when they were shutting those plants down.
The problem is that those cables are not the same quality as
the cables that we have today. So it's a answer--
DR. SEALE: They may be the quality of the ones
that were put in when the plant was built, though.
MR. UHRIG: Well, that may be. Okay. But it's
just a suggestion that this cable issue is a serious
concern.
CHAIRMAN BONACA: That's -- when we discuss at the
end our recommendations to the staff for presentation. That
may be a candidate. Just to hear something about that.
MR. UHRIG: Okay.
CHAIRMAN BONACA: Graham?
MR. LEITCH: As far as issues that I'm left with a
little bit of concern about there is still the issue of 10
to the 17th versus 10 to the 21st neutrons, and exactly
where specificity of -- where that applies physically in the
vessel, what type of steel we're dealing with there. And
I'm still a little unclear about that issue. And I think
maybe that would be a candidate for some more discussion at
the full meeting.
CHAIRMAN BONACA: Yep. Good.
MR. LEITCH: I guess thinking about it some more
last night, it seemed to me -- I thought I heard that there
were areas where effluents of 10 to the 21st had already
been experienced in 30 plus years of operation. So I'm just
a little confused about where that whole topic is going.
CHAIRMAN BONACA: Good.
MR. LEITCH: The other thing, in a very general
way, is when -- particularly, you know, when you look at the
NUREG and elsewhere or the Reg Guide I should say, there are
three important parts of the application that we haven't
discussed very much at all. One is the FSAR supplement.
And one is the changes to the technical specifications.
Perhaps those two are almost self-explanatory. But then the
third one is the environmental information that also needs
to be submitted as part of the application apparently. And
I haven't heard, you know, any real discussion of that, and
I'm not sure if there's any real guidance that exists as to
the depth of that discussion, the format of that -- just
what is the expectation there on that environmental
information.
CHAIRMAN BONACA: Yeah, we have not expressly
reviewed the environmental portion.
DR. GRIMES: As an organizational matter, we
typically don't bring the staff environmental impact
statements to the ACRS for review. As a matter of fact, in
my description of the process, the whole environmental track
is separate, and there's a comparable review to the ACRS
review, by the Council on Environmental Quality. So the
environmental folks tend to operate in their own little
sphere. There is -- it's a well established practice.
There is a recently completed, and by recent, I mean
September of 2000 regulatory guide on the content of the
environmental report from license renewal. But the standard
review plan for license renewal is now in final form.
That's NUREG 1555 I believe. And at one of the earlier,
ACRS meetings, we did do a brief little show on what that
guidance consists of. We could run back through that
material for you, but, you know, my -- we'll do whatever
you'd like, but I'd suggest that you might want to consider
whether or not you want to delve into that area at all.
There is well-established guidance, and it is -- it's a
fairly well running system.
MR. LEITCH: I was not familiar with that
background. And I appreciate that information. I think I'm
just coming up to speed with that.
CHAIRMAN BONACA: Sure. And maybe we could just
get a brief presentation during one of the next licensing
renewal application reviews?
DR. GRIMES: We could do that.
CHAIRMAN BONACA: I think we could do it during a
subcommittee meeting rather than just coming in on the next
full committee for the generic documents. Rather than look
at the generic documents, so, for that, so--
DR. GRIMES: Correct. We could cover it. As a
matter of fact, I'll make a point that we would be prepared
at the A&O subcommittee--
CHAIRMAN BONACA: Right.
DR. GRIMES: To specifically cover the FSAR
supplement tech specs to the extent that we have -- we
haven't seen any yet. I think Hatch may have submitted a
tech spec change in conjunction with license renewal. But
it's my expectation we're going to see the tech specs work
separate so that they're not exposed to the license renewal
review. And then, of course, we can put together the
material from the environmental impact review that we used
for our public meetings. We could share that with the
committee. That's all I had.
MR. LEITCH: Thank you. That's good.
DR. GRIMES: Yeah, okay.
DR. SEALE: Well, I would agree with Bill's comment
about a little bit more transparency on the identification
of where one-time inspections are needed. I -- since I'm
supposed to be reviewing the chapter on structural materials
-- I mean, reactors and so on, I'm certainly interested in
this embrittlement of 10 to the 21st versus 10 to the 19th
thing. I have a stupid question to ask, and not being shy
in that regard, I thought I'd bring it up. And Bill just
mentioned that he would expect over the maturation of this
process, as more and more information comes in, that Chapter
11 is going to grow and some of the generalities in some of
the earlier chapters are going to fade away. Is that a
fair?
DR. SHACK: No, it's just -- it's mostly going to
be moved.
DR. SEALE: I'm -- well, that's what I mean.
Moved. It -- would it make sense, especially with this
format, for GALL to be a looseleaf thing and occasionally be
updated in that format rather than being updated in the
format of a whole new publication of it?
DR. GRIMES: I have a -- for every stupid question,
there's an equally good stupid answer. And my immediate
reaction is that makes too much sense for us to pursue it.
And I -- the reason that I have to sort of make light of it
is because every time I get those supplement changes for
0933, I just groan at the prospect of sitting there, leafing
through that bloody report, sticking in the page changes. I
mean, but we used to do that in the good old days when we'd
get the ASR supplements.
DR. SEALE: Yeah. Yeah.
DR. GRIMES: You know, and I think half the
professional staff at the NRC spent their time leafing
through -- sliding pages.
DR. SEALE: Sure. But this is such a dynamic
process right now. You know, if it were just doing clerical
stuff, that's one thing. But clearly you're on the front
edge of the learning curve. And it -- there's a tremendous
benefit for everybody to be able to know that by golly when
we come to the application of plant XYZ, that the version of
the GALL report of such and such a date is the way we're
going to do it. Otherwise, you're going to spend all your
time asking yourself well do we take into account the
results of what we learned in plant UVW? Yeah. Yeah.
There is -- you know.
DR. GRIMES: Wait, they don't make looseleaf CD
ROMS?
DR. SEALE: Well, but you know what I mean.
DR. GRIMES: Yes, sir. Dr. Seale, I understand
completely and I do think that that would be a wise way for
us to publish GALL is to make it looseleaf and to clearly
identify the updating practice that we would expect to
follow. I think -- my hesitation was when Dr. Bonaca
referred to frequent updates.
DR. SEALE: Uh huh.
DR. GRIMES: And I think--
DR. SEALE: Well, you know.
DR. GRIMES: It's the frequency is the only issue.
DR. GRIMES: Yeah, well, the thing is that -- yeah,
but frequent in the context of knowing that it's a dynamic
document, and being aware of that as you use it could reduce
the amount of confusion rather than increasing it. And, you
know, the first question I raised when I thought about this
was well is that going to be so resource intensive that it's
going to kill you. And I'd say normally that might be a
very appropriate question. But with these different
applications coming in and so forth, hey, it's the name of
the game around here. And you got to play it. And so it's
-- you might want to look at that real carefully.
DR. GRIMES: Well, I intend to. As a matter of
fact, before the day is out, I'm going to find out how you
go about getting a NUREG published in looseleaf form.
DR. SEALE: Yeah, and that's a serious question.
MR. SIEBER: You have to give us a charge account
to do all the filing.
DR. SEALE: He'll send you a new disk.
CHAIRMAN BONACA: Okay.
DR. SEALE: That's all I had.
CHAIRMAN BONACA: That's it? Jack.
MR. SIEBER: I have no further comments from those
of yesterday other than to say that the -- I think this is a
well organized program, well coordinated, and it's -- the
successes in NRC and NEI have done.
CHAIRMAN BONACA: Good.
DR. KRESS: I guess I would second what Jack just
said. I think this whole process with the standard review
plan and Reg Guide that endorses 95-10 and the GALL report
has a high probability of being a successful enterprise. I
guess I am glad that the NRC has said that one-time
inspections can be part of the aging management program, and
I share Bill's view that that ought to be more transparent
where that applies.
I guess I'm a little disappointed, or not
disappointed -- amazed a the lack of PRA input in this
process. I guess if George was here, he'd get a little
appalled at that. But it seems to be -- it doesn't look
like it's going to work without out it, without much of it.
So I think it's a successful program. And--
DR. GRIMES: Dr. Kress, I would like to say I
expect that we will see more PRA input into the process in
the future. My concern about getting PRA involved in
license renewal in a more explicit way is getting too far in
front of risk-informing regulations.
DR. KRESS: I fully understand that, and I agree
with you.
DR. GRIMES: But I do want to point out that in the
inspection process, in the manual chapter, and we didn't
share that piece -- you know, which is also an important
piece of the whole process as we have manual chapter 2516
and the associated inspection procedure. I believe it's
71002. In there, we specifically use PRA in order to
identify where the inspection process is going to go
looking.
DR. KRESS: Yeah, I think that's probably the most
appropriate use of it, anyway.
DR. SEALE: Sure.
DR. GRIMES: Thank you, sir.
DR. KRESS: I'm glad you pointed that out. Other
than that, I don't -- that's all I have to say right now.
CHAIRMAN BONACA: Thanks. And I -- really my
comments are -- well, you heard them, I mean, I -- you know
I raised some similar issues to the IPE on the EOP's issues
that there is some confusion to this -- on the voluntary
commitments and then on the update frequency. But in
general, I feel that this has been a big effort, and I think
that we have a body of guidance documents which are very
effective. I mean, if I think of a new applicant having to
undertake this between the experience of the first two and
this body of guidance, there is clarity to the process. So
with that, there are seven questions we pose ourselves.
There were actually criteria that we set for ourselves in
our review. And we will talk it over with the full
committee in two weeks. If I look at those questions for
all of them I believe the answer is pretty much yes. The
document are well integrated. I think we have concluded
that they are. Are there sufficient bases for supporting
technical decisions? I think there are. In some areas
where we said there's more to be done and there is no
further criteria, we understand why that is the case. And
maybe the GALL report will looseleaf will help speed up the
updates.
DR. SEALE: Maturate the--
CHAIRMAN BONACA: We will -- we asked ourselves if
the lessons learned are folded in I believe that we are
convinced now that they are, from Calvert Cliffs and Oconee.
Is the guidance adequate to support effective
scoping screening? Probably yes. I mean, the concern was
older plants. It's clear that there is not going to be a
cookie-cutter approach to that. But still, the answer seems
to be yes.
Will the NRC staff develop a comprehensive
understanding of the technical issues? I am convinced now
that they will have to for each one of the applications. So
the answer is yes, they'll be involved. It will not be
simply a rubber stamping of the process.
Is the review of plant specific operating
experience adequately emphasized by the SRP? That's a
concern that both Bob and I had. And I think that they are
-- it's emphasized, and that's important.
Have the SRP and supporting documents taken into
proper consideration the issues and concerns raised by the
-- all stakeholders? I believe they have. I mean, we had a
presentation. It was focused on the issues, and I believe
that you will see concerns have been addressed, too.
And also the license renewal generate issue
resolutions again, again, they're adequately folded in. So
I think we have a positive message to bring to the full
committee.
I would like to go through just some of the
arguments I heard from you that we should ask the staff to
bring to the full committee.
You know, a suggestion I would have is that again
at the beginning there could be some explanation that
measured differences between the documents we saw before and
the one we have now. It doesn't have to be very extensive,
just, you know, a measure of observations of that.
DR. GRIMES: The sense that I got from the dialogue
was that not on a section by section basis, but more
globally.
CHAIRMAN BONACA: Exactly. Globally understand --
you know, there is a significant change to GALL report. We
understood that. But I think the issue of formatting those
two new chapters and the reasons why that's very important.
A second issue I think that would be very useful
if you went through an example of how you go from one issue
all the way down to the GALL report, the way we did for the
one-time inspection. And I would suggest that the same
example could be provided, because Dr. Powers had quite an
interest in the one-time inspection. And that would allow
us also to -- you know, talk about again the philosophy
behind those as was discussed during this meeting here.
Clearly, we need also a brief summary of
disposition of the NEI and the issues. You gave us a very
focused presentation on that. I would suggest simply that
you highlight the most important points, and give us a head
count of whatever is open. And if there is some significant
one that is open, then we'll like to hear that -- about
that.
I think we need to hear something about the
cabling issue. There is a significant interest in the part
of the committee on cable performance. The presentation on
GSI-168 I think sensitized everybody on the committee on
this issue. And on that, if there is any sites you have
regarding the ability of condition monitoring to predict and
what are the ultimates of that that would be useful.
The issue of effluents that Graham, Mr. Leitch,
brought up I think is very important. I think we'd like to
hear about that. He was left hanging. We were a little bit
left hanging there with -- on the issue that some areas have
already exceeded the 10 to the 21st criterion.
When you talk about -- I would suggest when you
talk about the GALL report, and you're telling us the
reorganization of it, then there is an issue that was raised
by a number of members regarding well, yeah, I think Graham
raised it regarding the fact that the guidance ends with
more is needed. And there are no criteria for that. That
is important that one communicates that as experience comes
in. Then this experience will be folded in in what more
needs to be done. Where the programs in GALL are not
sufficient. That could be an opportunity also to talk
about, you know, the desire expressed here that there will
be some level of updates of the GALL report, with some
frequency. Not every three months, but six months.
We don't need to talk about frequency, but
certainly I mean, there is a valuable information coming in
that we need to--
DR. KRESS: After every new license renewal review.
MR. SIEBER: Or right before.
CHAIRMAN BONACA: Right before.
DR. GRIMES: That's going to be really messy in
2002.
CHAIRMAN BONACA: Alright.
DR. GRIMES: That's right.
CHAIRMAN BONACA: I personally would like to just
hear briefly from you a perspective on the fact that, you
know, EOPs -- EOP equipment is in the maintenance rule as
part of the CLB but is excluded from the license renewal
rule. I mean, if it is, it is. And, on the other hand, it
just leaves you hanging there. Why this inconsistency?
Now, I do believe that it is not -- there was some thought
behind that. And so if there is any information, it would
be valuable to the committee to hear why it was left out,
because it's so obvious that -- you know, you look at one
rule and then you look at the other one, and in one case
it's very explicitly called for, but the other one it's not.
And the last thing would be on voluntary
commitments. I mean, severe accident management is one, but
there are others and I wasn't left with a good feeling about
it. I mean, why leave them hanging there.
DR. SHACK: Why make those voluntary commitments
voluntary, right?
CHAIRMAN BONACA: Right. Like I said, we would
like to hear about it.
DR. KRESS: I think you're always between a rock
and a hard place on those. What the expectation is that
those will be committed to and followed up by the plants,
and although NRC says they don't have any enforcement, they
really do have. And, you know, I wouldn't be too explicit
on how you deal with those.
CHAIRMAN BONACA: No, I understand that.
DR. KRESS: I would just assume they're going to be
there, and deal with it when the time comes if they're not.
CHAIRMAN BONACA: The reason why I raised it is
that there are three issues that we discussed and the one
was PRA, which has been excluded. Then you have--
DR. KRESS: Virtually excluded.
CHAIRMAN BONACA: The issue of EOPs. I'm sorry?
DR. KRESS: Almost excluded.
CHAIRMAN BONACA: Yeah, almost excluded. And then
you have voluntary commitments. The question is, clearly
the rule is clear that the staff is not in, but we as a
committee I think have a responsibility to also speak about
the rule. I mean, if we found something really blaring
wrong with the rule, I think it would be our obligation to
point it out. And so I don't think that -- you know,
looking at it is inappropriate. At least, it would be
important to hear.
MR. SIEBER: I guess when I think about that,
though, it's not in the current licensing basis. It's not
required now, and license renewal doesn't change anything.
DR. KRESS: Yeah, why should you treat it any
differently in NUREG 3.
MR. SIEBER: And, you know, whatever the ordinary
regulatory process to deal with these things should take
place and they -- and I don't think it's a factor in license
renewal.
DR. KRESS: That was my feeling.
CHAIRMAN BONACA: Well, I'm no saying license
renewal. I'm saying would the licensee still be committed
to these voluntary commitments?
DR. SHACK: If they volunteer to commit, they'll
volunteer?
MR. SIEBER: Yeah, that's -- if it's on the record,
it's on the record. But like I said, license renewal is not
the issue in my opinion.
CHAIRMAN BONACA: Well, I mean, that's one -- I
would like to hear about that.
DR. GRIMES: We'll be prepared to talk about
commitment management.
CHAIRMAN BONACA: Were there any other issues that
we should--
MR. DUDLEY: One question, do you feel it would be
worthwhile to have an NEI presentation at the full committee
meeting?
CHAIRMAN BONACA: I think it would be worthwhile,
if nothing else, even if a brief one to, you know, indicate
the level of a consensus that the staff and NEI have reached
on this. I think that's very important.
DR. SHACK: The violent agreement?
CHAIRMAN BONACA: Yeah. It doesn't have to be a
long presentation, I think it would be very useful and it
can be done quickly.
Anything else we would like to hear for the full
committee?
Okay, were there any other comments from the
staff? From NEI?
DR. GRIMES: Dr. Bonaca?
CHAIRMAN BONACA: Yep.
DR. GRIMES: I would like to, as I mentioned
yesterday, I would like to point out that when we issued the
guidance for public comment, we identified four specific
questions that we were interested in receiving some feedback
on. So far, I haven't seen anybody respond to the four
specific questions, but I would like to call to your
attention, question number three talks about the treatment
of the ASME code and reliance on the 50.55(a) process. And
it asks for feedback on whether other national codes and
standards that are referenced in GALL, like those published
by the ACI and I would add to that or IEEE or other
acknowledged standards groups -- whether they should be
credited and how should GALL treat them. In the absence of
any other guidance, we credit programs that cite specific
additions and addenda of particular codes and standards, but
we don't, except for the ASME process, we don't give credit
for the consensus process to change the practices in the
future. And part of that is because we're expected to
articulate a safety basis for concluding how particular
practices and its aging effects. And it's difficult to do
that in a -- and say whatever they decide to change in the
future is okay too. So that's sort of our fall back
position, but I aks you to think about that in terms of --
you have provided us with some very useful feedback on ways
that we can improve the guidance and make it more
transparent and improve its readability. And we will be
struggling with those questions in the future, so if there's
anything that you can add, we'd appreciate that.
DR. SEALE: I wouldn't advise you, but I would
suggest that Dana is extremely concerned, or let's say aware
of the legislative or maybe it's administrative urging at
the present time to rely on standards and -- consensus
standards where possible.
DR. SHACK: If I go to the web site.
DR. SEALE: You might want to try to get his input
on that question.
DR. SHACK: If I go to the web site, will I see
your four questions?
DR. GRIMES: Yes, if you look at the Federal
Register notice. Yes, if you look at the Federal Register
notice. Okay.
DR. GRIMES: And I'll also -- want to verify. We
also made a number of commitments over the past day and
half. We're going to provide a sample of the industry
comments to you so that you can see the form that they were
presented.
DR. SHACK: Will you be able to say anything about
the public comment by that time or that will be too fresh?
DR. GRIMES: Probably too fresh, especially with
the letter writing campaign. We're still sorting faxes and
e-mails and nuclear power is bad and you folks should be put
out of work. But if we find any other -- if we can assemble
any of the other public comments that we've got, we'll pass
those along.
We're going to expand the explanation about dams
to address empoundments and earth dams. Yeah, in the table.
We're going to provide you with the UCS comments
on GALL SRP and we'll make sure that for the subcommittee on
the A&O safety evaluation that we describe the other
features of the license renewal process.
CHAIRMAN BONACA: Yea, we discussed about the FSAR
update and the tech specs in the letters that we wrote for
Oconee and Calvert Cliffs.
DR. GRIMES: And we'll also do a quick review of
the environmental review process and illustrate it with the
results for Arkansas, so you can see how that process works.
CHAIRMAN BONACA: Anything else. If not, I want to
thank the staff for the presentation. It was informative,
and I adjourn the meeting.
[Whereupon, the meeting was adjourned at 11:59
a.m.]
Page Last Reviewed/Updated Tuesday, July 12, 2016
Page Last Reviewed/Updated Tuesday, July 12, 2016