Plant License Renewal - October 20, 2000

                             UNITED STATES
                              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,
               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
               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
               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
               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
               [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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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.
               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
               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
               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
               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
               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.
               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.
               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
               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
               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
               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
               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
               MS. FRANOVICH:  Thank you. Perhaps at the break I
     could chat with you.
               DR. SEALE:  Okay.
               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
               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
               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
               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
               MR. SHEMANSKI:  Paul Shemanski from Electrical
               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
               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
               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
               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
               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
               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
               MR. VORA:  This is Jit Vora from Office of
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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.
               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
               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
               The spent fool -- excuse me.  Whoa.
               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
               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
               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
               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
               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
               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.
               CHAIRMAN BONACA:  Okay.  Any other comments or
               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
               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.
               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.
               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
               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
               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
               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
               MR. WALTERS:  We do.  And there's no disagreement
     with that.  We just don't want renewal to be the
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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
               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


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