Materials & Metallurgy - November 29, 2001

                 Official Transcript of Proceedings


Title:                         Advisory Committee on Reactor Safeguards
                               Materials and Metallurgy Subcommittee

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Thursday, November 29, 2001

Work Order No.: NRC-117                               Pages 1-135

                   NEAL R. GROSS AND CO., INC.
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                          UNITED STATES OF AMERICA
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                                 + + + + +
                             NOVEMBER 29, 2001
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                            ROCKVILLE, MARYLAND
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                       The Subcommittee met at the Nuclear
           Regulatory Commission, Two White Flint North, Room
           T2B1, 11545 Rockville Pike, at 8:30 a.m., F. Peter
           Ford, Chairman, presiding.
                 F. PETER FORD            Chairman
                 MARIO V. BONACA          Member
                 THOMAS S. KRESS          Member
                 WILLIAM J. SHACK         Member
                 Noel F. Dudley
           ALSO PRESENT:
                 Maitri Banerjee
                 Mohamad Behravesh
                 Helen Cothron
                 Robert Cullen
                 Farouk Eltawila
                 Bob Exner
                 Lane Hay
                 Gary Henry
                 Robert K. Johnson
                 Ken Karwoski
                 Bob Keating
                 Herm Legally
                 Steve Long
                 Louis Lund
                 Mati Merilo
                 Rick Mullins
                 Emmett Murphy
                 Jim Riley
                 Edmund Sullivan
                                            I N D E X
                        AGENDA ITEM                        PAGE
           Opening Remarks by Chairman Ford . . . . . . . . . 4
           Introductory Remarks, E. Sullivan. . . . . . . . . 6
           NEI Presentation, J. Riley, NEI. . . . . . . . . .15
             NEI 97-06
             NEI Generic Change Package (GCP)
             Present Issues
           Concerns with GCP and NEI 97-06. . . . . . . . . .46
             E. Murphy, NRR
           Staff Presentation (Cont.), E. Murphy, NRR . . . .93
             Proposed resolutions
             Status and Plans
             Standards Issues, EPRI, Mohamad Behravesh. . . 100
           NEI Status, J. Riley, NEI. . . . . . . . . . . . 114
           Discussion, Chairman Ford. . . . . . . . . . . . 121
           Adjournment, Chairman Ford . . . . . . . . . . . 135
                                                    (8:36 a.m.)
                       CHAIRMAN FORD:  The meeting will now come
           to order.  This is a meeting of the ACRS Subcommittee
           on Materials and Metallurgy.  I am Peter Ford,
           Chairman of the Materials and Metallurgy Subcommittee. 
           The other ACRS members and consultant in attendance
           are:  Mario Bonaca; Thomas Kress, and William Shack.
                       The purpose of this meeting is for the
           Subcommittee to review the latest revision of the
           Nuclear Energy Institutes (NEI) 97-06, "Steam
           Generator Program Guidelines," and the Generic License
           Change Package.  The Subcommittee will gather
           information, analyze relevant issues and facts, and
           formulate proposed positions and actions, as
           appropriate, for 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 November 9, 2001.
                       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.
                       Since the early 1990s, the staff and the
           industry have worked to develop a mutually agreeable
           regulatory framework to ensure steam generator tube
           integrity.  In 1998, affected licensees committed to
           NEI to follow NEI 97-06, "Steam Generator Program
           Guidelines," and the associated Electric Power
           Research Institute (EPRI) implementing programs.
                       It was January 2001 that NEI revised NEI-
           97-06 and the implementing programs, and has developed
           an Industry Steam Generator Program Generic License
           Change Package, which provides templates for licensees
           to amend their technical specifications.  It is our
           understanding -- It is the ACRS' understanding that
           the staff and NEI are in general agreement concerning
           the intent of the NEI 97-06, Rev. 1, and the change
                       The last time the ACRS was involved in
           this specific issue was in early 1999.  Since these
           discussions are approaching agreement, we thought it
           appropriate to have a Materials Subcommittee meeting
           to bring us up to date so that there is no delay on
           our end when this matter is brought up to the full
           ACRS meeting next week on December 6th.
                       We will now proceed with the meeting, and
           we will call upon Mr. Ted Sullivan of the Office of
           Nuclear Reactor Regulations to begin.
                       MR. SULLIVAN:  Thank you for that
           introduction.  I would comment that a lot of the
           things I was going to say were contained in your
           introduction.  So I'll skip them and possibly hit some
           other points.
                       My name is Ted Sullivan, and I am just
           going to make a few introductory remarks maybe to st
           the stage for what is to follow.
                       We met with the Subcommittee, I think, on
           September 26.  The purpose of that briefing was to go
           through the steam generator action plan as it
           currently exists.  We covered a number of topics,
           basically falling in three broad categories,
           categories of licensing process, NEI 97-06 and the
           DPO.  That's sort of a breakdown of it.
                       We devoted a fair amount of time to the
           subject of NEI 97-06 and the NRC's process and status
           for revising the regulatory framework for steam
           generators.  Our understanding was that we should come
           back and provide more detail, and we thought that this
           was a very good request, because as Dr. Ford said, if
           there are comments that are going to come from ACRS,
           we would like to get them early and factor them in.
                       Basically, the rationale for why we are
           doing this, this being revising the regulatory
           framework, is that our existing requirements are
           prescriptive.  They are out of date, and they are
           really not focused on the right thing.  They are
           focused on surveillance.
                       The textbook is on surveillance and repair
           criteria.  They are not focused on the condition of
           the tubing while the plant is operating or what we
           refer to as tube integrity.
                       We have been at this for quite some time,
           revising the regulatory framework.  We worked on
           rulemaking in the early to mid-Nineties, and we came
           over, I think, a couple of times to brief ACRS on the
           rulemaking effort.
                       That was superseded, for reasons that we
           explained back then, with a generic letter and
           regulatory guide approach.  That kind of got off the
           ground.  We made a fair amount of progress in terms of
           getting a generic letter drafted.  We got the reg
           guide out for public comment.
                       In a fairly similar time frame, the
           industry started working on kind of a similar program
           which has been named NEI 97-06.  It is an industry
           initiative.  They asked us to put the generic letter
           on hold and consider that as an alternative approach,
           which we did.
                       We received -- We spent a lot of time
           discussing the program and how it would fit into the
           framework and what a generic license change package
           would consist of.  Eventually, after a lot of
           discussion, NEI was able to send in a package, which
           is on my next Vu-graph, in February 2000.
                       Shortly thereafter, the Indian Point 2
           failure occurred, and we were basically sidetracked
           for a year.  We got the review going in January of
           this year, and as I have previously noted, the review
           of NEI 97-06 is part of the steam generator action
                       Through a number of interactions that we
           have had with industry, including the workshop we had
           earlier this year and some review that we have
           explicitly done on the guidelines that are part of the
           NEI 97-06 program, we generated some concerns that we
           are working on and that, I think, will constitute a
           lot of the discussions that are going to follow.
                       The upshot of what we've done is we
           basically altered our strategy for how we want to
           proceed into basically kind of two time frames, a more
           near term approach to get us over these concerns, and
           a more long term approach to get us back on track with
           a fully performance based approach.
                       I am going to be deliberately vague,
           because I think that is going to be explained a lot
           more in detail later.
                       Now the presentations to follow:  Jim
           Riley and, I think, one of his other colleagues is
           going to talk about the NEI 97-06 industry initiative. 
           This is an initiative that is in place in the nuclear
           utilities in this country, and we thought that that
           would be a good way to set the stage for how our
           regulatory framework is going to try to build on top
           of that.  
                       So we thought it would make sense for NEI
           to make a presentation first, and someone from the
           staff will follow.  We are not exactly sure who at
           this moment, but we do have Vu-graphs and a couple of
           people ready, willing and able to fill in, if Emmett
           isn't here.
                       MR. LUND:  Emmett is running late.
                       MR. SULLIVAN:  Okay.  
                       CHAIRMAN FORD:  As you are already up
           there, maybe you can give us some idea.  It's
           disturbing that this has been going on for nigh onto
           ten years in one form of the other.
                       MR. SULLIVAN:  Yes.
                       CHAIRMAN FORD:  So can you give us some
           idea as to when this thing might come to an agreed
           upon package?
                       MR. SULLIVAN:  I'll try.  That's a good
           lead-in for something that I did want to mention.
                       Because of the Commission meeting that is
           coming up on this coming Monday, the staff wanted to
           be able to answer that question as best we could.  So
           our senior managers requested a meeting with NEI,
           which occurred yesterday.
                       Basically, the two kind of near term
           issues that we have been working on -- One is to
           establish maximum inspection intervals in lieu of
           going directly to a performance based approach, and
           establishing appropriate regulatory controls on those
           intervals within the two issues that we have been
           discussing most recently.
                       We have reached agreement on the
           regulatory controls aspect, and we have reached
           agreement on the overall concept of the near term
           approach and the longer term approach.  
                       The industry is interested in putting in
           place a program that satisfies some of their
           objectives and not just make this all one way to
           satisfy NRC's objectives.  Their objectives are to get
           longer inspection intervals for plants, where that can
           be justified.
                       They are in the process of resolving a
           number of comments that they have generated internally
           and that NRC has made on some of the more recent
           proposals.  They are estimating, based on yesterday's
           meeting -- and I'm probably getting ahead, and Jim
           Riley would probably address this.  But they are
           estimating being able to come to complete resolution
           on that, including addressing NRC's comments, by the
           middle of 2002.
                       We have basically already started writing
           a safety evaluation, and I think we can  virtually
           have the safety evaluation done by that time frame. 
           That's our intent.  
                       So that by the end of 2002, we can have
           gone through all the rest of the steps needed, which
           include such things as putting the safety evaluation
           out for public comment, meeting with the Commission
           once we have resolved the public comments, and putting
           the safety evaluation out in final form in a
           regulatory issue summary, which is a vehicle that NRC
           is using these days for this kind of activity.  
                       Then what would follow from that generic
           activity would be individual submissions by plants of
           tech spec revisions.  So I hope that answers your
                       CHAIRMAN FORD:  So by mid-2002 --
                       MR. SULLIVAN:  We should have all the
           technical issues resolved.
                       CHAIRMAN FORD:  -- Generic Change Package
           will be signed and sealed.
                       MR. SULLIVAN:  And delivered to us.  
                       CHAIRMAN FORD:  That opens up the pathway
           for individual plants to come and make their
           individual cases because of the change in the tech
                       MR. SULLIVAN:  That opens the pathway, but
           we have to go through some kind of mandatory steps. 
           We have to finish our safety evaluation, which we
           think will largely be finished by that time, because
           we are not going to be operating in a vacuum from each
                       We have to issue that safety evaluation
           for public comment.  We may have to come back and
           brief you one more time.  We have to go to CRGR.  We
           have to resolve the public comments.  We have to brief
           the Commission, and then we can issue it in final
           form.  All of that may take an additional four to six
                       CHAIRMAN FORD:  By the end of the year of
                       MR. SULLIVAN:  Yes.
                       CHAIRMAN FORD:  So as far as the ACRS is
           concerned and as far as committee is concerned, all
           you are looking from us today is to say, yeah, you've
           got the right technical issue.  You are arguing and
           discussing the various technical issues.  Do we see
           any further issues?
                       MR. SULLIVAN:  Right.  Are we on the right
                       CHAIRMAN FORD:  And then just go forward
           on that.
                       MR. SULLIVAN:  I think that would be the
           kind of feedback we would like from the full
                       CHAIRMAN FORD:  Jolly good.
                       MR. SHACK:  Ted, just a question.  Somehow
           in all this, I don't see any mention of severe
           accidents.  Have those been resolved in some way or
           have they just sort of disappeared?
                       MR. SULLIVAN:  Steve might be able to
           elaborate, but I think what I would try to say is that
           what we are trying to do is put in an approach that
           will require -- and not try; we are going to put into
           effect an approach that will require licensees to
           continue to have NRC approval on any alternate repair
           criteria that may affect risk.
                       MR. SHACK:  You deal with it when you are
           dealing with the alternate repair criteria.
                       MR. SULLIVAN:  Right.  Do you want to
           elaborate, Steve?
                       MR. LONG  This is Steve Long with the NRC
           staff.  Basically, what Ted said -- You will see this
           later on when we describe the performance criteria and
           how we intend to control the performance criteria
           through the tech spec -- this is not really my part,
           but the tech spec requirement for a steam generator
           program and content of that program being performance
                       So that the performance criteria would
           need approval from the NRC to change, even though they
           are not in the tech specs directly.  Those performance
           criteria are things that have come from our design
           basis regulation so far that we feel are necessary to
           control risk, including the risk from severe
                       We have had some discussions with the ACRS
           before about how that's not a very direct control. 
           Also, we are not sure exactly what we need to control
           to, and there's a lot of work that we have also
           described to you about the steam generator research
           program, part of which stems from the DPO that you all
           reviewed and reported on.
                       As we get research findings that allow us
           to know how to allow -- for instance, how much leakage
           you can allow in different parts of the RCS and still
           be okay during a severe accident, we will be able to
           relax some of these performance criteria.  But the
           intent right now is to be able to maintain control of
           the performance criteria that we think are needed to
           address severe accidents, insofar as we have them
           already at least.
                       MR. SULLIVAN:  Okay.  I think, if there
           are no more questions, it would be appropriate to turn
           the microphone over to Jim Riley.
                       MR. RILEY:  Good morning.  Jim Riley from
           the Nuclear Energy Institute.
                       I came with a prepared presentation, but
           I, like Ted, found that a lot of the items that you
           talked about on your summary were things I was going
           to talk about.  So I am perfectly willing to focus
           this on whatever areas you feel are most beneficial to
           you.  But here is what I was prepared to talk about.
                       One of the things I do want to get across
           to everybody is the extent of the steam generator
           organization within the industry and the degree of
           commitment that the various utilities, all the
           utilities, have to the steam generator -- their steam
           generator programs and the steam generator
           organization.  I think that's an important message.
                       I was going to go through kind of a
           history of the regulatory approach.  I'm not sure that
           is necessary, but stop me, move me around on this as
           you wish.  I want to give you a little bit of a
           background on NEI 97-06.  I want to make sure
           everybody understands what that document is all about,
           what it consists of, and what the industry's
           commitment to it is.
                       I'll talk a little about how the program
           is continuing to evolve.  I do want to talk about the
           generic license change package, what's gone on in that
           area, and then what we have been doing with the NRC.
                       As Ted indicated, there is another person
           here that will be sharing this time with me, although
           the way that we would like to do it is to split up our
           time so that I'll let Emmett have his say next, and
           then Mohamad Behravesh is going to be talking about
           the EPRI guideline that governs steam generator
           inspection intervals, because that is clearly the
           technical issue that is catching the most attention
           right now.
                       I think it would make more sense to you
           and from a presentation perspective if Emmett first
           got into his discussion of what are the issues, and
           then we were able to present what we have done in the
           way of this guideline in a way that kind of answers
           the questions that he raises when he does his
                       So that's the way I'd like to do this,
           unless there is any objection.  
                       CHAIRMAN FORD:  Don't feel shy about doing
           this, because I personally am new to this, and I would
           love to hear what the background is.
                       MR. RILEY:  Great, okay.  I'll be happy to
           then.  If I get a little long-winded here --
                       CHAIRMAN FORD:  Well, the others will shut
           yo up.
                       MR. RILEY:  All right.  Let me tell you --
           This is a little bit of a history lesson, and we are
           going to skip over these first slides to some degree,
           but I want to go over this.
                       The industry has had a Steam Generator
           Management Program in place a long time.  This thing
           was kicked off in 1976 to take a look at corrosion
           that was going on, and an organization that basically
           involves all the PWRs in the United States  was set up
           at that time to look at corrosion concerns and see
           what can be done about them.
                       NUMARC entered the fray somewhere along
           the line, and since about 1993 has been working with
           the Steam Generator Management Project, which is SGMP,
           to establish a framework for steam generator
           degradation specific management and alternate repair
                       NEI, who evolved from NUMARC, entered the
           picture in about 1995, and at that time we established
           what we call a Steam Generator Working Group and a
           number of steam generator task forces, and I will tell
           you a little bit about what the differences are there,
           to address different issues.
                       So industry's commitment to this and
           involvement has been extensive and has been
                       The next -- Approximately the next ten
           slides, I'm going to try and summarize, because I
           think I'm a little bit short on time, but I'll take
           more time if you want on any part of it.
                       This first slide is a rough organization
           chart, I guess you could say, of how the industry is
           configured to address steam generator issues.  There's
           really three arms here.  
                       One is NEI, and I think everybody is aware
           of the fact that NEI is the regulatory interface on
           the industry issues.  In the case of steam generators,
           as I mentioned on the previous slide, we have been
           involved for about the last six years or more as NEI,
           and before that as NUMARC.
                       EPRI has the technical end of this thing. 
           EPRI has responsibility for the Steam Generator
           Management Project and its organizations and the EPRI
           guidelines that provide the detailed guidance on how
           NEI 97-06 is going to be implemented.
                       Then finally, we have INPO's involvement
           also through a series of steam generator review visits
           that they conduct, have been conducting for a number
           of years.  In fact, I believe now they have visited
           all the plants, and they are now starting on their
           second go-round.  That's accomplished by peer as well
           as INPO involvement where they go in and look at the
           industries -- at individual utility steam generator
           programs and make some evaluations on how well that
           program is being conducted.
                       So there's three aspects of this.  Let's
           talk for a minute about how NEI is set up.  NEI's
           Nuclear Generation Division has a number of working
           groups and task forces within it or associated with
           it.  As you are probably aware, these working groups
           and task forces are all set up with an NEI
           coordinator, in my case for steam generators, and
           participation by the industry on the groups to form
           the real core of the membership.
                 The way the structure is set up with NEI -- and
           it isn't even shown on this one, but within the
           advisory committees that consist of utility people
           within NEI -- it's called the NSIAC.  NSIAC stands for
           Nuclear Strategic Issues Advisory Committee, and it is
           made up of the chief nuclear officers of all the
           utilities, nuclear utilities, in the country.
                       They provide kind of strategic direction. 
           Underneath NSIAC we have a series of working groups on
           various issues that raise to this level of importance
           within the industry.  One of them is a Steam Generator
           Working Group.  It's been around for quite a few
                       Basically, that group is made up of
           executives, managers, highly experienced people from
           within the industry who have overall cognizance of
           what is taking place in the area of steam generators,
           kind of policy, what are we going to do about this
           one, and they set the task forces to work to actually
           do the job of pulling together whatever effort is
                       The Steam Generator Task Force, a number
           of whose members are here today, was set up to look at
           this generic license change package, this regulatory
           framework, and we have addressed not only that, but we
           have also been addressing a series of technical issues
           that have come around related to the steam generator
           generic license change package over the last couple of
                       So in addition to that, which is the
           structure that basically puts this GLCP in process, we
           also have a review board set up under NEI.  The whole
           purpose of that review board -- and its membership is
           also pulled from the steam generator organization
           industry -- is to answer questions that come up on
           these various guideline documents that are out there. 
                       It has a pool of experts that addresses
           these issues, and then puts an interpretation out
           which gets posted on the NEI website, so that the
           utilities are aware of what is going on and any
           particular question that comes up.  
                       That's the NEI organization.  The EPRI
           organization is -- The SGMP is a pretty large group of
           individuals.  The SGMP itself is run by a management
           -- SGMP management and senior representatives that
           look over the SGMP from the standpoint of budget
           control, policy, what issues they are going to be
           working on, etcetera.
                       Again, the PMMP is a group of fairly
           highly placed individuals.  Jack Woodward, you
           probably know, of Southern Company, a lot of other
           vice presidents, etcetera.  Again, the intent is let's
           keep an eye on how this whole thing is going, where it
           is going.
                       Underneath them they have senior
           representatives, some overlap there between
           membership, and again the same kind of a management
           function for steam generators, in particular.  The
           PMMP, as you note, looks over both the management --
           the materials review project, the liability project --
           I may get that wrong -- the liability which has vessel
           head penetration, cracking and other issues on that
           side, as well as the SGMP.  The senior reps are pretty
           much concentrated on the SGMP.
                       Within the steam generator end of it, the
           major organization is called TAG.  It's a Technical
           Advisory Group.  All of the nuclear utilities who are
           members of EPRI are members of this TAG organization.
                       There are meetings, about three meetings
           each year of this TAG organization, and typically 80,
           90 people, something like that at one of these
           meetings, representatives from all these utilities. 
           They get together for two or three days and share
           experiences, and listen to presentations by various
           people, myself included, on what happens to be going
           on within the steam generator world.
                       The whole idea of that TAG is experience
           sharing, technology development for those kinds of
           issues that relate to steam generator corrosion
           control, steam generator inspections, and things like
                       So this is an extremely good mechanism for
           addressing technical issues and for hearing experience
           from each other that they can use in their own steam
           generator programs to keep themselves as much up to
           speed on what's going on as possible.
                       This Technical Advisory Group has a series
           of committees set up within it.  The committee with
           kind of overall responsibility for integrating what is
           going on is called the IIG.  They have three technical
           committees under them that look at the different
           aspects of what the steam generator programs are all
                       One of these is the NDE IRG.  They are
           responsible for NDE issues, technique qualification,
           personnel qualification, inspection intervals which is
           one of the things we are going to be talking about
           this afternoon.  
                       They've got a guideline that they have
           written specifically to address these issues.  It's
           called the Steam Generator Examination Guideline. 
           That's been the center of some of this controversy
           and, as I mentioned, Mohamad Behravesh is going to be
           talking about that to some degree later.
                       The E & R IRG, as its name implies, does
           engineering and regulatory issues.  They have three
           guidelines underneath them, the in situ pressure test
           guidelines which gives us guidance on how to do
           pressure testing of tubes, integrity assessment
           guidelines which takes the information from the NDE
           guys and evaluates it like what's the condition of the
           steam generator right now, condition monitoring, what
           is it going to be like in order for us to make sure we
           can meet the performance criteria at the next
           inspection operational assessment.  All those things
           are in the integrity assessment guidelines.
                       Then finally, and the last one is going to
           skip my mind here -- Help me here.  What's the third
           one?  Why am I missing one?  Integrity assessment, in
           situ -- Okay, there are only two.  The other is in
           TSS.  Thank you.
                       Then the third committee is the Technical
           Support Subcommittee, and they do long term research
           and various R&D type efforts.  They have three
           guidelines under them:  The primary  secondary leak
           guideline which talks about what action levels we have
           at various levels of primary secondary leakage, and
           primary chemistry and secondary chemistry which talk
           about chemistry controls.
                       So this organization is basically
           responsible for putting together the detailed guidance
           of how you run a steam generator program and doing the
           work that is necessary to track down the various
           technical issues that bubble up from time to time. 
           They are assigned to one of these committees who are
           given responsibility to put something together to
           address this thing, come up with an industry position
           on them.
                       It's a very active organization.  Not only
           do they meet three times a year, not only do they
           produce these guidelines which, by the way, are looked
           at for revision about every other year and, I think,
           pretty much have been revised about every other year. 
           They only put out interim guidance, if necessary, on
           various issues that come up.
                       Specifically, about a year or so ago, they
           issued two -- Well, one was an interim guidance on in
           situ pressure testing that came out of the
           pressurization ramp rate issue that was a result of
           the ANO situation about a year or two ago.  The other
           one was a general lessons learned from IP-2 and ANO. 
                       That group has continued to be involved in
           this pressurization ramp rate study we took which came
           out of ANO.  We did more work on it, made some
           evaluation, tried to decide what this really meant: 
           WAs there a ramp rate?  What was it due to?  All that
           was falling under the STMP.
                       CHAIRMAN FORD:  Jim, quick question.  
                       MR. RILEY:  Yes?
                       CHAIRMAN FORD:  Was there a peer review on
           these EPRI documents, guideline documents?
                       MR. RILEY:  The way that these guideline
           documents are revised is an ad hoc committee is
           selected from within the TAG who are given the
           responsibility of developing the revision.  Then the
           revised document is reviewed by the entire TAG.
                       CHAIRMAN FORD:  Not outside people?
                       MR. RILEY:  Beg pardon?
                       CHAIRMAN FORD:  Not outside people?
                       MR. RILEY:  I believe there is some amount
           of outside involvement in that, too.  For example, on
           the Rev 6, which we are going to be talking about, the
           NRC has had a chance to look at that.  The vendors
           have had a chance to look at it.  The NSSS
           organizations have had a chance to look at it.  So
           it's given a wide review.
                       CHAIRMAN FORD:  I'm thinking more of
           uninterested parties.
                       MR. RILEY:  Well, no, I don't believe
           uninterested parties are involved.
                       CHAIRMAN FORD:  Yes, you're right.
                       MR. RILEY:  No.  Then it's approved
           through the structure here.  The senior reps, the IIG
           itself signs off on these documents before they go out
           and are used by the industry.
                       MR. SHACK:  Jim, while we are on this, we
           seem to be focusing on the inspection issues here and
           the frequency.  There were some other issues that the
           staff had beyond the leak rate when you did the
           condition monitoring, just how the tubes were selected
           for the condition monitoring.
                       Has all that been resolved?
                       MR. RILEY:  No, it hasn't been resolved,
           but it is being addressed.  I can talk about that, if
           you would like.  In fact, I was kind of thinking we
           might get into some of this.  So I made some extra
                       I think what you might be referring to is
           the steam generator action plan.  Are you?  There were
           a bunch of issues that were identified by the steam
           generator action plan and, as luck would have it, I've
           got some stuff you guys can take a look at, and I can
           talk about this for a minute.
                       As you know, about a year ago or so, the
           NRC issued their Steam Generator Action Plan.  That
           was kind of a consolidation of various lessons learned
           and other things that came out of the IP-2 event.
                       I think, if I was to categorize the issues
           that came out, we could lump them into these kind of
           areas:  Assessment of degradation mechanisms -- what
           do you do about new degradation mechanisms, how do you
           assess them, what kind of process do you have to have
           in place to assessment?  What about hour glass, and
           what do you do about those?  What are the implications
           of all these things?
                       CHAIRMAN FORD:  Before you go, just to
           make sure we've got our definitions right, to me,
           steam generator action plan refers to the NRC.  Is it
           the same thing we are talking about?
                       MR. RILEY:  That is the same thing we are
           talking about.  A whole number of items were
           identified.  Twenty-seven of them were shown as things
           that the industry was supposed to be doing something
                       You take those 27, and you kind of pigeon-
           hole them.  These are the pigeon holes we came up
           with, and this is nothing new to Ted, of course. 
           We've been working with Ted and with Emmett and Louise
           and others on this.  In fact, I think this was
           Emmett's characterization of how these things would be
           pulled together into bins, if you want to call it
                       Anyway, NDE data quality, NDE
           qualification, NDE data analysis for all issues that
           were identified as part of the Steam Generator Action
           Plan.  All of those are being addressed as part of
           this Rev 6 work on the steam generator exam
                       We are talking about inspection intervals. 
           That's kind of what we are focusing on today, but all
           these other things are also being looked at on Rev 6,
           and Rev 6 has a lot of new information on these other
           aspects.  Hopefully, a lot of this is going to be
           cleared up when we get Rev 6 finally issued.
                       Pressure testing:  There were some
           questions that came out of the action plan on what do
           you do about cases where you've got leakage that
           exceeds the test equipment?  How do you go about
           performing some kind of an analysis to decide whether
           you had a burst or whether you didn't have a burst,
           and how do you establish the criteria, and all that.
                       That's all being looked at by an in situ
           test ad hoc committee.  I mentioned earlier, these
           committees are set up to revise these guidelines on a
           biennial basis.  That guideline is up for revision,
           and that committee has already been formed, and it is
           looking at those particular issues and, hopefully,
           will be addressing them and, hopefully, resolving them
           as part of the upcoming revision to the in situ
           pressure test guidelines.
                       Operational assessment:  That gets right
           into inspection intervals, of course, and there's
           other questions that were involved in the Steam
           Generator Action Plan for operational assessment.  We
           have an Integrity Assessment ad hoc Committee, and
           this one is a little bit different.  Even though its
           name might imply that they are looking at a revision
           to the integrity assessment guidelines, their scope is
           a little bit broader than that.
                       What they were trying to do is get the NDE
           community together and the integrity assessment 
           community together and come up with better tools for
           making those two communities talk to each other and
           come up with better results for steam generator
           inspections, better operational assessments, etcetera.
                       That committee is also ongoing right now,
           and is addressing the operational assessment issues as
           part of what they are looking at.
                       Then finally, the other bins that we've
           talked about here, tech specs and NEI 97-06 initiative
           implementation, feedback NRC, that's all being handled
           as part of the Generic License Change Package
           basically by the Steam Generator Task Force, the
           people that you are seeing in this room.
                       MR. SHACK:  I get confused gain about
           where NRC reviews, what tier documents, what changes. 
           Suppose in your operational assessment you wanted to
           change the probability of detection.  Is that an NRC
           reviewable change?
                       MR. RILEY:  No, except for the fact that
           the NRC takes a look at your operational assessments
           as they see fit based on their inspections of your --
           their review of your steam generator inspections. 
           PODs, etcetera, I believe, come off the ETSS sheets,
           do they not, which -- and those sheets, the equipment
           -- I'm going to fail on the name.  But basically, they
           are the sheets that define the capabilities of the
           different NDE techniques, and they are controlled by
           a QA program within EPRI and the NDE Center that talks
           about what are the critical parameters of this
           particular NDE technique that you want to use and the
           kind of performance you can expect out of them.  All
           that kind of rolls up into a POD.
                       Now the issue of POD, though, is a good
           one, and the industry is also struggling with what do
           we do about POD, how do we make it better.  That's
           part of the Integrity Assessment ad hoc Committee
           that's meeting right now, too.
                       If you want some details on it, we can
           probably give it to you, because we got the right
           people in this room to talk about it.  But in general,
           that's --
                       MR. SHACK:  I was more interested this
           time as to whether that was within  your bailiwick to
           change or they had to review that.
                       MR. RILEY:  That's our bailiwick.
                       Okay, regarding the Action Plan issues,
           back to these bins, if you will, I mentioned that
           there were 27 industry issues that were identified. 
           We have written up an initial response on all 27 of
           those and provided them to the staff.  That was done
           the early part of the summer.
                       We have gotten comments back on a number
           of them, not quite all of them, and we are addressing
           revisions to them right now.  The revisions to these
           are tied up -- When I say tied up, I don't mean to use
           it from the sense of being stopped, but they are
           wrapped up with the work that is ongoing on cycle
           lengths, the work that are ongoing with these various
           ad hoc committees.
                       We have reached resolution on, I think,
           about three or four of them.  The others are active. 
           They are ongoing, but they are not resolved yet.  So
           it's part of the continuing effort.
                       One thing you need to keep in mind with
           all of this is we are talking about having a target in
           mind for completion of the Generic License Change
           Package, but it doesn't mean industry is going to quit
           working with the NRC at the time the GLCP is done.
                       The industry has a commitment to continue
           working with the NRC on technical issues as they
           arise.  Some of these have already been identified. 
           We are already working on them, and we are going to
           resolve them.  They may not get resolved at the same
           time the GLCP is done, but they will continue to be
           worked on.
                       The Steam Generator Task Force isn't going
           anywhere.  It will still be around.  It will still
           work with the staff, and will continue to address new
           issues as they come up.  These are the ones that we
           have in place right now.
                       CHAIRMAN FORD:  So coming from, for
           instance, the work that is being done at Argonne or
           the work that is being done in the various tasks, one,
           two and three, in the action plan within the
           NRR/Research, they will just -- There will be a living
           document.  These guidelines will be living documents. 
           They will change?
                       MR. RILEY:  Definitely living documents,
           and they will change as time goes on and new
           information is identified.  The SGMP has got the
           responsibility for keeping those things up to date,
           and like I said, they look at them every other year.
                       So I'd like to skip through, because I
           really talked about most of these slides up to Slide
           14, which provides a summary of what I've said.  But
           I guess this is the message I want to leave you with
           here with respect to the industry steam generator
                       It is a highly active, running all the
           time organization, and does address issues promptly. 
           The SGMP, as a matter of fact, had people at TMI
           helping with TMI's evaluation of what went on with
           their tube sever issue.
                       We've got a TAG meeting that is coming up
           in a couple of weeks.  We intend to have
           presentations.  We will have presentations from TMI,
           what went on there, just for an example.  That's
           pretty recent stuff, and we've already got people
           involved with it.
                       At this TAG meeting we are going to be
           sitting down with the folks who are doing the Rev 6
           work.  We are going to be talking about what are all
           these comments we've gotten from the industry and the
           NRC.  They have been dispositioned to some point.  We
           are going to talk more about what the final
           disposition of these is.  
                       It's a vibrant organization.  We have
           broad utility participation in this organization from
           across the country and EPRI, in general and in the
                       We make a particular effort to encompass
           all the different steam generator designs within these
           different organizations.  The IIG, for example, they
           make a real effort to make sure they have folks in
           there who have an understanding of all the different
           steam generator designs.  So we got a good, broad
           perspective on it.
                       They know about the guidelines and the
           policies.  They've been talking about them.  The peer
           reviews:  We have that going on through INPO.  As
           well, NEI 97-06 suggests peer reviews within its own
           framework, separate from INPO.  That also takes place
           within SGMP when people use each other's expertise to
           look at aspects of their program, help them get things
           set up, help them maybe do a little bit better on this
           part or some other part.
                       The organization interfaces to the NRC
           through us, and maintains research and improvement
           efforts all the time.  
                       So that's the issue.  Anymore questions on
           what the industry is doing here with respect to this? 
           I want to get into a little now about what is this
           regulatory approach all about.  How did we get here,
           and what does it mean?
                       As you probably know, the original
           approach from the regulatory perspective was to put
           out a rule.  How am I doing on time?  Do I need to
           hurry this up or am I okay?  
                       CHAIRMAN FORD:  Was your plan to go from
           -- You are currently on this Item 3.  Is that right?
                       MR. RILEY:  Yes, and I can skip over as
           much as this as you want, and we can make it as quick
           as you want.  You wanted to spend some time on that
           one.  So I spent more than I was planning to.  When do
           you want me to be done, though?
                       MR. DUDLEY:  In about three minutes.
                       MR. RILEY:  Three minutes?  All right. 
           Well, let's not talk about history then.  
                       CHAIRMAN FORD:  No more history.
                       MR. RILEY:  Okay.  No more history.  Let
           me talk a little about 97-06, because it's essential
           to this thing.  97-06 is a document that's put out by
           NEI.  It establishes the framework for a steam
           generator program.  
                       It's an overall guidance document.  It
           does not provide the details.  The guidelines provide
           the details, but NEI 97-06 provides the direction.  It
           contains a lot of key issues, basically the whole
           aspect of what is a steam generator program and what
           does it consist of.
                       The next slide already talks about the
           guidelines that are included within it.  I want to go
           into the initiative a little, because it's very
                       Revision 0 of 97-06 was put out in 1997,
           I guess, as its name might imply.  That was followed
           by an NSIAC initiative, and this is really important. 
           I told you what NSIAC is.  When NSIAC decides to look
           at what they call a formal initiative, they take a
           vote on some policy.  
                       Eighty percent of the chief nuclear
           officers in this country agree with this policy.  That
           policy becomes a commitment to all the chief nuclear
           officers in the country, and this is the commitment
           that was voted on in 1997.  It's in italics and in the
                       "Each licensee will evaluate its existing
           steam generator program and, where necessary, revise
           and strengthen program attributes to meet the intent
           of the guidance provided in NEI 97-06, Steam Generator
           Program Guidelines, no later than the first refueling
           outage starting after January 1, 1999."  
                       In fact, 97-06 has been implemented at all
           the plants, and it is part of the driving force behind
           all this industry involvement that we see and
           commitment to working together to make our programs
                       97-06 is also a living document.  It's
           been revised once, I think you mentioned earlier, in
           January of this year.  We are working on Rev 2 right
           now.  The intention of both these revisions is to keep
           it up to date with what the industry sees in the way
           of a steam generator program, what we discuss with the
           NRC, what new issues come up and get resolved.
                       I can move through the rest of these with
           almost saying nothing about them.  I told you about
           TAG.  This is just a reemphasis of the fact that we
           have a lot of things going on with respect to
           communications, that the industry is talking to each
           other.  People are aware of what is going on at other
           plants, and we do so through the TAG organization in
           the SGMP.
                       We already know, I think, about the
           Generic License Change Package.  We are in the middle
           of revising it.  I will say a little bit about some of
           the issues that are going on with it.  You know, or
           maybe you don't know so I'll take a minute to tell
           you, that the License Change Package really is, as its
           name implies, everything you need to change your
           license to be in compliance with this regulatory
           framework we are developing.  
                       It includes the regulatory framework.  It
           includes the steam generator tube integrity tech spec,
           which basically says you will maintain steam generator
           tube integrity and, if you have reason to believe you
           got a problem with it, you got actions to take, and
           you got surveillances to perform to verify that indeed
           you do have integrity that involve inspecting and
           plugging your tubes at certain intervals.
                       It has a bases associated with it, a
           fairly detailed one that goes into a lot of
           information on what we've done over the last couple of
           years with the NRC to pull this thing together to give
           people an understanding of where all these
           requirements came from.
                       It includes change to the operational
           leakage tech spec which you know governs primary,
           secondary leakage.  In fact, it requires 150 GPD
           primary, secondary leakage level, which is a change
           from what a lot of folks have in their tech specs
           right now, and it reflects what we have discussed with
           the NRC and what's in the primary, secondary leak
                       It includes admin tech specs to place
           controls on certain key elements of the program.  In
           fact, the issue of regulatory control of inspection
           intervals is going to be resolved through this admin
           tech spec.  We are looking at how do we change
           performance criteria, repair criteria, repair methods
           and, in this case, inspection rules going forward.
                       Basically, what this sets up is a means to
           do so.  The NRC wants to have a part of the approval,
           wants to approve these changes if they occur.  Once
           they have approved them, if they have approved them
           generically, others can use them.  But it kind of
           keeps things under control with respect to these key
           elements.  That's in the admin tech spec.
                       It also includes significant hazards
           evaluation, safety analysis.  The intent is that, when
           this is approved, it will be clipped.  If you are
           familiar with the clip process, which basically it
           puts something out there for everybody, and other
           plants can use it a lot quicker and avoid the whole
           license amendment -- avoid the time involved in the
           difficult license amendment process.
                       We hope to be able to clip the Generic
           License Change Package when it's done, so plants will
           be able to implement it relatively quickly.
                       Real quick here, inspection rules:  We are
           going to be talking about later, there's two aspects,
           as Ted said.  There is a regulatory control issue, and
           there is a technical issue.
                       I think, with our meeting yesterday, we
           are on the same beam with respect to regulatory
           controls.  Technical issues still need to be worked
           out.  We are going to talk to you about what we are
           doing on inspection intervals.  We are working with
           the NRC on their comments.
                       So in general, I believe we've got a real
           commitment within the industry to perform -- to make
           our steam generator performance as good as it possibly
           can be.  It's living.  It's viable.  It's continuing,
           and we are very proud of it, actually.
                       That's it.  Questions?
                       CHAIRMAN FORD:  Just to make -- so that I
           am sure, as far as being proactive with what we do,
           you are saying that -- I'm sure, Ted, you will jump in
           and tell me if I'm wrong -- that you are agreed on the
           regulatory aspects.  Therefore, unless we decide
           otherwise, do we just forget about regulatory aspects? 
           So it's only the technical issues from this point on
           that we are interested in, the inspections of those --
           these are the things that we are mainly interested
           from this point on?
                       MR. SULLIVAN:  Yes, and I might note that
           the tech specs currently contain controls on
           inspection intervals.  So we are not inventing
           something new here.  It's more that we are carrying it
           over into the new framework.
                       We weren't initially intending to do that,
           but because of the concerns that the staff has with
           the performance based approach, we want to carry that
           over until we get those issues fully resolved.  And
           I'll discuss a little bit more, or whoever is going to
           give this presentation will discuss a little bit more
           some of the flexibility we are trying to build into
           this admin tech spec so that we won't have to revise
           the tech specs yet one more time to get rid of these
           prescriptive maximum inspection intervals.  That is
           covered later on.
                       CHAIRMAN FORD:  I noticed in the timing,
           in the majority of the time left we are going to be
           hearing primarily NRR's views on these technical
           issues.  And there's only ten minutes for the NEI to
           argue against them.  Is this what the wish was?  I
           mean, so we get a balanced view?
                       MR. DUDLEY:  That's really up to you.
                       CHAIRMAN FORD:  Well, the question is, has
           NEI got the veto in the arguments?  I know you guys
           have gone through this backwards and forwards quite a
           few times.  Do you all have the data upon which these
           technical issues are being argued backwards and
                       MR. RILEY:  We have an explanation of the
           details of our guidelines on inspection intervals.  We
           didn't come here with a lot of detailed technical data
           on the NRC comments.  As a matter of fact, we are
           still dispositioning their comments and developing
           that technical data right now.
                       CHAIRMAN FORD:  That's the things to do in
           early next year.  Is that right?
                       MR. RILEY:  Well, yes.  That's the thing
           that we believe we want to have this guideline on the
           street by the middle of next year, and our intent is
           before that time that we will have responded to not
           only the NRC comments but also the internal industry
                       CHAIRMAN FORD:  So in your comments and
           the NRR comments, we will hear both sides, what they
           say and then what you dispute?
                       MR. SULLIVAN:  I think so, and I think I
           want to just add one thing and see if Jim Riley agrees
           with me.  When Jim was talking about putting together
           the information in the time frame of the first -- you
           know, between now and the middle of 2002, that's
           information to address staff comments and their own
           comments on inspection intervals.  But over a longer
           time period, I believe industry and the NRC are going
           to be working together on other -- on technical issues
           associated with the performance based approach, which
           are issues that I'm going to touch on in this
           presentation somewhat topically.
                       CHAIRMAN FORD:  Okay.  So if we ask
           technical questions, you can both jump in.  Yes?
                       MR. SULLIVAN:  That's true.
                       CHAIRMAN FORD:  Okay, let's roll.  Thanks,
                       MR. RILEY:  Thank you.
                       MR. SULLIVAN:  Okay.  The fall-back plan
           was that I was going to start this presentation.  But
           since Emmett is here, Emmett, you came in at the
           perfect time.  Now could you help us understand the
           time frame here?  Emmett is going for how long before
           the break?
                       MR. DUDLEY:  Right now, about half an
                       MR. SULLIVAN:  Okay.  We are on schedule.
                       CHAIRMAN FORD:  Emmett, would you like to
           -- Would it help you if we took a ten-minute break now
           let you regain your breath?
                       MR. MURPHY:  To collect my thoughts?  I
           wouldn't mind.
                       CHAIRMAN FORD:  Excellent.  Okay.
                       (Whereupon, the foregoing matter went off
           the record at 9:29 a.m. and went back on the record at
           9:41 a.m.)
                       CHAIRMAN FORD:  Emmett, if you would like
           to start, we would appreciate it.
                       MR. MURPHY:  Okay.  Well, thank you.  
                       In September we briefed the Subcommittee
           on the Steam Generator Change Package, describing some
           background, outstanding issues, that kind of thing. 
           The Subcommittee expressed a desire to be briefed on
           additional details of the outstanding issues in the
           proposed resolution.  So that is why I am here today.
                       I will jump quickly ahead perhaps to the
           punchline of all of this, and that is there has been
           in recent days and weeks considerable progress toward
           reaching some sort of conceptual agreement on a
           resolution path for resolving these issues and moving
           on with the review of the Generic Change Package.
                       Now just to have for purposes of a
           perspective on the revised generic framework that is
           being proposed, it's helpful to remember where we are. 
           I don't think we have talked about this for a couple
           of years.
                       Existing requirements are highly
           prescriptive.  Basically, you are required under
           existing tech specs to inspect a specific number of
           tubes at specific intervals, and you plug the
           defective tubes that you find at a prescribed plugging
                       Typically, under the tech specs plants are
           implementing a 24 calendar month inspection interval. 
           That can be extended to 40 months, to the extent that
           there's not really a whole lot going on in your
                       MR. KRESS:  Why not 48?
                       MR. MURPHY:  These numbers date back to 
           the -- basically, to the mid-Seventies.  Their origin,
           prescribed origin and basis is obscure, but clearly --
           Well, we'll just leave it there.
                       CHAIRMAN FORD:  When you say degradation
           activity is minimal, is there a metric to do that?  I
           mean the number of cracks or the depth of cracks?
                       MR. MURPHY:  Yes, there is a metric in the
           tech specs, precisely how many flaws that would get
           you above a threshold beyond which you do more
           frequent inspections and more inspections in general.
                       MR. SHACK:  What is a guy with the 690
           steam generator actually doing at the moment?
                       MR. MURPHY;  It varies.  Some now are
           beginning to implement the 40 months, take advantage
           of the 40 months interval allowed in the tech specs. 
           Historically, there were not many plants ever that
           were able to take advantage of that, if for no other
           reason, even if corrosion hadn't started yet, you
           know, wear problems would --
                       MR. SHACK:  Got nailed by something?
                       MR. MURPHY:  So it's only been in recent
           times that plants are really able to begin to take
           advantage of this 40 month interval, and that's, you
           know, plant with replacement generators with the more
           modern designs that minimize wear problems.
                       MR. SHACK:  Now what are they doing with
           sample sizes, for example
                       MR. MURPHY:  Sample sizes they do in
           accordance with the guide -- Well, they meet the tech
           specs, of course.  That's no problem.  The driving
           force is what the EPRI guidelines say.
                       MR. SHACK:  Okay, right.  Right.  So they
           are all committed to that.  
                       MR. MURPHY:  Yes.  Just one other
           observation I think that's important to make is that
           tech specs don't speak at all to inspection methods: 
           Eddy current, how do you do eddy current.  There are
           code requirements with respect to how you do eddy
           current, but the improved inspection performance
           through the years has really been driven largely by
           technology improvements and improved industry practice
           in accordance with industry guidelines.
                       I guess the point I wanted to make here is
           that these are prescriptive requirements.  Their
           origin is obscure.  There aren't -- One might ask do
           these ensure that you maintain tube integrity.  They
           don't force you to ask yourself am I inspecting
           frequently enough?  Are the flaws that I'm finding
           during inspection within a comfort zone that I'm
           assured that I am maintaining adequate tube integrity? 
           The existing tech specs don't force you to ask that
                       So one might ask then where are we from a
           safety perspective today?  The available evidence is
           that steam generators are generally operated with
           acceptable safety margins, consisting with the
           licensing basis.
                       MR. KRESS:  What does that mean?  What
           exactly does that mean?  
                       MR. MURPHY:  It means that typically, to
           the best of our knowledge, steam generators are
           operating while meeting margins of three with respect
           to a burst under normal operating pressure.
                       MR. KRESS:  Three with respect to --
                       MR. MURPHY:  Yes.  I mean, you know, we
           might see one or two plants a year out of the fleet
           that are -- during an inspection we find that they
           have challenged that criteria.  But in the main,
           plants typically do not trip this criteria during
           their operation.  But, of course, there are
                       We would argue that they appear to be
           relatively isolated occurrences.  Exceptions include,
           but are not limited to, the eight SGTR events that
           have occurred.  There are other events besides SGTR's
           where we don't degrade to the point of failure, burst
           during normal operation, but you know, you don't have
           the margins you would like to have.  
                       A recent example is TMI with the wear
           associated with the severance of a plugged tube.  The
           other example recently was Arkansas Unit 2 where again
           they didn't have a tube rupture during normal service,
           but they didn't have the margins that -- the margin 3,
           for example, at the end of the operating cycle.
                       So you know, available risk studies
           indicate that from an industry-wide perspective the
           risk is within acceptable levels.  As you know, there
           is ongoing work in this area as part of the SG Action
           Plan, in part responding to some of the concerns that
           ACRS has with respect to risk, steam generator risk.
                       MR. KRESS:  Remind me what an acceptable
           level is.
                       MR. MURPHY:  I'm not sure.  I can't give
           you the precise numbers, but acceptable levels in
           terms of the available estimates on the core melt
           frequency and LERF.  Both those considerations were
           looked at.  The best --
                       MR. KRESS:  In reg guide 174?
                       MR. MURPHY:  Forgive me?
                       MR. KRESS:  The values in Reg Guide 1.174?
                       MR. MURPHY:  Yes.  Yes.  The available
           risk studies today would indicate that risk from steam
           generator related events are not a significant
           contributor to core melt risk or LERF.
                       Steve, do you want to add to that?
                       MR. LONG:  This is Steve Long with the NRC
           staff.  I think I understood your question was related
           to the slides saying that the risk studies have
           indicated that the risk from SG related causes are
           within acceptable levels.
                       MR. KRESS:  Basically, what?
                       MR. LONG:  We've been doing PRAs for
           sometime, and steam generator tube rupture since -- It
           really wasn't included in WASH 1400, but since then
           it's been there.  It's been a fairly small contributor
           to the core damage frequency, but it's been one of the
           major contributors to the off-site consequences. 
           That's what attracts our attention to it, to try to
           make sure that we maintain adequate control of the
           tube integrity, because we don't want that number to
           go up.
                       We have accepted the numbers we've been
           finding.  In terms of whether or not we would like to
           see changes in them, that usually gets into a backfit
           consideration:  Is the change worth the cost in terms
           of dollars or operational exposure or whatever?
                       As late as NUREG 1570 in the middle of the
           1990s, we were looking at what we thought the risk
           was, including the severe accident risk and what we
           thought some of the changes that the industry was
           requesting at the time might mean in terms of severe
           accident risk and other risks.
                       I think we continue to conclude that with
           the regulatory framework we are trying to  enforce now
           that the risk is pretty much where we have thought it
           was and accepted in the past, which is probability of
           core damage that is in the low 
           10-6 range from all the degradation mechanisms, and a
           probability of -- The definition of LERF is kind of
           hard to deal with -- a combination of core damage with
           containment bypass through tube failure.  It's in the
           10-6 range.
                       We've been accepting that all along.  So
           I guess that is our definition, at least, of something
           that is so far acceptable.  
                       MR. BONACA:  Those are the values we
           looked at for the BPR in the NUREG?
                       MR. LONG:  Now in 1570 we also looked at
           what might be the implications for some things like
           allowing steam generator tube leakage during
           depressurization transients to go maybe 100 BPM or
           higher.  We concluded we didn't know enough to say
           that that would remain acceptable.  We needed to know
                       So we think what we are enforcing now is
           acceptable.  We are not sure about some of the things
           that would be economically beneficial to allow but
           maybe not acceptable safety if we allowed them.  
                       MR. MURPHY:  Thanks, Steve.  Okay.  safety
           record to date reflects two things.  One, it does, to
           some extent, of course, reflect existing requirements,
           and we would argue, in particular, it reflects the
           tight requirement on inspection intervals that
           currently reside in the tech specs.  
                       Arguably, if that's all there was, that
           would have been sufficient, that clearly, a very
           significant factor in the overall safety record of
           steam generators through the years have been industry
           initiatives that have been and guidelines embodied in
           industry guidelines that have resulted in industry
           actions in excess of minimum requirements.
                       These industry practices have resided in
           industry guidelines.  Some of the more powerful
           influences on experience through the years have been
           the water chemistry guidelines and SG examination
           guidelines.  These have had a tremendous influence
           through the years in reducing the level of --
           minimizing corrosion problems or reducing them to
           levels that we experienced early on, and resulting in
           the application of more sensitive eddy current
           inspection methods toward detecting these problems and
           detecting them early.
                       MR. KRESS:  What message are we supposed
           to get from that, that industry takes it seriously?
                       MR. MURPHY:  The industry takes it
           seriously, but I think that one of the things we are
           getting to -- where's my previous slide?
                       MR. KRESS:  The one just before?
                       MR. MURPHY:  What we are going to do --
           What has been proposed is to -- We are going to
           eliminate current requirements, and essentially we are
           going to rely on a framework that is built around
           industry guidelines.
                       So then the question is:  Is a regulatory
           framework built around industry guidelines -- is that
           adequate to do the job?  to what extent has the safety
           record to date been a function of both?  Actually, we
           think it's been a function of both, and when we move
           to the new regulatory framework, we have to keep in
           mind what's been helping us out in the past, make sure
           that we are adequately covered in that respect.
                       One of the major issues in this respect,
           I think, is the 24 month inspection interval.  It's
           only been just recently the industry issued its tube
           integrity assessment guidelines, guidelines allowing
           you to predict how much safety margin you have now
           based on your inspection results and to predict where
           you are going to be at the time of your next
           inspection, how much safety margin you are going to
           have -- or tube integrity margin you are going to have
                       We think that these guidelines need
           further development before they going to be fully
           effective.  I think the major concerns, not the only
           concerns but the major concerns at this point, are the
           ability to project, based upon current inspection
           results -- the ability to project where you are going
           to be tube integrity-wise at the time you do your next
                       Okay.  So we are on to -- Under the
           proposed, industry proposed Generic Change Package, we
           are essentially going to delete the existing
           prescriptive requirements and replace them with this: 
           "An SG program shall be established and implemented to
           ensure SG tube integrity performance criteria are
                       MR. KRESS:  Integrity performance criteria
           -- Could you spell out what those are?
                       MR. MURPHY:  Yes, I'll get -- As a matter
           of fact, I'll give you a brief summary of what those
           performance criteria look like, but the performance
           criteria are identified in the SG Program which is
           outside of the tech specs.  They are also identified
           in NEI 97-06.
                       MR. KRESS:  Are they the same for every
                       MR. MURPHY:  They will be -- In general,
           they will be the same for every plant.  There is an
           admin tech spec that says that, if people want to
           implement different performance criteria, they have to
           come to NRC for review and approval.
                       The details of the SG Program, of course,
           as Ted talked about in September during the earlier
           meeting with you -- Details of that program are
           outside of tech specs, and these programs will
           generally be developed in accordance with the industry
           guidelines that we talked about earlier.  But the
           admin tech spec will require periodic condition
           monitoring of the tubing relative to the performance
           criteria every time you do an SG inspection.  This
           requirement, of course, does not specify how
           frequently you will be inspecting or how frequently
           you will be doing condition monitoring.
                       Basically, this is a performance based
           approach.  Performance criteria are identified. 
           Periodically,  you are assessing the condition
           relative to this performance criteria.
                       The performance criteria we've talked
           about in past years with this Subcommittee. Just as a
           brief refresher, they include -- Under the heading of
           structural criteria, they include maintaining a factor
           of three against burst under normal full power
           operating conditions.  Also includes maintaining a
           factor of 1.4 against burst for accident conditions. 
                       That's the structural criteria.  There's
           also an accident induced leakage criteria, which is
           applied to the population of tubes.  Under this
           criteria accident leakage from the population shall
           not exceed that assumed in the licensing basis
           accident analysis.  In addition, it should not exceed
           a number such as 1 gpm, which is normally assumed in
           the licensing basis, except as approved by NRC.
                       This criteria is intended to ensure that,
           even if one is using a number within the licensing
           basis, one is not using a number that might have
           potential risk implications, that if you are going to
           -- If your leakage criteria is going to be 1 gpm, you
           need to be risk informed, and that's what this
           criteria is about.
                       There are a number of plants out there,
           for example, that utilize -- that have done accident
           analyses to justify leakage numbers on the order of 15
           gpm, 20 gpm, under accident conditions.  
                       These numbers are consistent with
           maintaining a small fraction of Part 100, those
           limits, during a design basis steam line break.  But
           we also had to -- You know, the staff determined that
           provided this leakage was coming from -- that the
           calculated leakage was coming exclusively from cracks
           at tube support plates, that there shouldn't be any
           severe implications.
                       It wouldn't be acceptable, for example, to
           have free span cracks leaking at this amount, the
           difference being that actual leakage under steam line
           break conditions from cracks at the tube support
           plates are believed to be substantially less than what
           were calculated.
                       CHAIRMAN FORD:  Before you move on, do I
           understand that these are the criteria that are
           currently in the 97-06 Rev 1?  
                       MR. MURPHY:  That's correct.
                       CHAIRMAN FORD:  And you approve of it, and
           no problems at all with these?
                       MR. MURPHY:  These criteria were arrived
           at through a consensus reaching process with industry. 
           So I guess it would be fair to say we negotiated these
           criteria with the industry.
                       CHAIRMAN FORD:  So when I see in the
           various memoranda a question about the factor of 1.4,
           for instance, that as of today is no longer an issue?
                       MR. MURPHY:  No.  We were recently
           informed by NEI that one or two of the NSSS vendors
           who were asked to comment had a potential difficulty
           with the 1.4 as it applies to differential thermal
           stresses, and that they may seek a proposed refinement
           or revision to this criteria.  Maybe this criteria, in
           their mind, needs some clarification.
                       Other than being alerted to the fact that
           there's a potential issue here, we have not been --
           The industry has not submitted their position, their
           revised position, on this point yet.
                       So to the extent that -- You know, we
           expect that the industry is going to come at us in a
           few weeks and say, look, we have these comments with
           respect to that criteria, and this is what we think we
           need to do about it.
                       CHAIRMAN FORD:  But what is the technical
           basis for your approving these criteria, and also the
           operation that you speak of, I think, has changed, is
           it not, from 500 to 150?
                       MR. MURPHY:  Well, as I said, you know, we
           -- The criteria, as they exist as of this point, were
           believed -- They were developed with the belief that
           they were consistent with the existing licensing
           basis.  For example, we believe that they were
           consistent with the safety factors that went into the
           development of the 40 percent plugging limit in the
           existing tech specs.
                       So the dogma behind the development of the
           performance criteria was to try to maintain
           consistency with the structural margins and the
           leakage margins that we have been maintaining all
           along, not to cut back relative to those margins.
                       That was the goal.  That was the goal
           behind the development of the performance criteria. 
           Now there's a suggestion out there that perhaps we
           didn't quite succeed with respect to all the
           applications of the 1.4 safety margin for accidents.
                       It's a little bit early for me to react to
           that until I see exactly what kind of position the
           industry is developing on this.  But this is -- You
           know, this was something we arrived at a couple of
           years ago, and --
                       CHAIRMAN FORD:  I guess I keep coming back
           to next week when you make a presentation at the full
           Committee of the ACRS.  Do I take it that those lists
           of things you've got up there -- there's a sound
           technical basis for having approved them?
                       MR. MURPHY:  Yes, I think they are
           conservative.  I think there's, you know --
                       CHAIRMAN FORD:  So if someone on the full
           Committee asks, well, where is your data to justify
           that approval, that could be shown?
                       MR. MURPHY:  We would certainly be
           prepared to discuss the basis for these performance
           criteria, and I think the industry concern with
           respect to the 1.4 is that, with respect to
           differential thermal stresses, the safety factor is
           over-conservative, that we need to --
                       CHAIRMAN FORD:  I guess we are taking a
           lot on faith here.  We've really been asked as a group
           here to put our signature that, hey, this is okay, and
           yet we have seen no evidence that it is okay.
                       MR. BONACA:  I have a question on that, if
           I may.  Accidents that you are talking about, I mean,
           what conditions are they assuming to measure against
           at a 1.4 factor?  Could you put up that slide again?
                       MR. MURPHY:  Yes.  
                       MR. BONACA:  Seems now that number is
           supposed to be conservative.  What puts that an
           accident?  I mean, any accident, any over-pressure?
                       MR. MURPHY:  Any design basis --
           typically, main steam line break is the most limiting
           accident when dealing with steam generator tubes, and
           typically the main loading that needs to be considered
           for that condition is differential pressure that may
           exist across the tubes, typically on the order of 2500
                       For plants such as -- For B&W type
           generators, tubes also tend to experience a high
           degree of tension with respect to -- you know, during
           the cool-down part of the transient.  These are
           thermally induced stresses.  
                       The code requirement for faulty
           conditions, of course, were not -- The code equations
           or the code limits apply to primary stresses, not to
           secondary stresses.  There's some question as to what
           this 1.4 means with respect to the treatment of axial
           stresses in B&W tubes.
                       If one applies this -- It's maintained at
           applying this directly to -- To thermal stresses, it's
           over-conservative.  There needs to be a different
           treatment with respect to thermal stresses, and this
           is the issue I think the industry wants to take up
           with us.
                       MR. SULLIVAN:  It might be worth it to tie
           this into the ASME code also.  We're getting a little
           bit of question about the soundness of these criteria. 
           They originally came from the code.
                       MR. MURPHY:  Yes.  There is an assumption
           -- There's an assumption in the design rules, Section
           3 design rules, that a one-time application of thermal
           stress cannot lead to component failure, and that's
           fully appropriate for design conditions.  But if we
           are talking about a long tube with a circ crack under
           a significant axial load, a thermally induced axial
           load, that may no longer be an appropriate assumption
           to make.
                       That is, a large axial load, thermally
           induced axial load, could well --
                       CHAIRMAN FORD:  What would the likelihood
           of there being such a thermally induced axial load be?
                       MR. MURPHY:  Oh, it will occur.  
                       CHAIRMAN FORD:  So, in fact, that is not
           necessarily -- If you want to put a probability
           against it, that criteria is not absolutely safe.  I
           don't know  how you qualify that, but it could occur. 
           You could get burst even by maintaining that criteria
           of a factor of 1.4.
                       MR. MURPHY:  Actually, I think what is
           being maintained is -- and we haven't heard the
           position yet from the industry, but I think what is
           being maintained is that applying this factor to a
           different thermal load leads to overconservatism.
                       CHAIRMAN FORD:  I guess that's the nub of
           my question.  We are being asked to -- or the
           Committee will be being asked next week to say, hey,
           yeah, we bless this.  But you have already said that
           that is not an absolute guaranty that you will not get
           a catastrophic 360 degree burst.
                       MR. MURPHY:  No.  I think that --
                       CHAIRMAN FORD:  Therefore, what would the
           consequence of that be?  I need guidance from my
           colleagues here.  Am I pushing this too much?
                       MR. SHACK;  Well, I think the answer you
           are looking for is that those factors really come out
           of the implied factors that are in the code.  Those
           are kind of the implied structural integrity factors
           that the code has.
                       Now the code didn't really mean to sort of
           imply them to defective -- You know, the code assumes
           that you didn't have defective structures.  So this is
           kind of a pseudo ASME limit, but that was really the
           intent of the code, was to provide a significant
           margin against burst under normal conditions, which is
           three, and then under accident conditions, which are
           presumably not going to occur nearly as often.  They
           were willing to back off, and so they came down to the
                       Now the question is:  Typically, the code
           has different allowances for thermal stresses for
           secondary stresses than they do primary stresses,
           simply because a little bit of deformation relieves
           the secondary stress.  I guess the question here is
           whether you are going to -- They are nominally
           treating this differential thermal expansion now as a
           primary stress when you apply the 1.4, I guess, is the
           argument that you are getting.
                       MR. MURPHY:  Yes.
                       MR. SHACK:  Whether that's appropriate or
                       CHAIRMAN FORD:  But for an non-defective
           tube, you said.
                       MR. SHACK;  Even for a defective tube, you
           know, the -- I would argue that the three and the 1.4
           come from code limits.  Now the discussion as to
           whether this applies to the differential thermal
           stress sort of has to come back to a discussion of
           whether you think in this particular case the
           differential thermal stresses are acting like
           secondary stresses or they are acting like primary
                       You know, we normally think of thermal
           stresses as being secondary stresses, but sometimes
           there is a -- they act a whole lot like primary
           stresses, and sometimes they don't.  So that's
           presumably the discussion that comes in as to whether
           you maintain this on the differential thermal stresses
           or not.  But the factors of the three and the 1.4 are
           essentially derived from the code.
                       CHAIRMAN FORD:  What I would suggest is,
           rather than belabor this an take up all the time,
           bearing in mind that we will be talking next week
           about this whole thing in a condensed fashion, you may
           well be asked a question, what is your technical basis
           for making this approval, and the ASME code were
           based, I understand, on undefected tubes.  So --
                       MR. MURPHY:  Let me just give you this
           answer.  I think it's the same answer I'll give next
           week.  These limits were intended to be consistent not
           just with the licensing basis as well as the original
           design basis of the tubes in Section 3 of the code. 
           The margin criteria here were derived from the Section
           3 stress limits, even though the stress limits are
           developed -- are to be used for design space, and we
           are applying these to an operational situation where
           the components have cracks.
                       I think the way these criteria presently
           read -- The performance criteria, I think that they
           represent a conservative set of criteria with respect
           to accident situations.  I think what we are going to
           hear from the industry in the future is that they are
           over-conservative with respect to how one ought to be
           treating thermal stresses and that maybe the 1.4 will
           continue to be applied to primary stresses in the
           tubing, that perhaps we need to do something --
           consider the differential thermal stresses in a little
           bit different way, not applying this factor of 1.4.
                       CHAIRMAN FORD:  Well, I think there's been
           some tests done, have there not been, on burst
           pressures for defective tubes?  Can you not use that
           data as support for this contention, and also to
           support industry if that is going to be their argument
           that these original curbs are overconservative?  I'm
           trying to help you in terms of convincing an
           independent review body.
                       MR. MURPHY:  Well, I think there's a lot
           of test data with respect to the burst strength of
           tubing and how it varies with the size of the flaws
           and the orientation of flaws in the tubing.  There's
           certainly a lot of data there.
                       I think the available body of evidence is
           that the sort of safety margins that we are talking
           about, the factor of three and the factor of 1.4, are
           generally sufficient safety margins that through the
           years have been successful in minimizing any safety or
           risk implications with the actual condition of the
                       So that the safety margins appear to be
           sufficient based on experience.  The goal is being
           consistent with the code.  Yes?
                       MR. LONG:  Can I add one other thought. 
           This is Steve Long with the NRC staff again.
                       You had asked earlier in the presentations
           about severe accident issues.  One of the things that
           we are counting on to maintain the tube integrity
           during severe accidents are these margins.
                       So when we think about the adequacy of the
           margins, we need to think about them with regard to
           all the challenges that relate to the risk equations,
           and some of those are higher than normal operating
           temperature and various delta P's.
                       So when you get into whether or not this
           is overly conservative or maybe not quite conservative
           enough for some reactor designs which get to fairly
           high temperatures in the tubes during severe
           accidents, we are not quite sure yet.
                       For some of the designs it looks like
           we've got enough margin here.  Maybe for some we don't
           quite have enough margin at three times normal
           operating pressure as the strength requirement for
           normal operating temperatures.  
                       So it's a little more debatable than it
           would sound when you just stuck to the design basis
           conditions.  We are still doing research to try to
           nail it down a little bit better.
                       CHAIRMAN FORD:  Recognize where I'm coming
           from.  I'm coming from an ACRS member that's been
           asked to stamp your conclusions, not having seen the
           detailed technical case you have made for making those
           conclusions.  I don't doubt you have a good argument,
           but this makes you feel good to see some data that
           backs up -- as a back-up.  Have a back-up slide next
           week to show that, hey, you've thought about this.
                       MR. BONACA:  I have just one last question
           I want to ask about this.  The guidelines -- They
           consider the possibility that you have -- during the
           cycle.  Okay, not necessarily a similar break.  But
           you have cool-downs and heat-ups.
                       MR. MURPHY;  Yes.
                       MR. BONACA:  And they will place some
           stress on the tubes, and will it affect the
           temperature in some way?  I mean, there are
           considerations of that in the guideline? 
                       MR. MURPHY:  Well, of course, the design
           rules in Section 3 consider that.  You have the 
           different service level stress limits.  In fact, years
           ago when discussing with the industry what the
           performance criteria should look like, we had proposed
           that there should be different safety factors,
           dependent upon whether we were talking about service
           level A, B, C type loadings.
                       The industry maintained that that would be
           going beyond the existing licensing basis, that if one
           looks at the 40 percent plugging limit, and if one
           looks at the factors of safety that are implicit in
           the 40 percent plugging limit, that while those
           factors of safety -- while you are maintaining a
           factor of safety of three with respect to operation at
           normal full power steady state operation, that in fact
           during a heat-up, cool-down or other operational
           transient, you might actually have less than a factor
           of three.
                       Apart from the performance criteria
           themselves in NEI 97-06, the guidelines -- the
           industry guidelines go into additional detail about
           how licensees should assess structural integrity.  it
           talks about consideration of these other operational
           transients, making sure, for example, that you don't
           exceed the no yield criterion.  
                       You  know, you need to -- These are -- and
           I guess one might say, to some extent, these criteria
           that I presented on the previous slide are sort of the
           criteria that the guidelines do contain additional
           details about the kinds of evaluations people should
           do to assess structural and leakage integrity.
                       CHAIRMAN FORD:  Emmett, I noticed you've
           skipped one slide.  Would you mind going back to the
           steam generator program, a request, actually.  I
           understood from Jim's earlier comment that the second
           bullet that makes reference to detailed EPRI
                       Could I suggest that maybe you have a sub-
           bullet in there making note of the fact that they
           agree that these are living documents.  I'm aware that 
           -- environmental degradation in the whole light water
           reactor business.  We are forever learning, and new
           data will come along, and those EPRI guidelines are a
           living document.
                       MR. MURPHY:  All right.  
                       CHAIRMAN FORD:  It would be worthwhile
           pointing this out, because if you come back to this
           thing in ten years' time, there could be --
                       MR. MURPHY:  All right.  Point taken.  in
           fact, I was going to get into that a little bit later.
                       CHAIRMAN FORD:  Oh, okay.  Fine.
                       MR. MURPHY;  But at this point, obviously,
           I am going to be reconstructing this presentation as
           I go along.
                       CHAIRMAN FORD:  That would have been
           helpful there.  That's the first thing I want to say.
                       MR. MURPHY:  Here it is.  Okay.  So we are
           going to have an admin tech spec that says you are
           going to implement a program to ensure that the
           performance criteria maintained, and you are going to
           periodically condition monitor the tubing to ensure
           the fact that you are meeting the performance
                       This is really an embodiment, in our mind,
           of criterion 16 of 10 CFR 50, Appendix B, namely,
           which specifies that measures shall be established to
           ensure that conditions adverse to quality are promptly
           detected and corrected.
                       Condition monitoring programs must be
           capable of meeting this requirement.  They've got to
           be able -- Condition monitoring programs have to be
           able to promptly detect the condition of the tubing
           which was not meeting performance criteria.
                       Performance criteria, of course, should
           represent tolerable conditions, if one is in a
           performance based -- implementing a performance based
           strategy, and that is -- we hold that that is true
           also for the performance criteria that are part of
           this Generic Change Package.  But this is all premised
           on the fact that, if you do exceed these performance
           criteria, that that kind of condition is promptly
                       To the extent that you continue to eat
           away at your safety margins after you have exceeded
           the performance criteria, at some point, you know, you
           are getting into a difficulty from the safety
           perspective.  So it's critical that condition
           monitoring be capable of promptly detecting such
                       So the question for us, the staff, as we
           look at the Generic change Package is:  Is there
           enough here, not just with respect to the admin tech
           specs but with respect to the industry guidelines,
           that give us assurance that the programs, the SG
           programs the utilities will be implementing will be
           able to promptly detect and correct such conditions.
                       I would like to move on to slide 11
                       (Slide change.)
                       MR. MURPHY:  The current version of the
           EPRI guidelines with respect to examination
           requirements is Rev 5, which was issued in 1997.  They
           provide for two different approaches, potential
           approaches, for determining the appropriate cycle
                       One is a prescriptive approach, which is
           not all that different from what we have today under
           existing requirements.  In general, you inspect every
           fuel cycle unless you've had minimal problems, in
           which case you can go for two cycles.
                       There is also conceptually in Rev 5 a
           performance based approach that says that you can use
           operational assessment to look ahead and determine how
           long you can operate the steam generators before you
           predict that you would exceed the performance
           criteria, and then you would set your inspection
           interval on that basis, but the inspection interval
           could not exceed two fuel cycles.
                       So that is the current version of the 
           industry guidelines, and in that respect they are not
           too different from where we are today with existing
                       I'm going to skip the next few slides.
                       CHAIRMAN FORD:  Just to -- I'm trying to
           tie it in with what Jim was saying.  He said that this
           essentially -- What you say here is essentially not
           the 97-06, and Jim said 97-06 is already applied.  Is
           that correct?
                       MR. MURPHY:  NEI 97-06 is already being
           implemented by utilities.  Utilities are also -- As
           part of that effort, even before NEI 97-06, utilities
           have been implementing these examination guidelines,
           and since '97, of course, they have been implementing
           Revision 5 of the examination guidelines.  
                       CHAIRMAN FORD:  And they are not going
           against the original regulatory prescriptive formulas?
                       MR. MURPHY:  Correct.  That is correct. 
           And so they are subject to the criteria of the
           guidelines.  In addition, they are subject to
           regulatory requirements.  Where we're going with this
           presentation is industry basically wants to move from
           Revision 5 to Revision 6 of the guidelines.  That is
           going to allow for longer operating intervals.  Okay?
                       So to get there, industry needs this
           revised regulatory framework, because right now they
           are constrained by the regulatory requirement for 24
           month to a 40 month inspection interval, and they need
           -- they would like to dispense with that.
                       With respect to the ability of condition
           monitoring to fulfill its Appendix B obligation, there
           are a number of guidelines that are relevant to that
           capability.  One of them is the examination
           guidelines, of course.
                       Also the tube integrity assessment
           guidelines which give guidelines for doing operational
           assessments, guidelines for doing condition monitoring
           assessments are relevant.  Also industry guidelines
           with respect to in situ pressure testing, which is a
           component of condition monitoring, are relevant to the
           capability of condition monitoring to fulfill its
           Appendix B obligation.
                       (Slide change.)
                       MR. MURPHY:  I'm at Slide 15.  
                       CHAIRMAN FORD:  Just to make sure that I'm
           calibrated. So far we haven't heard anything -- You
           haven't touched on any of the technical issues that
           currently exist.  Is that correct?
                       MR. MURPHY:  That's correct.  It had not
           initially been our intent to formally review or to
           endorse the sub-tier detailed EPRI guideline documents
           such as the examination guidelines, the tube integrity
           assessment guidelines, that kind of thing.  
                       It had been our expectation that the
           guidelines would be sufficiently well developed to
           lead to improved tube integrity performance within the
           context of the new regulatory framework being
           proposed.  We knew that there were going to be issues,
           outstanding issues, with respect to the guidelines,
           but these issues were issues that have existed all
           along.  These are not issues introduced by the new
           framework and issues that are not unique to the
           revised framework.
                       It was our expectation -- I think this
           responds to one of the questions earlier -- that the
           guidelines would continue to evolve over time.  They
           are living documents in response to identified issues,
           technology changes, lessons learned from operating
           experience, and the results of industry and NRC
           studies, such as the NRC SG round robin study, the
           action plan including the work that's being done to
           address some of the ACRS comments with respect to the
                       Findings from all of these activities will
           influence the future course of these guidelines over
           time.  There's no question about that.  
                       MR. SHACK:  Have you formally reviewed
           your Revs 3, 4, 5 with respect to inspection
                       MR. MURPHY:  We never formally reviewed
           the guidelines.  We always read the guidelines, tried
           to know what's in there, but they were never submitted
           for our formal review and approval, and we have never
           gone through a formal process like that with respect
           to the guidelines.
                       MR. SHACK:  But an inspector sort of
           accepts them as an acceptable Appendix B approach to
           quality assurance for the examination?  Is that your
           regulatory tool for looking at these procedures?
                       MR. MURPHY:  In general, in today's
           regulatory -- under today's regulatory requirements,
           the plants are not inspected relative to the
           guidelines.  Their adherence to the guidelines is an
           industry initiative. 
                       Now in a case such as Indian Point where
           it became clear that past inspections leading up to
           the failure at Indian Point were not as effective as
           we would like to have been, we certainly looked at
           utility actions with respect to industry guidelines
           prevailing at the time the last inspections were
                       If one is making judgments about the
           reasonableness of licensee actions at any point time
           in time, you know, questions of how well they are
           adhering to available guidance may be relevant in that
                       Okay.  We knew there were going to be
           issues with respect to the guidelines.
                       MR. BONACA:  Could I ask just one thing? 
           I know we already talked about Slide 8, and I want to
           go back to the criteria.  As I reflect on this,
           clearly, a much higher burden is being placed on the
           criteria than ever before.  Before you had intervals
           that were based on the prescriptive.  
                       There was some relationship between, for
           example, the first criteria and the interval, but it
           really wasn't so tied together; because you had
           prescriptive intervals by which you were inspecting
           the plant.
                       Now you are performance based. Really, it
           seems to me that they are going to set the intervals,
           testing, inspection frequency based on these criteria. 
           So I think it is very important for next week that we
           get a real understanding about the adequacy of the
           criteria --  So why do you feel they are acceptable?
           -- and adequacy of what you have to do to measure that
           to the criteria.  
                       What I've seen for the past three or four
           slides is that they clearly will be able to set their
           pace for inspections based on some way in which they
           measure that they in fact exceed the 1.4 burst
           pressure for transients or -- There is a lot of burden
           placed on this criteria now.  Formerly,  there wasn't.
                       You know, I never thought of this criteria
           as a burden on them.  I never felt that way, because
           they were like, yeah, the code says that.  But really,
           you do the inspection at a given time, and that's all
           that's important.
                       Now everything is going to depend on these
           criteria.  So how credible are they as criteria, and
           I'm sure they are, and what ways do they propose to
           measure to those criteria?  Are they acceptable ways
           to measure or are we going to have other stuff coming
           to us without an understanding?
                       MR. RILEY:  Can I say something to that? 
           This is Jim Riley from NEI.
                       Maybe this might clarify it a little bit,
           and Mohamad is going to provide a lot more detail. 
           Our guidelines have two ways of establishing the
           inspection rules.  One is a prescriptive based method,
           and the second is performance based.
                       What we are discussing as part of the
           Generic License Change Package right now, and what the
           NRC has comments on are prescriptive based inspection
           intervals which do specify intervals.  They are a
           little longer than what is currently in there, but
           they are still defined intervals.  It's a function of
           the steam generator tubing materials.
                       They have to be supported at the same time
           by an operational assessment.  So they lay out the
           specific lengths of time, but you have to be able to
           show by an OA that indeed you can make those -- that
           length of time.
                       Rev. 6 also includes a performance based
           inspection interval, which is along the lines of what
           you are discussing now.  The length is purely
           determined by how good you can do at predicting where
           you will be at one time with respect to the
           performance criteria.
                       The initial version of the Generic License
           Change Package will not be adopting those performance
           based intervals.  it will be the prescriptive based
           intervals that we are focusing on.  We do want to use
           those performance based, but we recognize we have more
           work to do in terms of developing the justification
           with the NRC.
                       MR. BONACA:  I appreciate you are doing it
           in a step-wise way, but since you are going in that
           direction, try to answer and focus the question next
           week.  You know, a lot of burden is placed on these
           criteria, and it is going to be.  All right.
                       MR. MURPHY:  Okay.  
                       MR. SHACK;  Just a moment.  You know, one
           of the things that's always puzzled me is that you
           guys have been doing these operational assessments,
           monitorings now for umpty-ump years, and we never see
           comparisons of how well you are doing.  If you
           condition monitoring said that, you know, the largest
           crack was going to be something or other, your
           condition monitoring said --
                       MR. MURPHY:  Well, Bill, actually, on one
           of the next few slides here, that very point is made. 
           That is one of the issues that we have identified as
           being something where -- one area where the guidelines
           can be improved, a better benchmarking of operational
           assessment relative to what you actually find later on
           in revising -- you know, the feedback loop, and
           refining the models based on experience.
                       I was going to get into a lot of details
           of the issues that currently reside in the guidelines. 
           Suffice it to say for purposes of this morning's
           discussion that we believe that there are a lot of
           areas where the guidelines can be improved and be made
           more effective.  And I would just like to leave it at
           that and move on.
                       CHAIRMAN FORD:  When you say the
           guidelines, these are the ones that you are going to
           talk about?  Okay.  Since there are issues, I'm not
           too sure what order you should go.  After you give
           your talk, Emmett, will you give a presentation on
           your issues of this Rev. 6?
                       MR. MURPHY:  I was going to push on to --
           What was proposing to do now was to not get into a
           discussion as planned on issues relating to the
           guidelines that were more general than the Rev.  6
                       I would rather at this point just move on
           to Rev. 6, and simply point out that, quite apart from
           Rev. 6, there are a number of issues that exist with
           respect to the industry guidelines that we need to
           work through the years in firming up, making it 
           better and more effective.
                       (Slide change)
                       MR. MURPHY:  During an NRC sponsored
           senior workshop in February of 2001, industry
           representatives made a presentation on work being done
           to prepare a Rev. 6 of the steam generator examination
           guidelines, and they caught our attention with their
           plans for revising the inspection criteria for the
           steam generator, particularly with respect to steam
           generators with Alloy 600 thermally treated and 690
           thermally treated tubing, primarily the tubing in
           replacement generators, that they anticipated
           substantially longer inspection intervals than what
           exist either in current regulatory requirements or in
           Rev. 5 of the guidelines.
                       At the time of the February meeting, the
           prescriptive criteria they were proposing would have
           provided for inspection intervals on the order of five
           to six effective full power years with respect to
           Alloy 600 thermally treated tubing and six to seven
           effective full power years for 690 tubing.
                       There's been considerable interaction of
           the NRC with the industry over the intervening time. 
           More recently, the industry has revised this 
           proposal, and now would include a two-cycle limitation
           with respect to inspection intervals for 600 thermally
           treated tubing and a three-cycle limitation, fuel
           cycle limitation, with respect to 690 tubing.
                       (Slide change)
                       MR. BONACA:  How do you go to from five to
           six or six/seven to two or three.  Seems such a
           disparity of opinion.
                       MR. MURPHY:  Well, you know, this bears
           mentioning.  A fuel cycle in this country generally 
           ranges anywhere -- depends on the plant -- from 12
           effective full power months to 22 effective full power
                       So maybe 18 is -- One might say 18 is
           typical.  So a two-cycle limitation for the 600
           thermally treated tubing is quite a bit less than the
           five to six effective full power years we're talking
           about here.
                       CHAIRMAN FORD:  Now this is what you will
           be talking about, the arguments for these?
                       MR. BEHRAVESH;  Yes.
                       MR. MURPHY:  And when will you be doing
           that, Mohamad?
                       CHAIRMAN FORD:  After you.
                       MR. MURPHY:  That's right.  This is your
           -- Okay, I understand.
                       Okay.  Under the performance based
           approach, the Rev. 6 would have dispensed with the
           two-cycle limitation and, basically, the inspection
           intervals could be as long as whatever could be
           supported with an operational assessment or
           degradation assessment.
                       Just based upon curves that are applicable
           to the anticipation of corrosion mechanisms, we were
           talking about inspection intervals potentially ranging
           up to 20 years or so, assuming that something like
           wear wasn't a more imminent concern.
                       So, clearly, here at this point, what we
           saw was that there were going to be future changes to
           the guidelines where there were going to be
           potentially substantially longer inspection intervals
           than we had contemplated up to that point.  Then the
           question for us was is there sufficient guidance
           available to the industry to ensure that condition
           monitoring will take place frequently enough to
           promptly alert us to situations where we don't meet
           the performance criteria.
                       CHAIRMAN FORD:  I'm a little bit confused
           by these two, both 20 and 21.  Do I understand it,
           Rev. 6, there are two criteria, a prescriptive
           criteria and a performance based criteria?
                       MR. MURPHY:  There are two different
           strategies, yes, for determining --
                       CHAIRMAN FORD:  And you get your choice,
           or what?
                       MR. MURPHY:  Yes.  Well, I think what the
           industry had envisioned as they were developing these
           guidelines was that, you know, we are moving to a
           performance based regulatory framework, and that the
           implementation details in the guidelines ultimately
           should be performance based as well.  I think that was
           the thinking.
                       Now they did have prescriptive criteria
           available, and you would still have to do condition
           monitoring and operational assessments to demonstrate
           that those prescriptive intervals were consistent with
           meeting the performance criteria.  You would still
           have that obligation, but the performance based
           approach allowed you to actually set the inspection
           intervals consistent with -- to make it as long as you
           could, consistent with meeting the performance
                       CHAIRMAN FORD:  And you will going through
           the realism as to why you would choose one over the
                       MR. BEHRAVESH:  Yes.
                       CHAIRMAN FORD:  And it will be plant
                       MR. BEHRAVESH:  Mohamad Behravesh, EPRI. 
           I will be touching on all of these, realizing that all
           of that will be done within the time span of ten
                       CHAIRMAN FORD:  Okay.  
                       MR. SHACK:  Let me be clear now.  Are the
           prescriptive criteria an option or they are a cap on
           the performance assessment?
                       MR. MURPHY:  No, they are not a cap.  The
           way the guidelines are written, utilities have a
                       MR. SHACK:  Oh, they have a choice.
                       MR. MURPHY:  They can implement the
           prescriptive criteria or the performance based
                       MR. BONACA:  When you talked about
           possibly ranging to 22 effective full power years --
           well, maybe you will be talking about that.  So I'll
           withdraw my question and wait.
                       (Slide change.)
                       MR. MURPHY;  Okay.  Our concerns with
           respect to what is being proposed for Rev. 6:  We
           believe that appropriate inspection/condition
           monitoring intervals are critical to ensuring the
           prompt detection of conditions not meeting performance
                       We are concerned that certain of the 
           guidelines, the tube integrity assessment guidelines,
           aspects of the in situ test guidelines, and the
           examination guidelines, are not sufficiently well
           developed to support inspection intervals
           significantly longer than what is being implemented
           under current requirements or other acceptable
           alternatives, which I'll be talking about.
                 Further, industry may -- You know, the industry
           proposal in February kind of revealed a vulnerability
           we had of our regulatory framework -- of the proposed
           regulatory framework, namely, even if we reach
           agreement on what the guidelines say, industry may
           revise the guidelines down the road, and we are not
           going to review an approval loop on that.
                       Further, licensees themselves may not
           follow the guidelines.  They may deviate from those
           guidelines.  They can do that.
                       We need to be assured that the regulatory
           framework -- We need to be assured that condition
           monitoring will be capable of fulfilling its Appendix
           B obligation.  Got to be able to promptly detect
           conditions that are not meeting the performance
           criteria, and we've got to be assured that that's the
                       (Slide change.)
                       MR. MURPHY:  Okay.  I've talked about the
           fact that we have numerous issues relating to the
           guidelines that affect the tube integrity assessments. 
           Further, we believe that the guidelines for
           operational assessment of active degradation
           mechanisms are not sufficiently developed to be used
           as a tool for directly determining acceptable
           inspection interval extensions.
                       Further, degradation assessment guidelines
           and the technical bases for these guidelines have not
           been developed for ensuring that the initial
           occurrence of new degradation mechanisms will not
           cause performance criteria to be exceeded.
                       Historically, degradation assessments have
           not really been -- People haven't been doing
           degradation assessments in this way.  It is assumed --
           The current regulatory basis -- The current
           requirements, prescriptive requirements, assume that,
           if we have a new degradation mechanism, that the
           prescribed inspection interval will ensure a timely
           detection of that new mechanism, and it will be
           maintaining the appropriate margins.
                       If plants are to operate for many years
           between inspections, we now have to reckon with the
           potential that there may be a degradation mechanism
           about to initiate and to progress, and there will need
           to be some ability to determine when such degradation
           mechanisms might occur and over what period of time
           that might begin to challenge the performance
                       Right now, the guidelines do not contain
           a lot of detail about how to do this, and there's not
           much in the way of a technical basis for what guidance
           is there at the present time.
                       Finally, the draft inspection interval
           strategies for Rev 6 of the examination guidelines are
           being -- they are still being finalized.  They are
           still dealing with industry comments as well as NRC
           comments.  They have lacked critical details, and the
           technical justification has not been provided to NRC
                       MR. BONACA:  When you say operational
           assessment and you are talking about condition
           monitoring inspections, tell me the difference.  I
           mean, what is included in an operational assessment?
                       MR. MURPHY:  An operational assessment is
           a forward look which, based upon what you know about
           the condition of the generators today and what you
           believe the corrosion rates are or the flaw growth
           rates are, where do you anticipate you will be
           relative to the performance criteria at the end of
           your inspection interval?
                       Condition monitoring is looking backwards: 
           Did I -- Based upon the inspection results, did I
           succeed over the last cycle in maintaining adequate
                       Both of these assessments are dealing 
           with known mechanisms, active mechanisms.  You project
           where you are going to be in an operational assessment
           with the degradation mechanisms that you know are
           taking place, and you don't account in an operational
           assessment for degradation mechanisms you haven't seen
                       MR. BONACA:  I was reflecting.  On page 21
           where you have the 22 effective full power years, and
           now we are talking about operational assessment. 
           Okay, we'll talk about it later.
                       (Slide change.)
                       MR. MURPHY:  Okay.  Staff has interacted
           extensively with the industry and proposed a
           resolution path.  We believe that predictive
           methodologies for managing known degradation
           mechanisms and for anticipating the occurrence of new
           mechanisms need to be strengthened to support
           implementation of inspection intervals significantly
           exceeding current requirements or acceptable
                       We plan to work with the industry in
           identifying the needed improvements to the guidelines. 
           In the meantime, inspection intervals  -- We believe
           that inspection intervals should be subject to
           appropriate limitations based on experience and
           consideration of the improved stress corrosion
           performance expected with the 600 thermally treated
           and 690 thermally treated tubing.
                       Such acceptable approaches might include,
           for example, limitations similar to what we currently
           have in tech specs in the way of operating intervals,
           or other potential alternatives such as perhaps the
           criteria that are being developed in the context of
           Revision 6 of the guidelines.
                       We have commented extensively on the early
           drafts of the guidelines.  Industry is considering
           those comments as they work on Revision 6 of the
           guidelines with respect to inspection intervals, and
           we would hope that this work will lead to something
           that we think ensures that inspections -- that through
           the condition monitoring process we will be able to
           promptly detect conditions that are inconsistent with
           meeting the performance criteria.
                       (Slide change.)
                       MR. MURPHY:  Apart from the technical
           issue as to what constitutes an appropriate inspection
           interval, the staff has concluded there must be
           appropriate regulatory controls with respect to
           inspection intervals to ensure that the performance
           criteria are maintained, that conditions failing to
           satisfy these criteria are promptly detected and
           corrected, and that risk is not increased.
                       (Slide change.)
                       MR. MURPHy:  So staff proposed an
           additional criterion for inclusion in the admin tech
           specs, which would basically specify that no changes
           relative to a reference inspection interval criteria
           that we have reached a consensus on -- that no changes
           to such a criterion could be made without NRC review
           and approval.
                       So you know, as industry refines the
           guidelines, ultimately perhaps coming out with a
           rigorous performance based approach for determining
           how long inspection intervals can be, they would  have
           to come at NRC with such a proposal and get our review
           and approval before licensees would be able to
           implement such a approach.
                       CHAIRMAN FORD:  Could I suggest -- I've
           just been flipping through the remaining ones you have
           and looking at the time.  It seems to me that your
           last four or five overviews are primarily just
           recording some of the history of the industry and the
           NRR responses to this.
                       I think that should be given -- It's
           factual, but it doesn't add to the debate, technical
           debate, that we have going on, what the issues are,
           outstanding issues.  As I understand it, we have re-
           raised the issue about the 1.4 and the factor of three
           for defective tubes.  We are not too sure the depth --
           the technical basis behind that agreement.
                       The other one, the big outstanding one, is
           this whole question of the performance based
           inspection.  Periodicity is the big, outstanding 
           technical issue.  Am I correct?
                       MR. MURPHY:  No, we don't believe that the
           guidelines support as yet a performance based strategy
           for setting inspection intervals, but not only that. 
           The guidelines are not yet able to support
           prescriptive criteria that are vastly different from
           what is being implemented today.
                       So it's both.  We have concerns about some
           of the initial proposals that were made with respect
           to prescriptive criteria, as well as having concern
           about the performance based.
                       CHAIRMAN FORD:  We've seen verbally on
           your overgraphs what some of your concerns were on
           those two issues, the prescriptive and the performance
           based inspection interval.  Could I suggest, looking
           at the time, I want to leave at least -- We have one
           more hour.  I want to leave at least quarter of an
           hour for subcommittee members just to give their
           opinions about how you can enhance the presentation
           for next week, and I want to have as much time as
           possible to hear your views on the really outstanding
           issue, which is the inspection.
                       So would you mine, Emmett, yielding the --
           I'm getting real good at this parliamentary language
           here -- yielding the podium to our friend to hear
           their arguments?
                       MR. SULLIVAN:  Dr. Ford, I wonder if I
           could just add a minute or two.  I'm not sure if this
           will be useful, but --
                       You know, I hear the comments that have
           been made by several members about your concern and 
           interest in the adequacy of the performance criteria,
           and I don't think that comes as a complete surprise. 
           I know Emmett and I over the years have had a number
           of conversations expecting interest in that area.
                       We didn't really come today prepared to
           talk about that in detail, and I think what I'd like
           to do is just try to shed a little bit of perspective
           on why.
                       I think that there are two points, one 
           Emmett really wasn't able to get into because of the
           time crunch.  He slipped over Slides 18 and 19, but
           those particular slides talk to performance standards
           for applying the performance criteria.
                       Performance criteria are -- You know, I
           think your point about the increased emphasis in the
           performance based approach on those criteria is very
           well taken.  But there is also a lot of importance
           into what standards you use to apply those criteria.
                       I'm not an expert in talking about this. 
           Emmett could explain more maybe this time or some
           other time, but depending on how you apply those
           performance criteria, you can get vastly different
           results, vastly different levels of assurance of tube
           probability -- tube burst probability.
                       So that's an important area of emphasis
           that we've placed in some of the comments that we have
           made to industry.  We haven't focused on defending the
           criteria, but we have focused on what are the
           performance standards that you need to be assured that
           those criteria are even being met.
                       Then the other part, I think, that Emmett
           hit on quite well, although there are more details in
           the slides, there are a number of comments we have
           about the way the integrity assessments are being
                       So these are all connected or
           interconnected issues with the bottom line of the
           performance criteria, and I think what we are  trying
           to say is we are looking at all of it.  We will try to
           be prepared next week to talk to some of the issues
           you have specifically emphasized, but we think there's
           a lot of importance on looking at the entire picture
           of how are you actually going to do these assessments,
           what standards are you going to apply to show that you
           meet these criteria.
                       MR. BONACA:  Okay.  That was  the question
           that I asked about.  Clearly, the issues are what's
           the basis for the criteria, and that doesn't bother me
           as much.  I mean, insofar as margin, we could discuss
           what margin you need, but it is margin there.  
                       The main question is the one, how do you
           measure up to the margin?  What do you have to do to
           demonstrate that you meet the performance criteria?
                       MR. SULLIVAN:  Yes, I agree, and that's a
           lot of what we are focusing on.
                       CHAIRMAN FORD:  Okay.  Could I ask you to
           give your presentation.  If you could take about half
           an hour, no longer, if possible, and then you could
           jump in with the relevant concerns you have.
                       Emmett, you had a whole lot of verbal
           concerns.  Maybe you could just jump in.
                       MR. SULLIVAN:  We'll be glad to interrupt
                       MR. BEHRAVESH:  It won't be the first
           time.  I am Mohamad Behravesh from EPRI.  I think the
           nature of my presentation probably would have to be
           changed a little bit based on everything that we have
           heard and the questions that were raised, but I'd like
           to set the stage very, very quickly for you as to what
           the issues are.
                       In all the discussions that went on this
           morning, you will find out that one topic comes up to
           the surface, and that is the inspection interval.  It
           is not to say there aren't other issues, but that is
           the one that stands out as the primary one.  
                       So this is the inspection interval, and
           within that there were two other issues kept coming up
           as the prescriptive inspection, as well as the
           performance based.  Okay?
                       So I'll first put prescriptive based, and
           then I'll put performance based.  Have these two
           things in mind.  As we stand here as of now, the law
           of the land still is what is in everyone's technical
           specification as of now, regardless of everything that
           has been said, and that says that you do a three
           percent sampling of your steam generator tubes, and
           you make sure that no steam generator goes more than
           40 months without being looked at -- 40 months.
                       So as of now, this is the law of the land. 
           This has been the case even 20 years ago; it was also
           the case.  Clearly, as far back as late Seventies and
           early Eighties, it was recognized that this was
           clearly inadequate, clearly inadequate.
                       CHAIRMAN FORD:  I guess my math must be
           rusty.  If you inspect only three percent of your
           tubes, how can every tube be inspected in 40 months?
                       MR. BEHRAVESH:  Good question.  They
           won't.  It won't, unless --
                       CHAIRMAN FORD:  That's what you just said.
                       MR. BEHRAVESH:  No, no, no.  I said, if
           you do sampling, you do 30 percent, you are also
           obligated to make sure that steam generator doesn't go
           without being looked at in more than 40 months.  If
           you don't find degradation, you may go for a long time
           and never see.  And by the way, there is no
           stipulation in there that says this has to be a
           different three percent.  You could be looking at the
           same three percent.
                       So, yes, the question is that it is
           possible that it would never get looked at all of
           them.  Now this was -- has been the case all along, as
           early as late '79, early Eighties.  And unlike the
           other components like pressure vessels and piping, you
           didn't have much guidance in the ASME either.
                       Now the ASME has lots of guidance on how
           to do the rest of the inspection, how to do piping,
           but has been kind of silent and inadequate on steam
           generator.  So that brings me to the point of what
           industry started doing, recognizing that they started
           developing their own set of guidelines, help, for
           doing inspection.
                       The first one of it came out in 1981, was
           revised as a formal EPRI report in '84, had benefitted
           from a lot of industry support by 1988, getting
           support from and input from all the NSSS, and then we
           added the performance demonstration requirement,
           meaning qualification of techniques and personnel and
           so forth for '92, went to prescriptive sampling.
                       One of the reasons for going to
           prescriptive sampling was that, in the absence of a
           lot of information, how can you suggest something to
           a large group of people that covers all the issues and
           would be adequately conservative and still would keep
           you within a safe margin?  So that was the impetus
           behind prescriptive sampling.
                       Then we went forward in 1997, and we put
           a very strong language in terms of all the so called
           guidance and recommendations which has made it into
           "shalls."  So these set of documents really became de
           facto requirements as far as the industry was
                       It wasn't -- Although the name says
           guideline, in reality it is a requirement.  This is
           what the industry has been living with for the last
           20-some years, and the point that I want to get across
           to you is that everything that goes in here is
           experienced based, time tested, field tested, and well
           rehearsed, and result has been used from one revision
           to the other revision to get us here.  This is the so
           called Revision 5 that the industry is currently
           following now.
                       CHAIRMAN FORD:  Is it all prescriptive?
                       MR. BEHRAVESH:  All prescriptive.  Also I
           should add that, even in this revision, we have
           allowed for performance based, recognizing that in
           order to do performance based examination, you need to
           have a lot of smarts to do performance based.  You
           can't just go and predict something.  
                       You have to have a lot of data from your
           past history that guides you into future to enable you
           to say that I can go this length of time without
           running to any problem, recognizing that to do
           performance based you need a lot of information.  In
           practice, no one has picked this up in doing
           performance based.  Everyone is doing prescriptive,
           because that's where their comfort zone has been.
                       Again, remember that the prescriptive
           based, by the nature of its name, is conservative as
           well in order to cover everyone.  
                       Now the time frame is now late Nineties. 
           These guidelines had a provision in them that they say
           that they need to be looked at in order to see whether
           they need to be revised every two years or not.  But
           something else was happening along this time, not that
           this was inadequate.
                       The guideline has really served the
           industry quite well.  What we came to recognize is
           that it was beginning to be very unfair to those
           utilities who had made multi-million dollar
           investments in going to new materials and new designs,
           and this document as it stood did not recognize that
           and did not allow that.
                       Now again something to remember, that all
           of this, regardless of what recommendations are in
           here, still must operate within this.  Sure, you can
           exceed that.  There is nothing to stop you from doing
           100 percent, 20 percent inspection.  This cannot be
           violated even as of today.  Cannot be violated.
                       The whole point of going to this license
           change package and to these guidelines and all that is
           that it is time to revise this, because this is unfair
           to the new generators.  So this is the whole point of
           going through this revision and requesting the
                       Now I mentioned to you the new materials. 
           Surely, the new materials, they are not all the same,
           but in a nutshell the revision of this guideline,
           which is in the works now -- it has been in the works
           for over a year now and it is up for review.  
                       In a nutshell, it is separating these
           materials, 600 mill annealed, 600 thermally treated,
           and 690, and saying that 600 mill annealed should be
           looked at every outage.  This is no different than
           what is happening right now.  This is no different
           than what we have in Rev 5.
                       It is allowing more leeway for 600
           thermally treated, saying they should be looked at
           every other outage at least, and for 600 thermally
           treated it says every third outage. 
                       In a nutshell, this is what is different
           in Revision 6 from all the things that has been in the
                       CHAIRMAN FORD:  But that looks very
           arbitrary to me.  I mean, 600 TT and 690 TT have
           failed at the mill.  So why those multiples?
                       MR. BEHRAVESH;  Let's go and see.  
                       MR. BONACA:  So the only change would be
           the third one, I guess, 690 TT.
                       MR. BEHRAVESH:  And 600 thermally treated,
           right now.
                       MR. BONACA:  Okay.  So you went from
           prescriptive to prescriptive.
                       MR. BEHRAVESH:  Prescriptive to
                       MR. BONACA:  And the only change, really,
           was for the 690 TT.
                       MR. BEHRAVESH:  That is correct.  So if
           you go into a little bit more detail, things have now
           -- in Revision 6 have gotten more prescriptive in that
           in 600 mill annealed, 100 percent of the tubes in each
           steam generator must be completely inspected in 60
           effective full power months.
                       Remember, there is nothing of such here in
           tech specs.  They should be inspected at every
           refueling outage, and in our -- it has been since our
           Revision 4 of the guideline.  To us, you don't do
           sampling unless you do a minimum of 20 percent.  Any
           sampling less than 20 percent is not meaningful.
                       So the industry from long time ago has
           abandoned this, and has turned this into a minimum of
           20 percent.  So if you do sampling, you do 20 percent,
           and this is pretty much the same as we are finding in
           the revision, because this material really hasn't
           changed.  It's the same.
                       Now this is where things change a little. 
           If you have a 600 thermally treated, and this material
           is free from cracking -- if it is free from cracking,
           then you can inspect 100 percent of the tubes in first
           go-round in 120 effective full power months, in the
           second go-round in 90, and 60, 60, 60.
                       The reason behind this is that these
           materials have a better performance in early life than
           in later life, such that your best chance of being
           trouble free is at the beginning, and then we are
           being conservative, dropping it to 90, for the
           conservative bringing it to 60.
                       Again remember, this takes you into many
           years in the future.  This is speculation at this time
           whether you would get to all of these things.  These
           guidelines get revised every two years.
                       CHAIRMAN FORD:  But what's the factual
           basis for choosing those numbers?
                       MR. BEHRAVESH:  Factual basis for choosing
           these numbers are that -- a series of things.  There
           are plants with these materials that are operating,
           and they have not found cracks.
                       CHAIRMAN FORD:  But there are plants that
           are operating that have found cracks.
                       MR. BEHRAVESH:  Where?
                       CHAIRMAN FORD:  Byron.  
                       MR. BEHRAVESH:  That is not true.  That is
           not -- They haven't found cracks in the 600 thermally
                       CHAIRMAN FORD:  Well, they haven't done a
           destructive examination.
                       MR. BEHRAVESH:  Well, yes, there may be
           times -- There may be times that someone may decide
           that it is more efficient or to my advantage to call
           this crack and plug it and move on, as opposed to
           taking it out.
                       CHAIRMAN FORD:  My point is that you are
           using very different -- Turkey Point, Byron are both
           incidences where they've got 600 PTQs, but using
           current NDE techniques indicates that you've got
           cracking.  So --
                       MR. BEHRAVESH:  That is not our
                       MR. HENRY:  Gary Henry with EPRI.  With
           response to the Byron they did pull tubes, and they
           were found to be benign.  There was a little groove on
           the OD.
                       With Turkey Point, I think it was Unit 4,
           they found indications for which they had identified
           in Unit 3 that were very similar.  In Unit 4 they did
           ultrasonic testing on those, which are qualified
           techniques.  They also found that those indications
           were benign and were not present, and they have since
           submitted a letter disputing or basically retracting
           the fact that they found indications in Turkey 3.
                       CHAIRMAN FORD:  Those are facts.  That's
                       MR. BONACA:  I mean, if that was my plan,
           I would never go ten years without looking at those. 
           You know, I would have to trust what you are telling
           me, that there is no degradation mechanism that
           happened, is true.  Then what am I going to do if
           there is, in fact, something new after 120 months.  Do
           I sue you?
                       All I'm trying to say is that it seems to
           defy a little bit -- I understand what you are saying. 
           No, we haven't seen something.  So you go for ten
           years without looking.
                       MR. BEHRAVESH:  But, no, there's a catch
           to all of this.  No, I didn't say going ten years
           without looking at it.  You must -- First time around
           you do 100 percent in ten years.  You do 100 percent
           in ten years, and you must look at every steam
           generator at least every other outage.
                       MR. BONACA:  All right.  All right.
                       MR. BEHRAVESH:  Every outage.  Now these
           are the conditions.  You must do a sample of 20
           percent at each inspection.  Even this 120 and 90, any
           of these, require supporting degradation assessment
           and operational assessment.  
                       What does supporting degradation
           assessment mean?  Means that you look at yourself. 
           You look at your sister plants, and if anything has
           happened to them, that has to come into play in your
           degradation assessment.  If there's an indication out
           there that some other 600 thermally treated plant has
           cracking, you no longer can do this.
                       MR. BONACA:  So the 120 only refers to 100
           percent of the tubes?
                       MR. BEHRAVESH:  One hundred percent of the
           tubes being crack free.
                       MR. BONACA:  All right.  Go on.  You have
           to inspect, but you have to do it every other year.
                       MR. BEHRAVESH:  You inspect, and then
           there's more --
                       MR. BONACA:  You can choose how many, as
           long as they make 100 percent.
                       MR. BEHRAVESH:  Minimum 20 percent, and
           then additional condition.  Furthermore, we go there
           and say you can't go and do all of them at the
           beginning or all of them at the end.  You must make
           sure that you do such sampling that you are done with
           about 50 percent of them by about mid-point.
                       This is the point of this.  Examine at
           least 50 percent of the tubes in each steam generator
           by the refueling audit nearest to the mid-point, and
           the other 50 percent by the end, which means that it
           has to be spread throughout that period.
                       CHAIRMAN FORD:  Is there some statistical
           rationale for your choice of all these numbers based
           on existing data?
                       MR. BEHRAVESH:  Well, yes, there is.
                       CHAIRMAN FORD:  Existing data will,
           obviously, be mostly laboratory data.
                       MR. BEHRAVESH:  Well, yes, there is
           rationale for 20 percent sampling, where you do more
           or depending on what you can expect to find.  Then
           these 50 percent and the length fuel cycle and this no
           steam generator can operate for more than two -- If
           you put these on a time scale, you would begin to see
           how they fit, gives you a uniform inspection schedule
                       CHAIRMAN FORD:  But what you are saying,
           not seeing the actual data itself and the statistical
           rationale -- It presumably exists, but it has been
           given to the staff so that they can do an independent
           assessment of that approach?  Is that correct?
                       MR. BEHRAVESH:  Well, let me be clear as
           to my understanding of your question.   Rationale for
           which of these things?
                       CHAIRMAN FORD:  Well, you are giving a
           whole lot of numbers there, 600 TT and, I guess we are
           talking about 690.  It's presumably based on some
           facts and statistical interpretations.
                       MR. BEHRAVESH:  Yes.  Two answers.  One is
           that those numbers, those length of times are
           currently supported by laboratory studies of these
           type of materials, and what it takes to crack them in
           the laboratory.  They are supported by experience of
           the current plants that are operating with these
                       Additionally, we are doing other surveys
           of everyone else who has these materials throughout
           the world to find out what their experiences are, even
           doing some cases that are not like the U.S. plants.  
                       So additional information is being
           collected as we speak, although it's not available to
           us today.  We are trying to put additional information
           together to support these numbers.
                       CHAIRMAN FORD:  Is this the sort of things
           that Roger Staehle is doing?
                       MR. BEHRAVESH:  Probably.  It could be,
           could be related.  Specifically, I don't think he is
           addressing  this, but all of his corrosion studies --
                       CHAIRMAN FORD:  Well, he probably is.
                       MR. BEHRAVESH:  Yes.  All of his corrosion
           studies would have a bearing on this.
                       CHAIRMAN FORD:  My point is that, as we
           try to resolve some of these issues -- I'm trying to
           be helpful here -- all these analyses where you've
           come out with these numbers and the rationale behind
           them, the data has been given to the staff so they can
           come up with a factual evaluation of that data?
                       MR. BEHRAVESH:  Not all of it and, as I
           understand, not to their satisfaction. 
                       MR. BONACA:  This is the prescriptive.
                       MR. BEHRAVESH:  This is still
                       MR. BONACA:  Okay.
                       MR. BEHRAVESH:  And then the final --
                       MR. RILEY:  Jim Riley from NEI again.  I
           would just like to add a little bit more to what you
           asked.  These are part of the comments that Emmett has
           given us on these guidelines, and we are developing
           documentation to get back to Emmett on a response to
           these things.
                       This information was here to provide a
           basis, as Emmett has described.  We are basically
           writing a white paper to provide this additional
                       MR. BEHRAVESH:  But the message I want you
           to get from this is that a lot of safety things are
           sort of embedded in here, particularly at the end that
           says, if this material at anytime is found to be
           cracking anywhere, then you have to go back to the
           rules for the 600 mill annealed, which means that all
           of these things are okay so long as you remain crack
           free and everybody else remains crack free.
                       The very first time that someone finds a
           crack, all of this changes, and there is always the
           rules for 600 mill annealed.
                       MR. BONACA:  If it is discovered anywhere.
                       MR. BEHRAVESH:  Yes.  Now for 690 alloy,
           it's pretty much like 600 thermally treated.  These
           periods -- The only difference is that these periods
           have been extended.  It's good, better, better-est.
                       CHAIRMAN FORD:  Are there any tubes of 690
           that have been in for any extended period of time?
                       MR. BEHRAVESH:  690?  In service, about 12
           calendar years in the service with about close to
           eight effective full power years.  There are a couple
           of them running neck to neck now.  There is Indian
           Point, and there is DC Cook.
                       CHAIRMAN FORD:  So exactly the same thing,
           but there is presumably data of some sort to justify
           those numbers?
                       MR. BEHRAVESH:  Data to justify those
           numbers, more data to be collected to satisfy NRC's
           comments.  Again, all of these are predicated in these
           things remaining crack free with all these safeguards
           built into them to make sure that, if anyone comes up
           with information that says that's not the case, these
           things no longer apply.
                       So jumping to the basis is that you -- One
           raises the question, are these cycle lengths too long
           or why are we going this way, what justification we
                       This notion of collective experience is
           very, very important.  Although you have all these
           individual utilities, individual plants that are
           autonomous and operate by themselves, but once as they
           keep changing these plants and have new materials,
           they are all part of a big aggregate.
                       I mean, if you look at EdF, EdF looks at
           their whole fleet of plants, and that's how they
           collect their experience in terms of what is happening
           to one unit and use that information in the other
                       What is happening here is that, if even
           though someone may say that, oh, you are going too
           long without looking at it, in any given spring or
           fall outage, although you are not looking at a 690,
           someone there, someone there, someone, somebody else
           is looking at 690, and based on what is written in our
           guideline, it is the requirement of the guideline that
           when you do your degradation assessment, you not only
           look at yourself, you look at everyone else and what
           has happened to them, and you take that into account. 
           And should you still have reason to support these long
           intervals, you continue.  Otherwise, you cannot
           continue with those extended intervals.
                       CHAIRMAN FORD:  Most of these phenomena
           have got fairly high activation enthalpies.  Is there
           any temperature correction?
                       MR. BEHRAVESH:  I am sure that they are
           temperature dependent.  I cannot speak to that, but
           I'm sure that that has to be taken into account.
                       CHAIRMAN FORD:  And I don't know the
           physics of the PWR.  Now would the PWR steam generator
           change with a power upgrade?  And if it did -- If it
           did, and I don't know physically if it does, would
           that affect your arguments?
                       MR. BEHRAVESH:  I think some of these
           differences would have to be taken into account, but
           because of the fact that on the increasing guidance on
           chemistry, everyone is doing the best chemistry that
           they know how to, and chances of very severe outliers
           that would produce an anomaly is, I think, decreasing.
                       If it was 20 years ago, I would be more
           inclined to think that chemistries may be very
           different in different places.  Now temperatures --
           they may be operating at different temperatures, but
           chemistries -- I think everyone is availing themselves
           of the best chemistry.
                       Now so this collective, this aggregate
           experience is a very strong support for these long
           cycles, knowing that something is happening here will
           affect all others, and that will be taken into account
           by the requirement of the guideline.
                       The other thing is this so called
           compensatory measure which that, if cracking is
           detected, all bets are off.  You will revert back to
           600 mill annealed, and that's understood.  Besides,
           there is additional assurance that secondary side
           requirements also address foreign objects, and they
           have to be met.
                       Really, furthermore, you have to realize
           that this is an immense improvement over the current
           requirement that we have now.  I mean, this is the law
           of the land as of now, and there's lots of improvement
           that this program is providing.
                       Now there are other issues that are being
           addressed.   I don't want to belabor those.  There are
           matters of data quality ,and all of those are being
                       So now I missed one point for you, going
           back to these two.  Going back to these two. 
           Everything that I said was on the prescriptive basis. 
           In Revision 6 we also have right of performance based.
                       This is the dilemma with the performance
           based.  People criticize prescriptive based, because
           they say that it may not be -- because it's not
           performance based.  They encourage you to go
           performance based.  
                       You go and do performance based on the
           basis of the information you have.  You come up with
           numbers that are huge and, all of a sudden, everybody
           says, well, that can't be, I can't go for 22 years. 
           But that's what falls out.  We have had research
           project that has addressed this, and has produced
           reports where there have been examples that said in a
           given situation somebody could go 22 years.
                       Now whether that person, that utility,
           will follow that, it's to be seen.  But that's what
           falls out of the data.  What I want to get across to
           you is that performance based relies very heavily on
           good data.  On this, you have good data from your past
           history.  It's hard to predict the future.
                       In absence of good data, I don't think
           people would be too anxious to run to do performance
           based.  Most everyone is comfortable with doing
                       Now NRC has had issues with performance
           based, based on the numbers that it throws out.  One
           example that we have followed -- and some of our own
           clients, the utility sponsors, have issues with that,
           too.  They are sort of uncomfortable with this.  They
           say, I see what these numbers say, but I'm not sure,
           I want to go there.
                       So this is something that I think we will
           learn more about, and until we have good data, I think
           there would be reluctance on everyone's part to jump
           into performance based, although this is the final --
           this is a real objective and a real goal  that
           everyone recognizes that needs to be pursued.
                       So to make sure that you understand that
           we have something in Revision 6.  We have had the same
           thing in current revision, in Revision 5, but in
           absence of good data, nobody is following that.
                       I am going to jump to my final slide.
                       MR. RILEY:  Mohamad, can I say one thing
           here?  Jim Riley again, NEI.  I just want to make it
           clear.  I think we stated this before.
                       The issue on performance based is a little
           academic right now, because the way that we are
           approaching the regulatory controls doesn't allow for
           these performance based methodologies unless the NRC
           gives their approval of an interval determining
                       So what we are really talking about from 
           the purposes of regulatory controls now is directed at
           prescriptive, not performance based.  Like Mohamad
           says, we want to get there, but we know there is more
           work that has to be done before we are there.
                       MR. BEHRAVESH:  This is my last slide. 
           The latest draft is currently in review by the
           industry.  In the previous draft that we sent out a
           few months ago, we had several hundred comments,
           including those from NRC.  Those have been addressed. 
           We have gone out with a new draft.  We expect
           responses by mid-December.  We will start addressing
           those comments by mid-January.
                       The important point again to emphasize is
           that consensus will be achieved.  We have 20 years of
           history doing these guidelines, and we have had more
           contentious issues among the industry themselves to
           come to a consensus, and that has happened.  So
           consensus will be achieved as for the past revision,
           and we have a goal of putting this document out by
                       CHAIRMAN FORD:  Thank you very much
           indeed.  We've got 25 minutes left.  Could I ask -- Ed
           is going to ask us for advice for next week.  Does
           anyone have any comments before we give specific
                       MR. BONACA:  Well, I think that this
           presentation gave me a real feeling for what is being
           on the table, and it shed a lot of light on the
           previous presentations, which were very good.  But I
           think they were  more general.  So we are left with
           some questions regarding the specifics.
                       So if I had to choose an order in which I
           would bring the presentations, it would be maybe NEI,
           but this information, I think, is better to help us.
                       CHAIRMAN FORD:  Bear in mind that the
           members have not heard anything about this since April
           1999.  Do you think that there should be an opening
           segment to bring them up to date as to what the
           objective of this was, plus the overall problems?
                       MR. KRESS:  Yes, but very short.
                       CHAIRMAN FORD:  Very short, but also
           there's regulatory concerns as well as technical
           concerns.  I think we agreed early on, without us
           hearing about the details, that there are no
           regulatory concerns currently on the table.  Is that
           correct?  That's not correct?
                       MR. SULLIVAN:  No.  I think that is what
           we said.  I think what we said was that -- We didn't
           belabor this, but we had some exchange over recent
           months of the regulatory controls issue.  We've
           settled that as of yesterday.
                       CHAIRMAN FORD:  Bear in mind, at the end
           of the day you are requesting that we write a letter
           -- ACRS writes a letter essentially saying, hey,
           you're going in the right direction, guys.  It's
           another ten years before we hear about this particular
           topic, and that the technical issues that you have
           honed in on are the correct ones to be resolved by the
           time your write your SR and safety evaluation report.
                       That's what your expectations are.  I
           guess I'm asking the subcommittee here for advice to
           them as to what they should be hitting.
                       MR. BONACA:  When I looked at their
           presentation, I see a lot of reasonable steps.  I
           think it's a responsible program.  I'm sure that there
           are plenty of issues that you have to hammer out, but
           I think that you are going in the right directions,
           has improvements definitely over the current problem. 
           It takes into consideration certain assumptions
           regarding improved materials.
                       On the other hand, it takes into account
           the possibility that cracks are being identified and,
           therefore, steps back the program.  I think it's a
           very responsible approach, and I think once we see
           that, then the concerns of the NRC come more in
                       I mean, they are looking more at the
           details, the specifics, and so if you go into those,
           I think that they will be more clear for the
           committee.  I would have a brief introduction
           definitely in the beginning to put the whole thing in
           perspective, but I think it's important that in a
           couple of years -- Again, I view the program as
                       MR. KRESS:  I would like to hear more
           about that the issues on Slide 18 and 19 strike me as
           fairly important ones.  That is one of the things that
           disappeared from the integrity guidelines.  There was
           a probabilistic statement in the earlier guideline
           that seems to have vanished.
                       I mean, you not only had to demonstrate
           the factor of three and 1.4, you had to demonstrate a
           probability of cracking also.  There were two
           requirements, as I recall, in the earlier version.  Is
           that an option?
                       MR. MURPHY:  The guidelines address a
           situation where you are taking a statistical approach
           to assessing where you are relative to the 3 delta P
           criteria, for example.  And it states that each tube
           should have a relatively high probability of meeting
           the 3 delta P criterion.  
                       In addition, there's a criterion that
           basically states that there should be a relatively
           high probability that the population of tubes will be
           capable of meeting the 3 delta P criterion.
                       The major failing of the guideline is that
           that second criterion is not consistently carried
           through the tube integrity assessment guidelines or
           the other guidelines either.  What that means is that
           where you are dealing with degradation mechanisms
           where there's a sizable number of flaws, which is
           often the case, you may well have a number of tubes
           which each individually has a high likelihood of
           satisfying the criteria, but when you look at the
           population, there's actually a relatively low
           likelihood that you are going to have all tube
           satisfying the criteria.
                       So that clearly is a pretty fundamental
           issue I think that the guidelines need to do a better
           job of addressing.
                       MR. KRESS:  I guess my comment was in the
           draft Reg guide -- and I thought in the first version
           of NEI 97-06 -- that requirement was actually a high
           level requirement.  It wasn't down in the guideline. 
           It was given equal weight, in fact, with 3 and 1.4, or
           am I wrong?
                       MR. BEHRAVESH:  I think you are confusing
           the probabilistic criteria with the deterministic one.
                       MR. MERILO:  I'm Mati Merilo from EPRI. 
           I think we are talking about two separate
           requirements.  We originally had a probabilistic
           requirement which the NRC said that they didn't really
           like, because they weren't able to tie that back to
           the deterministic criteria.
                       So we do have it in the guidelines, but
           said you require NRC approval before you can use that.
                       MR. KRESS:  I see.  So you didn't have to
           satisfy both then?
                       MR. MURPHY:  Well, I think we are talking
           -- A lot of us are talking past each other at this
           point.  I think Mati was referring to a probabilistic
           criteria that applied to probability of failure during
           main steam line break, as opposed to the likelihood or
           the probability that you are going to satisfy a 3
           delta P criteria or the 1.4.
                       MR. KRESS:  Okay, I see.  I understand
                       MR. MURPHY:  Yes.  We have entertained in
           the context of the ODSCC arc the notion that there
           should be an acceptance criteria with respect to the
           probability of burying a tube under steam line break
           conditions where no credit is taken for the presence
           of the support plate.  But in general, we haven't
           agreed to such a criterion in any other application.
                       Rather, we are looking for a high degree
           of assurance that you are meeting 3 Delta P or, you
           know, the 1.4.
                       MR. BONACA:  By the way, this is a very
           important issue, too, and we need to talk about it. 
           But it is interesting how two presentations really are
           going by each other.  I mean, what we heard from EPRI
           today was about the prescriptive approach.  We didn't
           hear anything about the performance based.
                       The main issue we had when you had your
           presentation was on the performance based.  So you
           know, we need to hear from EPRI of when you are coming
           out with the revision.  You said that you already have
           a revision in place with some performance based
                       MR. BEHRAVESH:  Really, no criteria in any
           form of detail.  It's a hint of things to come.  It's
           saying that, yes, there is another avenue to pursue,
           but in absence of data, in absence of well tested
           methodology, really we can't say anything more.  It's
           mostly expressed as a goal to achieve as opposed to a
           path to follow.
                       MR. BONACA:  I got kind of thinking,
           because I thought that we would see in front of us
           soon enough an approach that is performance based.  So
           I was kind of alarmed, and I wanted to know what's the
           basis for this.  But from what I hear now, it's not an
           imminent bet.
                       MR. SULLIVAN:  I don't think it is
           imminent, but I think our presentation -- It's always
           really difficult to figure out what is the best way to
           present this material.  There's a lot of it.
                       I think our presentation grew out of the
           perspective that as recently as the beginning of this
           year, we have been heading in the direction of a
           performance based approach.  We've gone down a
           different avenue, at least for the more near term.
                       I think we agreed with NEI and the
           industry that that's a success path for the near term
           for getting into place a new regulatory framework, but
           all of these issues are still going to be there when
           we devote our attention to the performance based
                       So it kind of came out of a historical
           perspective that we wanted to let you know that we
           have a number of issues.  We have identified them to
           industry, and then we have taken another avenue to
           getting the regulatory framework on board.
                       MR. BONACA:  I would just say, that was
           more reflecting on the shorter time we have next week
           and we got -- I was sidetracked somewhat, and I think
           we want to prevent that from happening in the meeting.
                       MR. SULLIVAN:  So you are recommending
           that next week we basically try to focus on the
           direction we are going in and not try to present
           information on both avenues, which may turn out to be
                       MR. BONACA:  I would just focus on the
           most imminent approach.
                       MR. SULLIVAN:  The inspection interval
                       MR. BONACA:  Right.
                       CHAIRMAN FORD:  Tom, do you have anything?
                       MR. KRESS:  Yes, I agree with what he
           said.  I would like to see more data based.
                       CHAIRMAN FORD:  I think what you are
           hearing is that we've got one and a half hours.  The
           traditional one is 45 minutes, therefore.  Out of that
           45 minutes, I would suggest that, contrary to what you
           are saying -- we can re-debate this, Mario -- that you
           give a very short background on the regulatory
           situation, how we want to go toward ultimately
           performance based criteria --
                       MR. SULLIVAN:  But don't belabor it.
                       CHAIRMAN FORD:  -- the whole background to
           the 97-06, and then now Rev 1 and the Generic Change
           Package, just a very -- two minutes, five minutes,
                       MR. SHACK:  No, I think it's important to
           get in what the regulatory requirements that you now
           currently plan to impose are.  I'm not worried about
           historically you thought you were going to have to do
           without this, but the notion -- Mohamad stated that,
           if they do go to a performance based approach, you are
           going to have to approve the methodology for doing
                       I think that is an important regulatory
           statement, and the slide that sort of got buried in
           Emmett's thing, that if they are going to change these
           maximum intervals, that's again something you have to
                       I wouldn't be too concerned about, again,
           you know, historically you were heading one way, and
           now you have changed directions.  Just tell us what
           the current plan is.
                       MR. BONACA:  I think, if you do that, at
           least we don't get hung up pursuing just how do you
           justify these criteria and how do you measure up to
           those, because that could take the whole Committee in
           that direction.
                       CHAIRMAN FORD:  And I also advise that,
           bearing in mind the Committee is being submerged in
           all these DPO issues in the last year, that it would
           be worthwhile -- it would behoove you to at least
           mention Jim's comment, that the EPRI guidelines are
           living documents, and they will take into account
           lessons learned from the DPO action plan, etcetera.
                       Everything I've said is literally within
           ten minutes to start.  The rest of the time, I think,
           should be focused on the technical issues, what has --
           I guess one slide, everything that's being taken into
           account that has been addressed.  
                       I think you should be prepared -- and
           result.  You should be prepared to back up the
           statements about the 1.4 and the 3 safety factors with
           some data.  There's a performance issue that Bill just
           brought up on your Slides 18 and 19.  I think those
           are important.  But the majority of time should be
           spent on the inspection to those and, if I could
           suggest, that maybe you start off with your viewpoint. 
           Then you end up with -- and Emmett had some good
           slides, word slides.  
                       In all of these, I really urge, use data,
           please, to make your points.
                       MR. KRESS:  With respect to Slide 18, that
           was very interesting how they would do the analysis to
           provide those assurance, the 90 percent assurance.
                       CHAIRMAN FORD:  Yes.  
                       MR. KRESS:  I don't -- I have to sit down
           and try to figure out how I would do this.  It's not
                       CHAIRMAN FORD:  Bear in mind, your
           expectation is that we will write a letter saying that
           you have covered all the technical issues, and those
           are the appropriate outstanding ones.  That's what you
           want us to do, and so we need the information to write
                       It would also be interesting to finish up
           with Emmett's time things of work:  When is this all
           going to all finish, i.e., completely finished by
           December 31st of next year.
                       MR. SULLIVAN;  One thing that we didn't
           get into, I think because we were wanting to focus
           across the board on all of the issues, were the
           specific questions and so forth that we have raised on
           the proposed inspection intervals.
                       Now that came out in the course of
           Mohamad's presentation.  I think somebody offered
           that.  I don't know whether it was Jim or Emmett, but
           we have a number of questions that are similar to the
           ones that you were raising.
                       I guess what I'm hearing you say is we
           should probably steer toward those issues that we have
           raised and that are being worked on, rather than the
           ones that have to do with the performance based
                       CHAIRMAN FORD:  I've got another question
           to my colleagues here.  It's not my area of expertise. 
           Bill, you brought up the question of severe accident. 
           I know Dana is also worried about iodine, etcetera. 
           Is this an issue that should be even brought up here
           or not?  Is it going to be asked?  Should they be
                       MR. KRESS:  I suspect that the issues will
           take the form of these new inspection intervals plus
           the associated increase in risk.  Steve addressed that
           to some extent.   I don't think the iodine spiking
           issue is likely to come up.  
                       CHAIRMAN FORD:  Okay.  Let that be
           forewarned, fore-armed.  Any other comments?  Well, I
           hope you found it useful rather than destructive.  We
           did give you a hard time, Emmett.  I apologize.  
                       Are there any other comments, questions?
                       MR. SULLIVAN:  I guess I have a question. 
           Maybe it's for the other side.  But I think what I
           hear you recommending is that you would -- from the
           second presentation coming from NEI, or industry, you
           would like the details that Mohamad presented more
           than the background that Jim presented.  Is that what
           you were saying?
                       CHAIRMAN FORD:  On that aspect, that
           helped me personally, because I'm new to this game. 
           But to the rest of the guys, they know this left,
           right and center, I suspect.
                       I think you that you all should start out
           with the regulatory background and the technical
           issues that you have examined relative to the Generic
           Change Package and NEI 97-06.  
                       Just state that you are prepared to defend
           all those that you agree with that are no longer
           issues, and let Mohamad take the majority of the
           technical discussion, I think, on inspection, because
           that is, as I hear it, the main thing on the table.  
                       Then you finish off and respond to make
           your rebuttals or your concerns which you put down in
           words, because I do urge everybody to come along with
           data to back up the statements.  
                       (Whereupon, the foregoing matter went off
           the record at 11:54 a.m.)


Page Last Reviewed/Updated Tuesday, August 16, 2016