Plant License Renewal - March 27, 2001

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               Plant License Renewal Subcommittee

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Tuesday, March 27, 2001

Work Order No.: NRC-135                               Pages 1-311

                   NEAL R. GROSS AND CO., INC.
                 Court Reporters and Transcribers
                  1323 Rhode Island Avenue, N.W.
                     Washington, D.C.  20005
                          (202) 234-4433.                         UNITED STATES OF AMERICA
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                              MARCH 27, 2001
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                            ROCKVILLE, MARYLAND
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                       The Subcommittee met at the Nuclear
           Regulatory Commission, Two White Flint North, Room
           T2B3, 11545 Rockville Pike, at 8:30 a.m., Dr. Mario
           V. Bonaca, Chairman, presiding.
                 MARIO V. BONACA                Chairman
                 F. PETER FORD                  Member
                 THOMAS S. KRESS                Member
           COMMITTEE MEMBERS PRESENT: (cont'd)
                 GRAHAM M. LEITCH               Member
                 WILLIAM J. SHACK               Member
                 ROBERT E. UHRIG                Member
                 JOHN BARTON
                 SAM DURAISWAMY
                 ROBERT ELLIOTT
           ALSO PRESENT:
                 HANS ASHAR
                 RAJ AULUCK
                 GOUTAM BAGELU
                 R.D. BAKER
                 BILL BATEMAN
                 TAMMY BLOOME
                 JOSEPH BRAVERMAN
                 WILLIAM BURTON
                 GENE CARPENTER
                 ROBERT CARTER
                 T.Y. CHANG
                 PEI-YING CHEN
           ALSO PRESENT:  (cont'd)
                 OMESH CHOPRA
                 MANNY COMAR
                 H.F. CONRAD
                 J.F. COSTELLO
                 AMY CUBBAGE
                 JAMES DAVIS
                 JERRY DOZIER
                 ROBIN DYLE
                 TANYA M. EATON
                 BARRY ELLIOT
                 JOHN FAIR
                 DONALD FERRARO
                 GREG GALLETI
                 HERMAN GRAVES
                 CHRIS GRIMES
                 JOHN HANNON
                 ALLEN HISER
                 CHUCK HSU
                 DAVID C. JENG
                 PETER J. KANG
                 ANDREA KEIM
                 ED KLEEH
                 STEPHEN KOENICK
                 W. KOO
           ALSO PRESENT:  (cont'd)
                 P.T. KUO
                 SAM LEE
                 W.C. LIU
                 YUNG Y. LIU
                 ROBERT LOFARO
                 WAYNE LUNCEFORD
                 JAMES E. LYONS
                 MICHAEL McNEIL
                 S.K. MITRA
                 RICH MORANTE
                 KEITH NICHMAN
                 WALLACE NORRIS
                 K. PARCZEWSKI
                 ERACH PATEL
                 PAT PATNAIK
                 CHARLES R. PIERCE
                 JAI RAJAN
                 MUHAMMAD A. RAZZAQUE
                 KIMBERLEY RICO
                 K. RIW
                 JOHN RYCYNA
                 SYED SHAUKAT
                 PAUL SHEMANSKI
                 DAVID SOLORIO
           ALSO PRESENT:  (cont'd)
                 SHIU-WING TAM
                 BRIAN THOMAS
                 STEVEN G. TONEY
                 JIT VORA
                 DOUG WALTERS
                                 I N D E X
                         AGENDA ITEM                       PAGE
           Opening Remarks. . . . . . . . . . . . . . . . . . 7
           Staff Opening Remarks. . . . . . . . . . . . . . . 8
           Introduction and Review. . . . . . . . . . . . . .10
           Overview of Public Comments. . . . . . . . . . . .14
           Changes to Standard Review Plan:  Scoping. . . . .15
             and Screening Methodology
           Changes to Generic Aging Lessons Learned . . . . .36
             (GALL) Report, Chapters II and III
           Changes to GALL, Chapter IV. . . . . . . . . . . .57
           Changes to GALL, Chapters V, VII, and VIII . . . .76
           Changes to Gall, Chapter VI. . . . . . . . . . . 105
           One-time Inspections, Regulatory Guide,. . . . . 111
             NEI 95-10
           Changes to NEI 95-10:  Industry Guidance . . . . 128
           Staff Introduction Concerning BWRVIP . . . . . . 169
             Topical Reports Related to License Renewal
           BWRVIP 76:  Core Shroud Inspection . . . . . . . 274
           BWRVIP 41:  Jet Pump Assembly Inspection . . . . 278
           BWRVIP 26:  Top Guide Inspection . . . . . . . . 279
           BWRVIP 75:  Technical Basis for Revisions to . . 280
             Generic Letter 88-01 Inspection Schedules
           Discussion . . . . . . . . . . . . . . . . . . . 299
           Recess . . . . . . . . . . . . . . . . . . . . . 311
                                                    (8:30 a.m.)
                       CHAIRMAN BONACA:  Good morning.  The
           meeting will now come to order.  This is a meeting
           of the ACRS Subcommittee on Plant License Renewal.
                       I am Mario Bonaca, Chairman of the
           subcommittee.  The other ACRS members in attendance
           are Peter Ford, Thomas Kress, Graham Leitch, William
           Shack, and Robert Uhrig.  We also have John Barton
           attending as a consultant.
                       The purpose of this meeting is to review
           the final drafts of the Standard Review Plan for
           License Renewal; the Generic Lessons Learned Report;
           the Draft Regulatory Guide DG 1104, Standard Format
           and Content for Applications to Renew Nuclear
           Powerplant Operating Licenses; and NEI 95-10,
           Revision 3, Industry Guideline for Implementing the
           Requirements of 10 CFR Part 54, the License Renewal
                       The subcommittee will also review
           selected reports of the boiling water reactor vessel
           and internal projects associated with the license
           renewal.  The subcommittee will gather information,
           analyze relevant issues and facts, and formulate
           proposed position and actions as appropriate for
           deliberation by the full committee.
                       Mr. Sam Duraiswamy is the cognizant ACRS
           staff engineer for this meeting.  Mr. Rob Elliott,
           who is on rotation assignment to the ACRS staff from
           NRR, is also present.
                       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 March 8, 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 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
                       We will proceed with the meeting, and I
           call upon Mr. Grimes of NRR to begin.  Good morning.
                       MR. GRIMES:  Thank you, Dr. Bonaca.
                       My name is Chris Grimes.  I'm the Chief
           of the License Renewal and Standardization Branch,
           and I want to thank the subcommittee for taking the
           time to review the results of the staff's effort to
           develop improved license renewal guidance.
                       As you may recall, we set off to review
           license renewal applications for Calvert Cliffs and
           Oconee with draft guidance, an industry guide, and a
           standard review plan that were untested and
           represented a very different way of staff review for
           a licensing action.
                       We accomplished those first two reviews
           through perseverance and with a focus on the
           objective of Part 54.  And through those efforts we
           learned substantial lessons in how to improve that
           focus and concentrate the staff review.
                       During the course of the review of the
           first two applications, the industry also raised an
           issue which they referred to as credit for existing
           programs.  That is described in a Commission paper,
           SECY-99-148.  As a result of that issue, and also a
           reflection on the lessons learned from the Calvert
           Cliffs and Oconee reviews, the staff set out to
           develop improved renewal guidance largely in the
           form of generic aging lessons learned, a catalog of
           the staff's expectations of the attributes of
           effective aging management programs.
                       We've kept the subcommittee and the
           committee informed of our efforts as we've gone
           through the evolution of trying to develop that
           catalog and the improved renewal guidance that goes
           along with it, with a focus on achieving
           predictability and stability in the license renewal
           reviews and to facilitate the future workload that
           we anticipate because of the substantial industry
           input and interest in license renewal for other
           power reactors.
                       Today's presentation is going to focus
           on addressing the way that the staff has responded
           to public comments on the improved renewal guidance,
           and I call upon Dr. Sam Lee, who is going to provide
           the introduction for the staff's presentation.
                       MR. LEE:  Good morning.  My name is Sam
           Lee of the License Renewal and Standardization
           Branch, NRR.  And as Chris had indicated, the INPO
           license renewal guidance document consists of the
           Generic Aging Lessons Learned, the GALL Report,
           which is a staff evaluation of aging management
           programs, and the SRP, which references the GALL
           Report, to focus the staff in areas where programs
           should be thoroughly evaluated, and also consists of
           the Regulatory Guide which endorses NEI document 95-
           10 that provides guidance to the applicants to
           prepare their license reapplication.
                       There has been a significant agency
           effort.  It involved the office of NRR and the staff
           who are conducting the license renewal applications,
           and also involved the Office of Research.  And Jit
           Vora, on my right, he is the team leader from
           Research.  And the two national labs -- Argonne
           National Lab, Yung Liu on my right, he is the
           Project Manager from Argonne.  And Brookhaven
           National Lab, Mr. Morante on my left, he is the
           Project Manager from Brookhaven.
                       This morning we are going to discuss the
           changes or significant changes in the document as a
           result of public comment when we issued it in
           August.  Back in August, the GALL Report has a
           format that is a double-sided, two-page table kind
           of format, and it turns out to be not very easy to
           use.  So as a result we streamlined the format in
           the GAL Report into a one-page table format, and
           then we centralized the program evaluation into
           Chapter XI of the GALL Report.
                       We are going to discuss the GALL Report
           by structures and systems later on today.  We are
           going to also discuss the associated changes in the
           program also.
                       The SRP references the GALL Report, so
           when the GALL -- when we make a change in the GALL
           Report, we make the corresponding or conforming
           changes in the SRP.  However, in Chapter II of the
           SRP, we discuss the scoping.  This is separate from
           the GALL Report.  Okay?  So Mr. S.K. Mitra will
           discuss the changes in the SRP relating to scope
           this morning.
                       And Dave Solorio is going to discuss the
           changes in the Regulatory Guide and NEI 95-10.  And
           we were asked to discuss the one-time inspections,
           and Dave will also do that.
                       We are preparing a SECY paper to submit
           this document to the Commission for approval in
           April.  And during the interaction with NEI to go
           over their comments on these documents, they
           identified five items that we should continue
           dialogue on.  And we will discuss them later on this
           morning as they come up in the respective systems.
                       Another NEI comment is on the -- how
           these documents are going to be used.  NEI is now
           performing a demonstration project which prepares
           some sample portions of an application, and they
           plan on submitting this to the staff by the end of
           April.  And we will interact with industry to go
           through that document to see how we can work out the
           implementation details when all of these documents
           get folded into the process.
                       CHAIRMAN BONACA:  Before you move that,
           could you expand on the second bullet?  I mean,
           continue dialogue on these five issues.
                       MR. LEE:  Yes.  We're going to talk
           about this later on in the later portion.
                       CHAIRMAN BONACA:  Okay.  All right.
                       MR. LEE:  Okay?  As they come up.
                       CHAIRMAN BONACA:  Okay.
                       MR. LEE:  Basically, this is -- continue
           to exchange information with NEI.
                       MR. GRIMES:  Sam, if I may, this --
           those five items were issues that were -- that
           evolved from industry comments for which there was
           some controversy.  And rather than take those issues
           to appeal, the industry requested that we -- that
           they be afforded an opportunity to continue a
           dialogue on those subjects, with an expectation that
           perhaps improved guidance or improved positions
           would be developed for future changes to the
           guidelines.  And as we get to those topics and the
           particular sections that they apply, we will explain
           the details.
                       CHAIRMAN BONACA:  Should complex
           assemblies be part of that list?
                       MR. GRIMES:  No.  I believe that complex
           assemblies has been clarified.  There may still be
           some details to work out, but that issue did not
           rise to a level of potential appeal.
                       CHAIRMAN BONACA:  Yes.  Because it seems
           there is some kind of significant issue in the Hatch
                       MR. GRIMES:  And we expect that we'll be
           able to resolve that, but we are continuing to
           discuss treatment of complex assemblies on the Hatch
                       CHAIRMAN BONACA:  Okay.  Thank you.
                       MR. LEE:  Okay.  Is there any more
           questions?  Okay.  Now I'm going to turn it over to
           Mr. Steve Koenick to discuss the public comments.
                       MR. KOENICK:  Good morning.  I am Steve
           Koenick.  To my right is Ed Kleeh.  I'll give you a
           brief overview of the public comments.
                       We issued four documents, as Sam stated,
           on August 31st in Federal Register Notice 65
           FR53047.  Following that, we had a public workshop
           with over 100 participants.  We also received
           numerous comments on the improved regulatory
           guidance documents.  
                       On the third bullet I reference NUREG-
           1739, which is the analysis of the public comments. 
           We received over 1,000 comments, the bulk of which
           was from the nuclear industry, with the majority of
           those being from NEI.
                       With the written comments, you see 100
           -- over 100 individual comments.  The majority of
           these comments were with respect to nuclear power as
           a whole and the license renewal process to which we
           responded to each comment with a description of the
           license renewal process.  So that's how we
           dispositioned those comments.  The rest are
           articulated in the NUREG, if you have any questions.
                       If none, why don't I turn it over to the
           SRP Chapter II on scoping.
                       MR. MITRA:  Good morning.  My name is
           S.K. Mitra, and with me from NRR on my left is Greg
           Galleti is -- he has contribution regarding scoping. 
           And on my right is Brian Thomas, also from NRR, and
           he contributed on scoping and screening.
                       Today we'll discuss the changes in
           scoping, Chapter II, the standard review plan from
           the -- due to the industry comments.  As Dr. Lee
           previously said, when the GALL changed, it resulted
           in a corresponding change in the SRP, and we will
           discuss later on as we talk about other GALL
           changes.  But how that Chapter II of SRP addresses
           scoping which is separate from GALL, so in this
           slide we are only going to talk about SRPLR Chapter
           II, which is scoping.
                       The first bullet is we incorporated
           severe accident management to the source document to
           consider scoping.  This is done in response to ACRS
           letter to Chairman dated November 15, 2000, to add
           severe accident management guidelines to SRPLR Table
           2.1-1, which is sample listing of potential
           information sources for identifying structure,
           system, and components within the scope of license
                       The number two bullet is clarify the
           focus of scoping review.  We clarified in response
           to industry comments.  The industry took an issue
           that we should -- that the industry should only,
           under Rule 5421, request to identify the list of SSC
           data subject to aging management review, not a list
           within the scope of license renewal.
                       Previously, the previous application,
           the industry submitted a list of components that are
           within the scope of license renewal.  So the change
           in the SRPLR will be from -- in the future, the
           industry is only going to submit the list which are
           in AMR, which is, you know, aging management review.
                       And the other list will be determined
           through the sample in PNID, review of FSAR, and
           other plan documents, what SSC are, you know, within
           the scope.  And during the inspection, the plant --
           the list will be available for the inspectors.
                       CHAIRMAN BONACA:  Well, let me ask a
           question.  I'm trying to understand if I understood. 
           So the industry wants to have only the results of
           the scoping and screening listed in the application?
                       MR. THOMAS:  Yes.  If I understand the
           industry's comments appropriately, they --
           basically, they're saying that the SRP should focus
           on the actual expected contents of the application. 
           And when you look at the rule, it specifically
           states that it should just be the structures that
           are subject to AMR.
                       CHAIRMAN BONACA:  Yes.  I understand
           that.  I mean, the way we have seen it, there was a
           scoping process that said this is -- potentially it
           should be in the application.
                       MR. THOMAS:  Right.
                       CHAIRMAN BONACA:  I mean, should be
           under the aging management programs.  Then you have
           a screening process that will cut out a number of
           those, because they do not perform the function that
           -- the result of it is a list of components which
           will be subject to an aging management program.
                       MR. THOMAS:  Right.
                       CHAIRMAN BONACA:  That's what they want
           to have in the application?
                       MR. THOMAS:  In the application itself,
                       CHAIRMAN BONACA:  How do you -- how does
           a reviewer understand the process by which the
           screening has been applied if you don't know what
           the list they started from is?
                       MR. THOMAS:  Well --
                       CHAIRMAN BONACA:  I'm trying to
           understand, you know, how you do that.  I mean, the
           review process is a very important one.  I'm saying
           this because even the ACRS struggles with the
           review, and we are -- you know, since scoping is
           important, and how you go through the steps is
                       MR. THOMAS:  Right.  There is a review
           of the scoping methodology itself that is performed. 
           And then the review of the application itself is
           just focused on the results of that -- of the
           implementation of that scoping methodology, which
           is, you know, a subordinate list of structures and
           components that are subject -- yes, that list is
           subordinate to the bigger picture list.
                       What a reviewer essentially has to do is
           what we consider to be a negative review if you
           will, and what you're looking for is really what's
           been omitted from the scope of structures and
           components subject to AMR.  What a reviewer then has
           to do is just canvass the PNIDs, the FSAR, any other
           plant supporting documents, the licensing basis, and
           so forth, to determine if there are any additional
           items that should have not been omitted from that
           list that presents the results of the screening, the
           scoping and screening.
                       CHAIRMAN BONACA:  But it seems to me
           that this places all of the burden on the staff.  I
           mean, I have a concern with that, and I would like
           to express it now, because I've seen it also in the
           Hatch application that we are talking about
           tomorrow.  If the staff has to ask questions, many,
           you know, requests for additional information
           saying, "Why didn't you include in scope the
           following 27 components?" and then the answer comes
           and says, "Oh, of those, 20 are in scope, but you
           have to look at them some other way."
                       And so you keep asking questions, and
           you keep having some confirmation or some exceptions
           and expirations.  At the end, you are making a
           statement in the SER that you have -- you have
           reasonable confidence that all components that
           should be in scope are in scope.
                       How are you making that statement?  I
           mean, you have to do a lot of pulling strings to --
           you know, I mean, the process it seems to me becomes
           some difficult for a reviewer that I'm just
           questioning how you're going to be able to make a
           statement that says there is reasonable confidence
           that all issues in scope are in scope.
                       MR. THOMAS:  It is a very involved
           review process, and it's very involved review on the
           part of the reviewer.  But it forces the reviewer
           to, you know, do a thorough evaluation of the
           systems and structures and components, and to do
           just that, what you said, to prod and probe to see
           if there has been any omissions from the screening
                       MR. GALLETI:  Excuse me.  This is Greg
           Galleti.  I'm with the IQPB part of NRR.  We're
           responsible for the scoping methodology review.  The
           staff would have two opportunities to review the
           scoping methodology in detail.
                       One would be during the scoping audit
           which is performed by the staff reasonably early on
           in the process.  We would be on-site at the
           engineering offices looking at the design
           documentation and going through with the cognizant
           engineers the specifics of the scoping review,
           scoping methodology, and looking at the scoping
                       In addition, there's a second
           opportunity for the staff to go through in detail
           and look at the scoping results, and that would be
           during the scoping inspection which is performed by
           the regional offices.  They would go out and do a
           more formal review of the results, system walkdown,
           things of that nature, to determine if in fact the
           scoping was accomplished in accordance with the
           methodology put forth.
                       CHAIRMAN BONACA:  I understand that.  It
           doesn't change the -- yes, sorry.
                       MEMBER SHACK:  Yes.  You know, it seems
           to me, and I guess we've argued around here, that it
           would certainly be helpful to the reviewer to have
           these results.  What is the major -- is it really
           just the burden on the licensee to provide this
           list?  He's got the list.
                       CHAIRMAN BONACA:  He's got the list,
           hopefully.  I think I started from somewhere, and --
                       MR. GALLETI:  The list would be
           available to us during the audits.  Obviously, the
           list has been developed by the licensee as part of
           their methodology.  When we go out to do the audit,
           that level of detail would be available to us, and
           we would exercise reviewing that information.
                       MR. GRIMES:  This is Chris Grimes.  I'd
           like to clarify that we can reflect back that it was
           the focus of the renewal rule that established that
           the application need only provide the results of the
           process, and the rule focuses on a process-oriented
           screening -- scoping and screening activity for
           which the application is specifically told to only
           produce the result.
                       The guidance that we have provided in
           the SRP explains to the staff how to go about
           testing the results of the process.  And,
           admittedly, it forces the staff to stop and think
           about the insights gained from, in this particular
           case, severe accident management guidelines, but
           also the FSAR and other source materials for which
           the staff then applies its experience and knowledge
           in order to go through a process of testing those
           results in order to determine whether or not the
           staff can identify any structures, systems, or
           components that have been omitted.  And that's the
           way that we have constructed the guidance, is to
           explain to the staff how to go about doing that.  
                       As Greg pointed out, during the
           methodology review and the scoping inspection, the
           staff has an opportunity to look at the underlying
           documentation that includes things that were
           originally considered and then excluded for whatever
           reason.  And our safety evaluations have explained
           what we found, how we've tested, and how we reach a
           conclusion that is framed in terms of the staff
           hasn't found anything omitted, and, therefore, there
           is reasonable assurance that the result is complete.
                       And we certainly could consider a new
           construct for the rule that would present the front-
           end of the process, but that would tend to detract
           from the process orientation of the rule.
                       CHAIRMAN BONACA:  Yes.  I'd like to note
           that the rule -- it's written in a few pages, and
           the guidance is written in hundreds and thousands of
           pages.  And I'm saying there is quite a latitude in
           support and documentation to help the processes
           which are implied in the application of the rule,
           which is the development of the application, the
           review, the SCR, and everything else.
                       So I -- I can't argue now -- and you
           may, in fact, have available during your inspection
           a full listing and very scrutable.  I'm only saying
           that it doesn't facilitate, for example, for a
           reviewer like myself.  I spent time looking at the
           Hatch application, and I really was troubled by the
           fact that it was hard to pull strings to find how it
           went from A to B to C.  And I think that documents
           should be more scrutable than that.  Anyway, that's
           my comment here.
                       MEMBER LEITCH:  Wait a minute.  I had a
           question on the first bullet, if you were getting
           ready to move forward.  As I understand it, all that
           was done as a result of the ACRS comment was that
           you added severe accident management guidelines to
           Table 2.1.1.  That table says sample listing of
           potential information sources.
                       So there's a suggestion that one might
           look at severe accident management guidelines.  It
           leaves me with a question about whether that's
           really required or not.  In other words, if there is
           equipment that is necessary to carry out actions
           prescribed in the severe accident management
           guidelines, is that equipment required to be in the
                       MR. GALLETI:  If I could answer that. 
           This is Greg Galleti again.  What is required is
           that the application be consistent with the current
           licensing basis.  To that extent, if there is --
           when you review the severe accident management
           guideline, if there is equipment in that --
           described in that guideline that would be consistent
           with the COB, then one would consider that to be
           potentially within the scope.
                       Just because something is in the severe
           accident guideline does not necessarily mean that it
           must be within the scope of for license renewal. 
           But, generally, what we have done is we've put, you
           know, a rather large listing of potential documents
           that would be available to the staff to review
           really in preparation for embarking on the scoping
                       The mandate of the staff is to come up
           with a safety determination, based on getting a good
           understanding of what the current licensing basis
           is.  That's a formidable task, and the staff felt it
           was appropriate to try to encompass as many
           technical documents that pertain to the licensee and
           the design of the plant as possible.  That's really
           the general reason why we felt it was appropriate to
           incorporate it there.
                       MEMBER LEITCH:  But doesn't it -- the
           severe accident management guidelines are not in the
           current licensing basis, are they?
                       MR. GALLETI:  That's correct.
                       MEMBER LEITCH:  So it seems to me it
           still begs the question as to whether we're -- what
           is our expectation with regard to severe accident
           management guidelines.
                       MR. GALLETI:  I think what we've tried
           to do is provide the staff with an opportunity
           certainly to look at that information to try to
           glean some insights as to what would be risk
           significant or important SSCs for the purposes of
           this plant -- you know, any particular plant.
                       I think what we've determined is that
           the efficacy of the SAM guidelines is really going
           to be considered on a site-specific, case-by-case
           basis.  Again, that's why we had incorporated into
           that level of this SRP.
                       MEMBER LEITCH:  And, again, the only
           change that was made as a result of that was just
           the added listing in this table.  There's nothing in
           the text that refers to that?
                       MR. GALLETI:  I believe that's true.
                       MEMBER LEITCH:  Okay.  Thank you.
                       MR. MITRA:  The last bullet we have --
           item which we are having continued dialogue with
           NEI.  And it's IPE/IPEEE has a source document to
           consider for scoping.  Since license renewal rule is
           deterministic, not probabilistic, the industry
           commented that PRA techniques have very limited use
           for license renewal scoping.
                       There is one element -- the review of
           individual plant examination, which is IPE, and
           individual plant examination of external event,
           which is IPEEE, in the SRP.  The staff agrees that
           license renewal rule is deterministic, but also
           feels that the use of IPE and IPEEE does provide
           useful insight for current licensing basis.
                       The dialogue with the industry is still
           going on, and hopefully we will have some kind of a
           resolution on this.
                       MR. GRIMES:  This is Chris Grimes.  I'd
           like to expand on that thought in further response
           to Dr. Leitch's question.  The standard review plan
           generally explains to the viewers your source
           material as part of this challenge to the results of
           scoping and screening, and particularly in the area
           of the use of severe accident management guidelines
           and IPEs.
                       The staff has very powerful tools to go
           -- to prod into the current licensing basis and to
           determine the extent to which there may be systems,
           structures, and components that are important to
           safety that may not be part of the current licensing
                       And I believe that it's reasonable to
           characterize the industry's concern as further
           guidance in the standard review plan in terms of how
           to use those devices without causing damage, and
           that is to unnecessarily challenge the current
           licensing basis to be more risk-informed without an
           explanation of the process by which risk-informed
           changes to the licensing basis should be made.
                       I believe that the guidance is
           reasonable, in terms of the importance of the focus
           on maintaining a current licensing basis and simply
           selecting from that those systems, structures, and
           components that need to be considered for aging
           management reviews.  
                       But I do also see an opportunity for us
           to draw experience from risk-informed licensing to
           further expound the explanation about how to use
           risk insights in a constructive way.  And that's why
           we'll continue a dialogue in this particular area
           that may result in additional guidance to the
           reviewers in the future and how to challenge the
           current licensing basis in a constructive way.
                       MR. MITRA:  That's all we have on
                       MR. BARTON:  Is there going to be any
           more discussion on the standard review plan in
           today's presentation, or is this it?
                       MR. MITRA:  Well, as I said before, that
           any changes in GALL have an effect on SRPLR, and we
           will discuss along -- the changes with GALL in the
           later part of the presentation.
                       CHAIRMAN BONACA:  Any other questions
           for --
                       MR. BARTON:  Yes.  Mario, I've got a
           question, and I don't know if it's timely or
           whatever.  Section 1 of the SRP, paragraph,
           it talks about timeliness of the application and
           says the licensee must submit an application at
           least five years before the license expires.  I
           don't know whether this paragraph is a "gotcha" from
           a licensee and decides late in life that I'm going
           to now extend my license, want to extend my license.
                       And I'm in my fifth year before
           expiration, and I submit an application which the
           reviewers decide is not "a sufficient application,"
           and I have to modify it.  It says I have to submit
           the modified application with at least five years.  
                       I just wonder whether if you're late in
           submitting it and you have to modify it, whether you
           can still meet the requirements of the standard
           review plan, because the next section says if I
           don't do this, the reviewer checks off, "No, I have
           not satisfied this requirement," and I get a letter
           from the NRC that says my license will expire in
           five years.  End of story.
                       And I just wonder whether that's what
           this thing really gets you -- is it a real "gotcha"
           or is there a way out of this thing?  That's the way
           I read this.
                       MR. GRIMES:  I'll respond to that
           question.  The provisions for timeliness are
           established by the rule, the guidelines, for the --
           to the staff are simply the guidelines on how to
           treat the timeliness requirements in the rule. 
           We've had several requests -- at least a couple of
           requests to take exception to the other end of the
           time scale, and that is not sooner than 20 years
           prior to expiration.
                       And it really gets to the Administrative
           Procedures Act in terms of the timeliness for the
           proceedings to occur, which were originally
           predicated on an expectation that it would take five
           years to complete a review.  
                       I would expect that if an applicant were
           to determine late in life that they still want to
           apply for license renewal, and they come in with
           less than five years to go, that they would be able
           to make a case for taking exception to that
           requirement, and then the staff would be given
           specific guidance on how to treat those specific
                       But this statute wasn't intended for the
           staff to be backed into a corner on making the
           timeliness decision.  It's an administrative
           requirement for the process.
                       MR. BARTON:  Thank you, Chris.
                       MEMBER LEITCH:  I guess I had a couple
           of technical questions in the standard review plan. 
           I'm a little unclear how we're going to proceed
           today.  Is this the appropriate time to ask those
           questions?  Or could they be discussed when we talk
           about GALL?  You're just talking about a few changes
           that have been made to the standard review plan?
                       MR. GALLETI:  Well, to the specific
           section of the SRP.  If your question relates to
           that particular section, I guess we can discuss it
           right now.
                       MEMBER LEITCH:  No, it does not.  Okay.
                       MR. LEE:  Are your questions relating to
           Chapter III of the SRP?  This is Sam Lee from NRR.
                       MEMBER LEITCH:  No.  They're mainly
           Chapter IV, actually.
                       MR. LEE:  Chapter IV?  And those -- yes,
           what are the questions?  Maybe he can help the, you
           know, panel, you know, answer that for you when they
           come up.
                       MR. BARTON:  If you want to talk about
           Chapter III, the comment I've got on Chapter III is
           there seems to be a lot of repetition in subsections
           of Chapter III.  And I don't know what your plan is
           with this document to go back and do some more
           editing, or if this is the final shot, or whatever,
           but I think you could significantly improve this
           document just by looking at Section 3.2 and some of
           the subsections -- and as an
                       There is so much repetition I think that
           you could kind of take out 90 percent of the
           repetition here and still get your point across. 
                       And the same problem occurs in the power
           steam and power conversion in Section 3.4.  If
           you'll look at those sections, I think you can
           significantly improve this document by a good
           editing job.
                       MR. GRIMES:  Our editors are going to be
           sorely disappointed.
                       CHAIRMAN BONACA:  I had just a couple of
           questions, too, about Section 3.  There are a number
           of -- for example, under auxiliary systems, there
           are some sections where the section is still there
           but at the beginning of it there is a parenthesis
           that says, "Program no longer used."  And I don't
           understand, what does it mean?  I mean --
                       MR. BARTON: and are
           examples of --
                       CHAIRMAN BONACA:  Are examples of --
                       MR. BARTON:  -- our program you say
           "Program is not used."
                       CHAIRMAN BONACA:  Yes.
                       MR. BARTON:  Kind of confusing.
                       MR. LEE:  I guess when we come to the
           auxiliary system, the panel can explain to us.
                       CHAIRMAN BONACA:  Also, before that, in
           a number of other sections, like on the
           crack initiation and growth due to stress corrosion
           cracking, that was in the old document.  It's not
           there anymore.  There are many examples of certain
           issues under certain sections that have been totally
           eliminated.  I'm sure there is a logic behind that.
                       I would like to understand how you
           restructure that eliminated those sections from the
           previous draft.  In some cases, I mean, I thought
           the issue was still there.  But I guess the
           discussion is gone, so either it has been absorbed
           somewhere else and I don't understand where, or it
           doesn't belong there and I don't understand why.
                       So if you will talk to me about that.
                       MR. LEE:  Yes, we'll talk about that
                       MR. MITRA:  Any other questions on
           Chapter II SRP?  If not, we'll leave the floor for
           Mr. Peter Kang for Chapter II and Chapter III
                       CHAIRMAN BONACA:  As we get ready for
           this presentation, there was one more question
           regarding the SRP.  It would be probably good to
           provide it now in case you want to look for an
           answer from NRR.
                       MEMBER LEITCH:  It was regarding
           Chapter IV, actually.  I wasn't sure if we were
           coming back to that or not.  4.2.3 related to the
           elimination of circumferential weld inspections for
           boiling water reactors, and I was just wondering why
           we were doing that.  Is it very difficult or
           impossible to inspect circumferential welds?  
                       It seems like what we're doing here is
           saying, well, we've made an analysis and they're
           good for 64 effective full power years.  And we're
           going to improve operator training so that we don't
           have any of these low temperature overpressurization
                       But my question still remains, why not
           just look at the welds?
                       MR. LEE:  We'll discuss that later.
                       MEMBER LEITCH:  Okay.
                       MR. LEE:  In Chapter IV of the GALL
                       MEMBER LEITCH:  That will come up later? 
                       MR. LEE:  We will do that.
                       MEMBER LEITCH:  Thanks.  Okay.
                       MR. KANG:  We are ready to talk to GALL
           Chapters II and III.
                       My name is Peter Kang, K-A-N-G, with the
           License Renewal, and --
                       MR. DAVIS:  Jim Davis from Materials and
           Chemical Engineering.
                       MR. COSTELLO:  Jim Costello from Office
           of Research.
                       MR. BRAVERMAN:  Joe Braverman,
           Brookhaven National Lab.
                       MR. ASHAR:  Hans Ashar, Mechanical and
           Civil Engineering Branch.
                       MR. MORANTE:  Rich Morante, from
           Brookhaven National Lab.
                       MR. KANG:  Okay.  For Chapter II, which
           is containment structures, and Chapter III,
           structure and the component supports,  So those two
           areas -- chapters we had in -- although there was a
           lot of changes, comments on that, but this is the
           most -- four most important issues.
                       The first has been dealt with before. 
           The first bullet is dealing with managing aging
           effects of concrete and steel for inaccessible
           areas.  In the August version of GALL we required
           evaluate the plant-specific programs whenever for
           any inaccessible areas.  When the conditions in
           accessible area may not indicate, then it presents
           degradation to some inaccessible area.
                       Since the industry commented that such a
           requirement is over and above 10 CFR 50.55A, which
           states, "Licensees shall evaluate the acceptability
           of an inaccessible area when conditions exist in an
           accessible area that could clearly indicate the
           presence of degradation to such inaccessible areas."
                       So our position was a very stringent,
           which is -- obviously, was that you've got to have a
           plant-specific whenever you have an inaccessible
           area.  So staff decided to clarify this aging
           management of an inaccessible area.  
                       The latest GALL has revised it to
           include specific criteria for, let's say, aging
           effects of concrete due to aggressive impact or
           corrosion of embedded steel.  The applicants should
           establish periodic monitoring of below-grade water
           chemistry and evaluate whether the below-grade
           environment is found to be aggressive.
                       But then we have a definition of -- or
           criteria for aggressiveness -- is based on NUREG-
           1611, which is for pH levels and chloride levels and
           sulfate.  And then --
                       MEMBER LEITCH:  Could you point us to a
           specific page on GALL?  Do you have that
                       MR. KANG:  Yes.  The latest or the
           August versions? 
                       MEMBER LEITCH:  This is the March 2001
                       MR. KANG:  Oh, the 2001.  2000 is the
           August version.
                       MEMBER LEITCH:  No, the latest one.
                       MR. KANG:  Oh, okay.  The latest one. 
                       This is first -- okay.  PWR is in the
           front sections, and BWR is in the back.  And the PWR
           Section 2, Chapter 2A, 1-3, has -- let's see here,
           this is -- okay.  Aggressive chemical is actually 1-
                       MEMBER LEITCH:  Okay.
                       MR. KANG:  Aggressive chemicals and --
           okay.  That's for one.  And then, four, aging
           effects on concrete due to leaching of calcium
           hydroxide, this is on A-1-3, the first items on the
           bottom, identified as A.1.1-B.  That one the
           applicant has to establish the leaching is not
           significant by evaluating whether the concrete is
           exposed to the flowing water.
                       Even then, you also have the conflict as
           to whether -- evaluate whether a conflict is
           constructed based on ACR 201.2.R.  This is to ensure
           the conflict is dense and well-cured and has low
                       And then the last one is steel.  For
           aging effects of steel area of containment due to
           corrosion, the concern was this is water on the
           containment floor, seeping through cracks in the
           concrete floor, or past degraded joint sealants.  
                       So to determine whether loss of material
           due to corrosion is significant the applicant
           establishes -- there was a list of four items,
           whether they -- their concrete meets the requirement
           of ACI, and the monitoring of concrete for
           penetrating cracks, and also moisture barrier.  Is
           it constructed or built in accordance with IWE
           requirements?  And then, also develop a program to
           minimize water spillage.
                       Then, so what we said was if any of
           those criteria cannot satisfy, then a plant-specific
           management program has to be developed to address
           each of those items.
                       MEMBER LEITCH:  So conversely, then, if
           all those criteria are satisfied, then no further
           action is -- no further evaluation is required.
                       MR. KANG:  Yes, that's correct.  Yes.
                       MEMBER LEITCH:  thank you.
                       MR. KANG:  Second bullet.  This is on
           managing loss of material due to corrosion of
           containment of steel elements.  In our August
           version of GALL, the report described -- what we
           said was IWE, with Appendix J and the coating
           program -- in other words, you've got to have all
           three components together.  But industry commented
           that Appendix J and the coating should be deleted,
           because IWE alone should be -- is acceptable as a
           stand-alone program.
                       MR. BARTON:  Excuse me.  "IWE" meaning
           -- what's IWE?
                       CHAIRMAN BONACA:  What does it stand
                       MR. KANG:  IWE relates to the in-service
           inspection of metallic liners and --
                       AUDIENCE MEMBER:  The code.
                       MR. BARTON:  Oh, the code?  Okay.  All
           right.  Gotcha.  Okay.
                       MR. KANG:  So then staff did that -- we
           had a lot of discussions back and forth, especially
           pertinent to Appendix J.  And the staff could not --
           we did not agree to deleting Appendix J and coating
           program.  However, in the past, the staff has
           granted the relief request for a few certain plants
           on IWE inspection, on the  maintenance of the
           protective coating to control corrosion.
                       So on that basis, the final version has
           slightly revised on the coating program.  We just
           added a statement which says the coating program is
           --  if the coating program is credit for the
           managing loss of material due to corrosion during
           current licensing terms, then you should continue
                       So that's a slight difference on this
           managing loss of material due to corrosion on the
           containment steel elements.
                       MR. BARTON:  Does this take care of
           corrosion of containment on the exterior of the
           steel as well?
                       MR. DAVIS:  No.  No, it doesn't.  It
           only applies to inside.
                       MR. BARTON:  How do you handle exterior
                       MR. DAVIS:  I'm not aware of it being a
           problem, but it --
                       MR. BARTON:  How about Oyster Creek's
                       MR. DAVIS:  Except Oyster Creek.  And
           it's not covered by the code.
                       MR. MORANTE:  This is Rich Morante from
           Brookhaven.  The basic in-service inspection
           requirements of IWE would include inspections of the
           exterior surface of a steel containment.
                       MR. KANG:  Accessible.
                       MR. MORANTE:  Of the accessible areas of
           a steel containment.
                       MR. BARTON:  Accessible areas.
                       MR. KANG:  Accessible areas.
                       MR. MORANTE:  Except that IWE, through
           10 CFR 50.55A, which invokes IWE, does require an
           evaluation of inaccessible areas if there is
           suspicion that there may be degradation there based
           on what is seen in an accessible area.
                       The sand pocket region would fall into
           one of those areas that would have to be
           specifically reviewed by an applicant, and it is
           identified in the GALL tables as an area for review
           during license renewal.
                       MR. BARTON:  Thank you.
                       MR. KANG:  Okay.  Third bullet.  The
           third bullet is for managing stress corrosion
           cracking and the crevice corrosion for the stainless
                       MEMBER SHACK:  Can we just back up for
           just a second?
                       MR. KANG:  Yes, okay.
                       MEMBER SHACK:  Go through that coatings
           program once more.  So if they have the coatings
           program -- only if they're taking credit for it -- I
           mean, that's the thing.  A lot of the time -- I see
           that in other sections, that they may have the
           program but it's only sort of required if they are
           asking credit for it.  They may try to continue the
           program, but if they can live without the credit
           then they don't want to sort of commit themselves to
           the program, is sort of what I see happening here. 
           Is that the basic idea?
                       MR. DAVIS:  A number of utilities have
           come in and asked for relief from the code
           requirements of IWE to use our coatings program
           because it's a more intense program.  And so they're
           doing it in relief of the code requirements.
                       MEMBER SHACK:  Requirements.  Oh, okay. 
           So you don't want to have both.
                       MR. MORANTE:  Well, let's say we're not
           required to --
                       MEMBER SHACK:  Required to have both.
                       MR. DAVIS:  A lot of them do both,
                       MEMBER SHACK:  Right.  Yes.  But
           required to only --
                       MR. ASHAR:  But the earlier applications
           like Calvert Cliffs, Oconee, and Hatch that I'm
           reviewing now, they all have credited coating
           program for corrosion.  So far we have seen that.
                       MR. DAVIS:  That's only in containment,
           though, not in the coatings program outside of
                       MR. ASHAR:  Yes.
                       MR. KANG:  All right.  The third bullet
           -- this is for managing stress corrosion cracking
           and the crevice corrosion for stainless steel spent
           fuel pool liner issues.  Industry commented that
           deleting monitoring of a leakage detection system
           that was discussed in August version, we had a leak
           chase monitoring of leak chase system drain lines
           and leak detection sump.
                       They commented that it should be
           replaced with just a water chemistry program as
           applicable, aging management program.  Their
           justification was the water chemistry program
           precludes aging effects by maintaining spent fuel
           parameters so that the degradation would not occur.
                       Staff has agreed or concurred that the
           water chemistry program could be identified as
           applicable aging management program.  And then also,
           in addition to water chemistry program, staff took
           the position reliance solely on controlled water
           chemistry does not manage potential degradation from
           concrete side of a spent fuel pool liner -- the
           other side of a concrete.
                       So because -- and this is because we --
           such degradation we have seen at the one plant.  So
           -- so and the latest GALL uses -- revised this one
           and said uses both a combination of the water
           chemistry program and the monitoring of pool water
           level to manage the corrosion of a stainless steel
           fuel pool liner.
                       MEMBER LEITCH:  So you're talking about
           monitoring the pool water level --
                       MR. KANG:  Yes.
                       MEMBER LEITCH:  -- rather than tell-
                       MR. KANG:  Well --
                       MEMBER LEITCH:  I mean, it would have to
           be a pretty gross leakage --
                       MR. KANG:  Right.  We --
                       MEMBER LEITCH:  -- pool water level.
                       MR. KANG:  We had a lot of discussions
           with industry at the time.  When was it?  December,
           right?  And not all industry uses that generic term
           such as leak chase, leak chase systems, or -- so we
           -- probably more appropriate just to more general --
           make it very general, say water level.  Go ahead.
                       MR. DAVIS:  Nobody really looks at the
           leak chase system to see leakage.  They watch water
           level.  And if the water level starts dropping, then
           they go look at the leak chase system and see if
           they have a leak.  That's what the industry is
           telling us their experience is.  So we agreed to
                       CHAIRMAN BONACA:  Please.
                       MEMBER FORD:  You must forgive me if
           some of my questions are simple, because this is my
           first time on this committee.  You mentioned just
           now inspection of accessible regions.  What happened
           to the inaccessible regions?
                       MR. ASHAR:  They were the first bullet. 
           If you see the first bullet that we have, it was
           referring to the inaccessible areas.  And that is
           where we concentrated, because accessible areas are
           being covered by the code -- code requirement, IWE.
                       MEMBER FORD:  Okay.
                       MR. ASHAR:  Okay.  Inaccessible we were
           a little bit concerned about.  We said did not --
           was not covered in the code, and we had to do
           something about it.  So the first thing what we have
           done was to put some provisions in the regulation,
           which is 10 CFR 50.55A, the requirement that if the
           weaknesses are found in accessible areas that
           indicates degradation of the inaccessible areas,
           then they will go and check out what is going on in
           an accessible area.  That is the way the rule is
                       Then, in NUREG-1611, we said, "If there
           is no evidence in the accessible area, and still
           there is corrosion going on, how do we get to the
           bottom of that?"  And this way in a generic way you
           say, "There is no evidence.  If the environment and
           conditions are such that could give rise to certain
           corrosion or degradation in inaccessible areas, that
           has to be investigated as a part of the license
                       MEMBER FORD:  Okay.
                       MR. ASHAR:  And in order to resolve this
           particular item, we had quite a discussion with the
           industry on this area.  And what we did was it
           looked like an open-ended thing for the industry. 
           So they said, "Identify the areas that you think are
           the most susceptible."  So we identified two areas. 
           One was the -- under the -- just over the basement,
           and on the top of it, in PWRs particularly, there is
           a concrete -- two feet of concrete.
                       Okay.  And we said, "Water always goes
           to the top of the -- up to the top, and then if
           there is cracking in the concrete, then it can seep
           in, and then it can degrade the liner below."  That
           was one concern.
                       The second concern that we expressed was
           if the chemical constituents of the soil is
           aggressive enough, it can degrade the concrete
           foundation part.  So there are the two areas that we
           identified, and then together with industry worked
           on the criteria and everything.  And we came out
           with the criteria that we have in the GALL Report.
                       MEMBER FORD:  Thank you.
                       MEMBER SHACK:  Just on this water
           chemistry program for the spent fuel pool liner,
           they're arguing basically the temperature is low
           enough that if they control the water chemistry they
           can manage the cracking of the stainless steel.
                       MR. DAVIS:  That's right.
                       MEMBER SHACK:  And what temperature are
           we talking about here, and how stringent are the
           controls on the water chemistry?
                       MR. DAVIS:  It's always below about 200
           degrees F.
                       MEMBER SHACK:  200F.
                       MR. DAVIS:  And that's controlled.
                       MEMBER SHACK:  And what controls do they
           put on the water chemistry, typically?  I mean, it's
           not as pure as a BWR, obviously.
                       MR. DAVIS:  It's the regular reactor
           vessel, RCS chemistry that --
                       MEMBER SHACK:  Chemistry.
                       MR. DAVIS:  -- guidelines, the EPRI
           guidelines.  You have the same chemistry in the
           spent fuel pool that you have in the RCS.
                       MEMBER SHACK:  RCS.  I see.  There's no
           boron additions, or something?  No?
                       MR. DAVIS:  Not in a BWR. 
                       MEMBER SHACK:  Not in a BWR.
                       MR. DAVIS:  But since you're
           transferring fuel back and forth, you have to have
           the same chemistry.
                       MEMBER UHRIG:  If you dump the water and
           boron in the fuel pool at all, is it soluble?
                       MR. DAVIS:  In a PWR, you do.  In a BWR,
           you do not.
                       MEMBER UHRIG:  In the fuel pool.
                       MR. DAVIS:  In the fuel pool.
                       CHAIRMAN BONACA:  This is pretty much
           what they do right now, right?
                       MR. DAVIS:  Yes.
                       CHAIRMAN BONACA:  That's all.
                       MR. KANG:  Okay.  The last bullet deals
           with that -- the August version of GALL included --
           we had included cracking of metal component support
           members due to vibratory loads and the cyclic
           loading.  The industry commented that there was --
           that this is not a license renewal item and should
           be deleted.
                       Their justification was that, number
           one, proper design eliminates or compensates for the
           vibrations and the cyclic loadings.  And then, also,
           what they said was vibration characteristically
           leads to cracking in the short period of time on
           order of hours or maybe days of operations.  Such a
           failure is probably early -- also occurs early in
                       Because of this time period that --
           because this time period is short when compared to
           the overall plant operating life, cracking will be
           identified and corrected to prevent occurrence long
           before the period of extended operations.  And they
           also said that this degradation is very limited in
           small -- a small set of components, and there is
           corrective as -- as discovered.
                       The staff has agreed that cracks in the
           steel elements component supports caused by
           vibratory stress would be developed in a matter of
           hours or days.
                       This timeframe is not consistent -- so
           this timeframe is not consistent with the
           requirements of the license renewal rule, which
           addresses a slow aging process affected by extended
           operations.  So staff agreed to delete cracking of
           metal components from the latest GALL Report.
                       MEMBER LEITCH:  Now, that comment,
           again, still applies just to steel structures.
                       MR. KANG:  Yes, supports.  Yes. 
           Component support sections of Chapter III.
                       CHAIRMAN BONACA:  Only support section. 
           So it doesn't affect your definition, for example,
           of complex assemblies that we have seen; for
           example, the casing of a structure like fans that --
                       MR. KANG:  This is a Class I and a Class
           II and III and small support areas.
                       MR. MORANTE:  Well, I'm not familiar
           with the complex structures issue on --
                       CHAIRMAN BONACA:  Well, I'm talking
           about, for example, an HVAC fan hanging from some
           ceiling out there, and there are structural members
           that hold it.  Typically, the fan will have some
           vibrations in it maybe.
                       MR. MORANTE:  Right.  I would expect
           that in that case we -- we must keep in mind that
           there are certain cases where supports, especially
           piping supports, may have been designed considering
           cyclic loading.  Those are still included in GALL as
           -- they need to be addressed as a TLAA.
                       The areas we're considering here is
           where the supports for piping or other structures
           were not necessarily designed to withstand any type
           of cyclic loading.  So the vibratory loading that
           might occur would be an unusual event, not a design
           basis event.
                       For the case of the fan support, one
           would expect that the design of that supporting
           system for a fan that would tend to have a certain
           vibratory load would be inherent in the design, and
           it should be considered that way.  So this would not
           really cover that particular case.
                       CHAIRMAN BONACA:  I'm trying to
           understand it because I know in the Hatch
           application that we will review tomorrow there are a
           number of issues to do with passive components of
           active systems that should be still within license
           renewal, and a list that was disseminated made by
           the SCR.  And some of those passive components
           include casings of HVAC systems as well as frames,
           or whatever, supports of active components.
                       So I just am wondering, you know, when
           we begin to cut it so close in the different issues,
           and then it becomes hazy, or whether it applies,
           whether it doesn't apply.
                       MR. MORANTE:  In the current GALL, in
           Chapter IIIB, we do specifically address supports
           for components such as fans, probably a vibration
           isolator.  That's a specific line item in the GALL
           tables that are subject to review.
                       CHAIRMAN BONACA:  Okay.  So there is --
                       MR. MORANTE:  Whether it exactly covers
           the case you're concerned about on Hatch, I couldn't
           answer that question.
                       CHAIRMAN BONACA:  We'll talk about it
                       MEMBER SHACK:  Now, again, are these
           anticipatory -- anticipated vibratory loads or
           unanticipated vibratory loads we're talking about
                       MR. ASHAR:  I would say unanticipated. 
           If they are anticipated, they will go into the
           analysis or TLAA.
                       MEMBER SHACK:  Well, I mean, I can sort
           of envision an anticipated fatigue load I'd handle
           in two ways.  One, I'd do a cyclic analysis, and the
           other one I would say, well, my vibratory loads are
           below my threshold, or, therefore, I can run
                       MR. ASHAR:  Exactly.
                       MEMBER SHACK:  If I have an
           unanticipated load, it doesn't seem to me to follow
           into either one of those.
                       MR. ASHAR:  And then it wouldn't be any
           measurement.  It will be just like in the current
           license what is happening.  Same thing will happen
           in an extended period of life, and it should be
           taken care of.
                       MEMBER SHACK:  When I find that I have
           vibratory loads that I didn't anticipate, I mean, I
           do something about it, right?  I either go out and I
           do an analysis, or I --
                       MR. ASHAR:  Yes.
                       MR. MORANTE:  I'd like to address that. 
           You're correct when you say if the -- if the
           vibratory loads are below the endurance limit, then
           you can have an infinite number of these cycles. 
           You're not going to see a problem.  So, obviously,
           the concern is vibratory loads that would exceed
           that level.  If you exceed that level, and it's a
           true vibratory loading, you're going to generate
           millions of cycles in a very short period of time
           and are likely to generate a failure locally.
                       Now, what the industry has said is we
           have to deal with that in the hear and now.  It's
           really not a license renewal issue.  It's an
           operation -- it's an operating issue.  And whether
           we're operating in the first 40 years of life, or
           years 40 to 60, is irrelevant.  We have to address
           it when we find this kind of problem, and we
           basically looked at it again and said, "Yes, we
           agree with you that it doesn't -- it's not really a
           slow aging process.  It's an operational problem
           that you need to address immediately."
                       So that's the reason for us removing it
                       MEMBER SHACK:  Okay.  I mean, I guess
           you're right.  
                       MR. DAVIS:  It goes into your Appendix
           B, Corrective Action Program.
                       MEMBER SHACK:  But, I mean, it is a
           cumulative damage process.  But in high cycle, the
           difference between 60 and 40 is nothing.
                       MR. MORANTE:  Right.  If it's going to
           happen in a matter of days or a week or so, does it
           matter at what point during that 40-year or 60-year
           life that it occurs?  And that's the basis for
           removing the consideration.
                       MR. KUO:  This is P.T. Kuo, License
           Renewal and Standardization Branch.  If I may
           clarify a little  bit.  This item here only deals
           with those supports for the steel structures or
           frames or cabinets or -- it is not -- those supports
           are not designed for any vibratory motion.
                       If they are, then it will be designed
           according to the fatigue rule that -- that is
           described in ASME Code Section 3 or used under the
           code requirement.  But these are those things that
           are not designed according to those rules, not
           required to design -- to be designed according to
           those rules.
                       And that the vibration were due to some
           unanticipated sources like pump vibrations.  We
           never expect it, but because of some other reasons
           it vibrates, you know, high vibration amplitude. 
           There are two ways to mitigate those problems.  One
           is to immediately correct the problems, the problem
           source.  The other one is that if it vibrates really
           with high intensity, you see the result right away. 
           It doesn't accumulate from 40 to 60.
                       CHAIRMAN BONACA:  Okay.  Any other
           questions?  If not, then I think we need a break. 
           It's 20 of 10:00.  So we will meet again at five of
                                   (Whereupon, the proceedings in the
                       foregoing matter went off the record at
                       9:40 a.m. and went back on the record at
                       9:56 a.m.)
                       CHAIRMAN BONACA:  Okay.  Let's resume
           the meeting now, and we have a presentation on
           Chapter IV of the GALL Report.
                       MR. DOZIER:  Yes, sir.  Good morning. 
           My name is Jerry Dozier from the License Renewal and
           Standardization Branch.  I have Barry Elliot from
           Engineering, Omesh Chopra from Argonne National Lab,
           and Mike McNeil from Research.
                       Chapter IV deals with the reactor vessel
           internals, the vessel itself, and also the reactor
           coolant system.  These five bullets represent
           examples where public comments were resolved for
           repackaging, providing minimal acceptable programs,
           providing a real focus of concern, ensuring
           relevance and completeness in the GALL Report.
                       For the first item, that's an example of
           repackaging.  In the ACRS meeting, we had
           considerable discussion about neutron fluence
           levels, and what is the threshold for ISCC, or when
           does void swelling come into effect.  We also had
           industry discussions and debates about that
           particular issue.
                       On the one hand, it was an argument of
           accounting of materials versus thresholds, or we
           could focus on what we really wanted the aging
           management program to be.  What we really wanted in
           this aging management program was to monitor the
           most susceptible locations and provide a method for
           inspection to detect that mechanism.  
                       And that's what we really wanted, and we
           wrote an additional program, and it was consistent
           with Calvert Cliffs, that would accept that program. 
           And if the licensee was willing to do that, then it
           would require no further evaluation.
                       The second one deals with minimal
           acceptable programs.  Earlier, in the August
           edition, we had boric acid corrosion, and we also
           credited in-service inspection.  NEI goes into --
                       MEMBER LEITCH:  Before you move on to
           the second bullet there, where is the -- could you
           point me to the section in GALL where the change was
                       MR. DOZIER:  Yes, sir.  In Chapter XI,
           Program M16 titled "PWR Vessel Internals" is the new
           program that was written.
                       MEMBER LEITCH:  Okay.  Thank you.
                       MR. DOZIER:  Was there any question?
                       MEMBER LEITCH:  No.  I just --
                       MR. DOZIER:  Okay.
                       MEMBER LEITCH:  -- want to know for
           reference.  That's all.
                       MR. DOZIER:  Yes, sir.
                       For boric acid corrosion, as we see it
           earlier, ISI could be a mechanism also -- could be a
           program that could be credited.  NEI asked for the
           minimal acceptable program.  Boric acid corrosion
           has been effective in the current term, and we feel
           like that it would be effective in the extended term
           for controlling boric acid corrosion.
                       So now in GALL we only have the boric
           acid corrosion program monitoring being credited for
           the boric acid corrosion.
                       CHAIRMAN BONACA:  The boric acid
           corrosion problem, this is a visual program?
                       MR. DOZIER:  Yes, sir.  It is a visual
           program, whereas in ISI we were also looking at
           crediting possibly -- when the -- during the
           pressure test, you make it to detect some boric acid
           corrosion.  If it was in an inaccessible area, or if
           it was covered by insulation, we thought that it
           might be effective, you know, also for that.  For --
                       CHAIRMAN BONACA:  And this is all
           components, anything which is effective -- this is
           effective boric acid corrosion.  I mean, so in
           general it doesn't talk about --
                       MR. ELLIOT:  This is not a coupon
           program.  This is an inspection program of the
           actual components.
                       CHAIRMAN BONACA:  Okay.  I understand. 
           All right.
                       MR. DOZIER:  Okay.  The next one is an
           example of how we got -- we made GALL more focused. 
           Earlier this was -- this PWSCC was primarily plant-
           specific, but now we focused it on for -- for the
           Inconel 600 penetrations they are primarily being
           adequately managed by the chemistry and ISI program.
                       However, for the Inconel 182 welds, we
           do need a plant-specific evaluation.  Now, of
           course, in that example, again, we're trying to
           focus the licensee really where they need to be in
           the -- or what we really want to see in the review
                       There was also some comments that for --
           for some components there were a lot of aging
           effects.  And sometimes maybe one or two of those
           aging effects may not have been really applicable,
           and we removed those from the GALL Report.  For
           example, wear/loss of material for the core support
           pads and the guide tubes.  Those were really not
           significant and we removed them.
                       Have we removed the component?  No. 
           They are still in there.  Just that particular aging
           effect was removed.
                       CHAIRMAN BONACA:  Just because we
           haven't seen wear or loss of material for core
           support pads and guide tube cards?  Or why else?
                       MR. ELLIOT:  That's the reason.  They've
           been looking at it over the years, the industry, and
           they -- and they mention it as something they look
           for, but they haven't seen anything significant.  So
           since it was not significant all these years, that
           we've decided to remove it and concentrate on the
           other aging effects that could affect these
                       CHAIRMAN BONACA:  But you are telling me
           they are looking at them.  That's why they know that
           there isn't.  So --
                       MR. ELLIOT:  Right.
                       CHAIRMAN BONACA:  -- I mean, it's a
           closed circle.  Are they going to stop looking at
           them, because --
                       MR. ELLIOT:  No.  There's an ISI
           program, you know --
                       CHAIRMAN BONACA:  No.  I mean -- all
           right.  So it's not specific -- specifically tied to
           license renewal, but it's still -- okay.  So there
           is not a commitment under license renewal.  That's
           what you're saying.
                       MR. ELLIOT:  Right.
                       MR. DOZIER:  The last bullet is more of
           a completeness issue.  One of the -- we had several
           comments where NEI would ask for additional
           components be added, so that they could be credited. 
           And we tried to accommodate those requests, so that
           it would be easier for the licensee to reference the
           GALL Report.
                       In this case, we are talking about the
           CRD head penetration.  That was an NEI comment. 
           Actually, this incore neutron flux monitoring tubes
           was a request from Union of Concerned Scientists. 
           So we tried to accommodate and make GALL as complete
           as we could based on those comments.
                       CHAIRMAN BONACA:  Before you move on, if
           you could go back to that PWSCC of pressurizer
           Inconel 600 penetrations.  Now, here the concern you
           -- the intent was to focus the program where it's
           needed, you said.  Okay?
                       MR. DOZIER:  Yes.
                       CHAIRMAN BONACA:  Is there a concern
           that when you begin to focus too much you may not --
           now you may inadvertently neglect some areas where,
           you know, you don't know exactly but it would be --
           you know what I'm trying to say?
                       MR. DOZIER:  Okay.  Well, the GALL
           Report actually is a self-check mechanism in it, and
           it -- even though -- say we don't mention an aging
           effect.  If we don't mean the aging effect, that
           does not relieve the licensee to identify that
           effect and also report it to us in that application. 
           He can only take credit for the things that are
           enveloped in the GALL Report.
                       So any -- any other -- that's the good
           thing about GALL is that any new aging effects, or
           whatever, that may come down the pike, if we have
           not addressed them, they will come in as a plant-
           specific evaluation.
                       Barry, I think you --
                       MR. ELLIOT:  Yes.  On PWSCC of the
           pressurizer, 600 components, what our experience is
           today is that the 600 component is-- the limiting
           materials are in the upper head.  And that's where
           we're concentrating our inspections and our efforts.
                       If we see in the current license that we
           need to expand the locations for inspection, then we
           would -- we might include the pressurizer.  But at
           the moment, our experience is that the Inconel 600
           type cracking is in the upper head.  And so that's
           where we're concentrating our effort.
                       The Inconel 182, of course, is a recent
           issue, and it has more -- you know, it is in a lot
           more locations, safe-ends, and all over, and that
           gets -- and that's why it's plant-specific.
                       CHAIRMAN BONACA:  Okay.  I think you
           have answered my question.  My concern was when you
           focus on something, it implies that you know exactly
           where to look.  Now, you know, these are -- there
           are so many applications of this -- different
           materials there, and that was the question I was
           asking you.  And you answered that.
                       MR. DOZIER:  Okay.  From Chapter IV, we
           had a couple of issues that we were continuing the
           NEI dialogue on.  One of those dealt with the
           operating experience with cracking of small-bore
           piping, and the other was management of loss of
           preload of reactor vessel internals bolting using
           the loose parts monitoring system.  And those we are
           continuing the dialogue with NEI to come to
           resolution on.
                       MEMBER SHACK:  Okay.  Can you describe
           the issues of contention here?
                       MR. DOZIER:  The first deals with small-
           bore piping, and basically they are asking about the
           operating experience.  They are saying, have we
           really got enough operating experience for us to
           justify the one-time inspection that we are -- that
           we now have in the GALL Report?  If you look at some
           of the operating experience, they may be because of,
           say, a weld defect, or there may be some event-
           driven issue.
                       But our bigger issue is that we feel
           like this -- that small-bore piping will be a
           concern in the extended period.  So, really,
           regardless of our operating experience, we probably
           still want to pursue the small-bore piping.  
                       And also, there is a -- a materials
           research project being performed by EPRI, and we
           want to follow that and -- you know, for the
           complete resolution of small-bore piping.  So I
           think that -- in that particular case, it's really
           an issue that's -- that's continuing forward, and so
           it's one good to keep a dialogue on.
                       The next deals with loss of preload of
           reactor vessel internals bolting.  Their contention
           is that ISI is good enough.  We credited also the
           loose parts monitoring system, you know, for this
           aging effect.  And the real issue is, is ISI good
           enough?  And we're still exploring that.
                       Also, with loose parts monitoring, some
           of them took -- took loose parts monitoring out of
           their tech specs and had -- have not -- have not now
           got it even plugged up, or I guess not operating
           further.  What we don't want GALL to be is a
           document that says, "This is the minimum program." 
           If they don't have a loose parts monitoring system,
           of course, they can come up with any plant-specific
           ways to monitor that aging effect.
                       MEMBER SHACK:  Well, I thought that's
           what GALL was was a minimum program, that this is
           what you have to have.  If you have anything more,
           that's fine and dandy.
                       MR. ELLIOT:  I think industry is arguing
           that loose parts monitoring is an additional program
           that they don't need for monitoring this aging
           effect, and that their concern -- it's our concern,
           too -- is that you don't want to put in a program
           that monitors a particular aging effect, and that
           puts the plant in a less safe condition.  Like what
           happens if they -- one of the problems, they have
           loose parts monitoring.  They've shut plants down
           looking for things that were not there.  
                       So that we don't want to start that --
           down that road again.  We've already done it in the
           current license, take out the loose parts
           monitoring.  We don't want to put it back in.  You
           know, we're discussing that, whether it's necessary
           to manage this aging effect using that.
                       MR. DOZIER:  The way it initially got in
           there was actually through a Westinghouse topical
           report that referenced that was the way they would
           do it.  So we kind of got the idea from them, and
           then as this has grown we've learned more.  And,
           again, I think the dialogue in this particular case
           is a good one to keep going.
                       MEMBER LEITCH:  Can you help me work my
           way through here?  I'm trying to find out about BWR
           circumferential welds.  All right?  So when I go to
           the -- I go to the GALL Report, and A.1.2 is for BWR
           vessel shelves, and I guess an intermediate belt
           line shell.
                       MR. ELLIOT:  Do you want to take a look
           at this?
                       MEMBER LEITCH:  Please, yes.
                       MR. ELLIOT:  Okay.  Page 5 -- 4.A.1.5.  
                       MEMBER LEITCH:  4.A.1.5.  Okay.  And
           that's -- is that --
                       MR. ELLIOT:  And it is the vessel shell
           -- intermediate belt line shell, belt line welds,
           and the aging effect is loss of fraction toughness,
           neutron irradiation embrittlement.  Do you have
                       MEMBER LEITCH:  Yes.  Right.
                       MR. ELLIOT:  In managing neutron
           irradiation in BWRs we look at the impact of the
           radiation embrittlement on the pressure temperature
           limits, on the upper shelf energy, and we look at
           the impact of the radiation embrittlement on whether
           or not we need to -- a circumferential weld
                       MEMBER LEITCH:  Right.
                       MR. ELLIOT:  And under the current
           licensing term, we did a review and we determined
           that the failure probability for circumferential
           welds were so low that we didn't need to include a
           circumferential weld inspection, that we could get
           along with just the axial weld inspection as like
           they would be more susceptible to cracking than --
           the radiation embrittlement than the circumferential
           weld.  And that analysis was done for four years.
                       MEMBER LEITCH:  Right.
                       MR. ELLIOT:  And it assumes certain
           radiation embrittlement criteria.  Now, as long as
           you met that criteria for the 60 years, you would
           still satisfy the failure probability evaluation
           which was used for the first 40 years.  And that's
           what this is intended to do is it -- is for the
           licensees to show how they meet that neutron
           irradiation embrittlement criteria.
                       MEMBER LEITCH:  And there's a discussion
           about 64 effective full power years?
                       MR. ELLIOT:  Well, 64 -- okay.  What we
           did, we did the original evaluation of the BWRVIP
           05, which is circumferential weld.  They did the
           original evaluation for 32 years, effective full
           power years.  And the ACRS raised the question:  is
           this a cliff, that if you go past 32 effective full
           power years all of a sudden does radiation
           embrittlement cause a high increase in failure
                       So we asked the VIP to evaluate 64
           effective full power years, twice the amount of
           time.  And they did.  And it didn't fall off a
           cliff.  It was a gradual change in radiation
                       For license renewal, we wouldn't be
           using the 64 effective full power year criteria.  We
           would want them to meet -- and our evaluation was
           for the 32 effective full power criteria.  We would
           want them to show that at 48 effective full power
           years they could meet the 32 effective full power
                       MEMBER LEITCH:  Okay.  So 48 effective
           full power years for --
                       MR. ELLIOT:  Forty-eight effective full
           power is 60 years.
                       MEMBER LEITCH:  -- 60 years.
                       MR. ELLIOT:  Eighty percent, 60 years.
                       MEMBER LEITCH:  Yes.  So the reason
           we're not requiring inspection of the
           circumferential welds is basically even at 60 years,
           or 48 effective full power years, they have an
           extremely low probability of failure.
                       MR. ELLIOT:  Yes.
                       MEMBER LEITCH:  And plus the fact
           there's a requirement to do some additional operator
           training to --
                       MR. ELLIOT:  Yes, that's part of -- we
           found out that there are certain events that are key
           to this that could cause -- that are significant. 
           As long as they have operator training to preclude
           those events, that's like a defense in depth.
                       MEMBER LEITCH:  Are these welds
           particularly difficult to inspect?
                       MR. ELLIOT:  Yes.  They're --
                       MEMBER LEITCH:  More difficult than the
           axial welds or --
                       MR. ELLIOT:  It's a matter of location. 
           I mean, the axial welds are hard, too.  It's -- you
           need special equipment for the axial welds also.
                       MEMBER LEITCH:  Okay.  Thank you.
                       MEMBER UHRIG:  One question.  You
           alluded to the 32 years or 48 years.
                       MR. ELLIOT:  Effective full power.
                       MEMBER UHRIG:  Effective full power
           years.  And given the increased performance in the
           last few years of the plants, it's likely that one
           of these limits is going to be exceeded before the
           license expires.  Are you -- how do you -- it's the
           license that controls, not the 48 --
                       MR. ELLIOT:  What really controls here
           is not the 48 effective full power years or the 32,
           whatever.  It is neutron fluence.  That's what we're
           really using here.  So as long as the neutron
           fluence estimate they use for the evaluation,
           whether it's 32 or 48 or whatever, is not exceeded
           by the end of the license, then they're adequate.
                       MEMBER UHRIG:  Okay.
                       MR. ELLIOT:  And as long as they monitor
           the neutron fluence, which is what they do, and they
           stay within their limit, whatever they said is in
           their application, they're going to meet the
                       MR. DOZIER:  Any further questions for
           Chapter IV or -- Dr. Bonaca, I think you had
           mentioned some -- maybe some SRP questions for
           Section 3.1.
                       CHAIRMAN BONACA:  We had some questions,
           yes.  If I remember -- well, there were some areas
           which were eliminated from the previous draft, like
           I can give some examples of one I notice.  One was
           under -- in management division.  That's probably
           for the next presentation, right?
                       MR. DOZIER:  Yes.
                       CHAIRMAN BONACA:  Okay.  So I'll wait
           for that.  We talked about the complexity of
           performing inspections on welds.  And any lessons
           learned from the disassemble experience on those
                       MR. ELLIOT:  Well, it says that we used
           to be very concerned about Inconel 600.  Now we're
           really concerned about the welds.
                       In fact, much more concerned about the
           welds.  And that's reflected here.
                       CHAIRMAN BONACA:  Well, I'm more
           concerned about the inspections, actually.  I mean
                       MR. ELLIOT:  Right.
                       CHAIRMAN BONACA:  -- it says that, you
           know, here you have full inspections and --
                       MR. ELLIOT:  Right.
                       CHAIRMAN BONACA:  -- you see nothing,
           and then you have a crack, and then you inspect
           again and you find --
                       MR. ELLIOT:  Right.
                       CHAIRMAN BONACA:  Which it seems to me
           the whole aging and, in general, license renewal is
           predicated on inspecting, seeing, and fixing.  And
           so that's why I asked the question I guess.
                       MR. ELLIOT:  Yes.  I mean, whatever we
           work out in the current term for the Inconel 182, I
           mean, will carry forward into the license renewal
           term for inspection.
                       CHAIRMAN BONACA:  Okay.  Thank you.
                       MR. ELLIOT:  Okay.  Thank you very much.
                       MEMBER LEITCH:  Excuse me.  I had
           another question.  I guess -- excuse me for jumping
           around here, but this concerns the generic safety
           issue, and I guess the issue is basically there's a
           concern that the effects of the reactor coolant
           environment on the fatigue life of components were
           not adequately addressed in the code of record.  I'm
           referring here to the -- to page 4.3-2 of the SER.
                       And I guess my comment is that it seems
           like 40 years is at the margin, and I'm wondering
           how we can justify 60 years.  Is that --
                       MR. ELLIOT:  Okay.  First, I'm not the
           fatigue expert.  The fatigue expert is John Fair,
           and he can answer this question a lot better.  But
           what I will say is that -- that as far as GALL is
           concerned, fatigue is a TLAA and it has to be
           evaluated by each plant.  And that's how we handle
           it for GALL, because we are concerned that they
           could exceed the limit between -- during the
           operating term.
                       MR. CHOPRA:  I just wanted to add one --
           that GALL requires them to address for all Class I
           components to address the effect of environment on
                       MR. KUO:  This is P.T. Kuo, License
           Renewal and Standardization Branch again.  The
           fatigue issue will be addressed in Chapter IV of the
           GALL Report.  That is the TLAA, and you will see
           some generic programs in Chapter X of GALL.
                       MEMBER LEITCH:  In Chapter which?
                       MR. KUO:  Chapter X.
                       MEMBER LEITCH:  Chapter X.
                       MR. KUO:  Yes.
                       MEMBER LEITCH:  And we're going to
           discuss that a little later today?
                       MR. KUO:  Right.
                       MEMBER LEITCH:  Okay.  Thank you.
                       MR. KUO:  You're welcome.
                       MR. DOZIER:  Thank you.
                       MR. KLEEH:  Good morning.  My name is
           Edmund Kleeh, and I'm representing the License
           Renewal Branch.  On my right is Mr. James Davis, and
           on my left is Mr. Crockett Petney, and we also have
           Chris Parchuski, all from the NRR, Division of
                       I would like to present the first four
           changes or items on this slide, which indicate the
           flavor of the changes between the August and current
           versions of GALL for Chapter V.
                       The first item is that water chemistry
           adequately manages transgranular stress corrosion
           cracking in the containment spray and safety
           injection systems of a PWR.  Stress corrosion
           cracking for stainless steel components exposed to
           borated water can occur at temperatures below 200
           degrees Fahrenheit only if containments like
           sulphites, sulphates, and chlorides are present in
           the water.
                       Stress corrosion cracking does not occur
           if water chemistry controls the level of those
           containments below stated levels.  
                       You have previously addressed the change
           in the SRP Section  There was a renumbering
           of that section of the SRP, and the particular
           section that you're talking about was deleted
           because there was no further evaluation of stress
           corrosion cracking in regard to the safety injection
           tanks and the refueling water tanks, because the
           one-time inspection was no longer required.
                       CHAIRMAN BONACA:  Okay.  I understand. 
           Okay.  So it's the elimination of those chapters. 
           That's what I imagined, but I wasn't clear there. 
           So the elimination was due to the fact that the
           concern is gone; you don't have to address it
           specifically anymore.
                       MR. KUO:  Right.
                       CHAIRMAN BONACA:  That's why you don't
           have that.
                       MR. KUO:  Right.
                       MR. LEE:  This is Sam Lee.  That's what
           we meant when we changed the GALL Report.  We just
           made the conforming changes in the SRP.  So when you
           see the SRP, some of the things have disappeared,
           because they have disappeared from GALL.
                       CHAIRMAN BONACA:  Yes.  What about the
           other issue of those headings where there is a full
           description of the program, but then in parentheses
           there is written program no longer --
                       MR. LEE:  You'll hear that.  We're going
           to discuss that later.
                       MEMBER LEITCH:  Does the water chemistry
           program, in addition to prescribing steady state
           limits, also discuss actions for excursions, say,
           unexpected chloride intrusion or --
                       MR. KLEEH:  What I would think would
           happen here is that the water chemistry is a program
           -- is an existing program.  So the plant -- the
           licensee would address that under Appendix -- or 10
           CFR 50, Appendix B, for any corrective actions that
           had to be taken.  It's an existing program, so it
           will be addressed in that manner.
                       MEMBER LEITCH:  Okay.
                       MR. KLEEH:  The next item is that
           general corrosion causes loss of material for carbon
           steel components in air but not for stainless steel
           components exposed to water systems.  Pitting and
           crevice corrosion of carbon steel require an aqueous
           environment, with their aggressiveness dependent on
           local chemistry conditions like oxygen levels and
           component configuration.
                       And also, general corrosion is a
           thinning of a metal surface due to chemical attack
           on aggressive environment, but stainless steel
           components are not susceptible to it unless
           containments are present.  This was just a
           conforming change that we made to GALL Chapter V.
                       The third item is that filters are
           considered short-lived components.  They are
           typically replaced based on performance conditioning
           monitoring, which indicates the end of each of their
           qualified lives.  They may excluded on a plant-
           specific basis from aging management review under 10
           CFR Part 5421.
                       And not to further elaborate on it, but
           this was also -- there was also a deletion here in
                       And the last item is management of
           external surfaces of carbon steel components is
           plant-specific.  Only service Level I coatings are
           in scope of the aging management program for
           monitoring and maintenance of coatings.  The
           intended function of a component is not affected by
           the degradation of its service Level II and III
                       Are there any questions on the items
           that I've covered?
                       MEMBER FORD:  I have a question.  You
           made some very definitive statements on the first
           two bullets as to when you are going to or not get
           localized corrosion, stress corrosion, pitting,
           etcetera.  Unfortunately, we know from history that
           you are always bitten in the future by such an
           occurrence.  You've changed something in material or
           the environment which you did not anticipate.
                       How are those unanticipated changes
           covered in this whole process?  And, again, I'm
           talking from lack of knowledge.
                       MR. KLEEH:  I'll let James Davis answer
           that question.
                       MR. DAVIS:  That, again, goes into your
           Appendix B, Corrective Action Program.
                       MEMBER FORD:  Okay.
                       MR. DAVIS:  So you deal with it as an --
                       MEMBER FORD:  So the whole process is
           compliant enough that you can take into account
           these unanticipated things in the future.
                       MR. DAVIS:  Yes, that's the purpose of
           the Appendix B program is when you have an unusual
           occurrence, then you take corrective action.
                       MEMBER FORD:  Okay.
                       MR. DAVIS:  You analyze the situation,
           determine why it occurred, and then you correct it
           with your corrective action program.
                       MR. GRIMES:  This is Chris Grimes.  I'd
           like to add to that that the requirements for the
           renewed license also provide that the -- this
           revised licensing basis, for which there is
           significant industry sensitivity to the extent of
           the commitments for these aging management programs,
           it provides the boundaries upon which Appendix B
           operates because if the design has changed, or if
           the environment has changed, or if the assumptions
           associated with the effectiveness of the aging
           management programs somehow are changed in the
           future, then the renewed license demands that those
           changes be addressed in terms of their impact on the
           licensing basis.
                       So if we're bitten somehow in the
           future, it would be our expectation that the
           licensing basis would be maintained by these
           departures being addressed with respect to the
           effectiveness of aging management.
                       MR. DAVIS:  Event-driven occurrences are
           included from this license renewal and from GALL. 
           So if it's some event that occurs, you don't
           consider it in GALL, like a spill or something like
                       MEMBER FORD:  Well, I wasn't talking
           about things like spills or other things like that. 
           I was talking about major systemic problems, like we
           didn't know that core cracking would occur until it
                       MR. DAVIS:  That's right.
                       MEMBER FORD:  And now that -- in the
           hind events, we know why it occurred, but we didn't
           know at time zero.
                       MR. KLEEH:  That concludes the
           presentation on these first four items.  The next
           items on this slide and the one on the following
           slide will be presented by Kimberley Rico.
                       MS. RICO:  Hi.  My name is Kimberley
           Rico.  I'm with the License Renewal Branch.  The
           fifth bullet on the screen is an issue raised by NEI
           concerning biofouling and the buildup of deposits. 
           And it -- the issue of whether flow was an active
           function, and we determined that biofouling affects
           both flow performance and pressure boundary
           integrity.  But flow performance is considered an
           active function covered under the current licensing
           basis and should not be included within the scope of
           license renewal.
                       However, biofouling causes loss of
           material, which affects the pressure boundary, and
           this passive function requires aging management.  So
           however -- in order not to contradict the license
           renewal issue Number 98-105, which states that the
           heat transfer function for heat exchangers is within
           the scope of license renewal.  So biofouling was
           kept in for the heat exchanger tubes for buildup of
                       The last bullet on the screen is we
           added an alternative AMP to the Chapter XI for the
           buried piping.  NEI was concerned with the current
           program that we had, followed the NACE standards,
           and we didn't want the NACE standards which aren't
           currently required to become the standard, that we
           wanted to give them an alternative program.  
                       And that was one of the purposes of GALL
           was that eventually it would be multiple AMPs for
           certain aging effects.  And so we created a new AMP
           -- M34 and buried piping tanks and inspection.
                       MEMBER LEITCH:  On that biofouling
           issue, just -- I'm still thinking about that a
           little bit.  You said that you did include
           biofouling as an aging management program?
                       MS. RICO:  Yes.  We kept biofouling as
           an aging mechanism, but we -- the effect is loss of
                       MEMBER LEITCH:  Not heat transfer.
                       MS. RICO:  Well, in the heat exchanger
           tubes we kept buildup of deposit, the restriction of
           flow, as the aging effect mechanism for the -- only
           the heat exchanger tubes.
                       MEMBER LEITCH:  Okay.  But does that --
           did you think about plants that are now experiencing
           asiatic clams in their cooling water systems? 
           There's growing concern about asiatic clams.
                       MR. DAVIS:  The zebra mussels probably.
                       MEMBER LEITCH:  The zebra mussels, yes.
                       MR. DAVIS:  Generic Letter 89-13
           addresses service water fouling, and in that one of
           the ways they suggest that you control or monitor
           fouling is by measuring the efficiency of your heat
           exchangers.  And you can tell very quickly if you're
           having a problem either from fouling or from zebra
                       MR. BARTON:  That's covered by existing
           programs, right?
                       MR. DAVIS:  That's an existing program.
                       MEMBER LEITCH:  Okay.  So that's
           excluded from the aging management, then.
                       MR. GRIMES:  This is Chris Grimes.  And
           I hope you won't think I'm overly trite, but we did
           have some difficulty trying to draw this fine
           distinction between what are active functions and
           what are passive functions.  And quite candidly, the
           performance monitoring -- those things that get to
           flow and heat exchanger efficiency, they are much
           more palatable if you think of them in terms of the
           active system demands and performance and system
                       And so for our purpose we focused on
           aging effects.  Heat transfer is not an aging
           effect.  Heat transfer is more related to system
           performance that is challenged on a fairly frequent
           basis.  But we couldn't extend that logic to the --
           so far as to say that crud buildup doesn't have some
           impact on loss of material, which is an aging
           effect.  So that was -- that's the focus of GALL. 
           And it is a rather subtle and fine distinction, and
           it's not really easy to articulate.
                       MEMBER LEITCH:  Yes.  Another concern
           that I had in that area, the plant, as you think out
           in terms of the forebay and dredging considerations,
           and all that type of thing which, you know, that --
           that is -- like silt building up in the intake is a
           function that develops over a long period of time. 
           And I don't know whether that would be an active or
           a passive type of thing.  I guess that's one of
           those things that's kind of on the cusp as well.
                       MR. GRIMES:  That's correct.  And we
           would -- you know, if the reviewers look at the --
           at this distinction, and they test it with operating
           experience.  And to the extent that we have delved
           into the area of the impacts of zebra mussels and
           other impacts on system performance, we still have
           to step back and say, yes, but to what extent are
           these things -- aging effects -- age related?  And I
           think that we've been fairly sensitive to making
           that fine distinction.
                       And we still have to -- we still have
           the system performance tests and the active features
           that provide protection in the future in the event
           that we find some long-term impact going on that
           needs to be addressed.
                       MEMBER LEITCH:  Yes.  Thanks.
                       MEMBER SHACK:  Just coming back to this
           last bullet again, in the earlier version of GALL
           you had the NACE program as an acceptable aging
           management program.
                       MR. DAVIS:  That's right.
                       MEMBER SHACK:  What you did then was
           create another new -- I mean, a plant could have
           always come in with a plant-specific alternative. 
           You just created a new generic management program,
           presumably based on some fairly typical plans, is
           that --
                       MR. DAVIS:  What we did was we basically
           did what Calvert Cliffs and Hatch and ANO and Turkey
           Point proposed, and that is when they go in to do
           maintenance they're going to dig up the pipe and
           they'll examine the coatings at this point. 
           Whereas, when I originally wrote it, I put the NACE
           standards of cathodic protection and coating. 
           Nobody really does that, and they don't want to take
           credit for the rectifiers, because they're not --
           they weren't purchase safety-related.  So that
           causes a problem for them.
                       So we -- rather than fight about it, we
           agreed with NEI that we would offer either
           alternative.  In the case of Oconee, they have 11-
           foot diameter pipes, and they actually are going to
           inspect from the inside of the pipe.  And that's
           about 80 percent of their buried pipe is 11-foot
           diameter pipe.  So that wasn't put into GALL because
           we thought that was an unusual occurrence.  But they
           can also propose any other program that they want
           when they come in.
                       CHAIRMAN BONACA:  This is AM34.  That's
           the one he quoted.  Okay.
                       MS. RICO:  And the last change to GALL
           was the addition of a selective leaching program. 
           Some materials were added that NEI had asked for
           that are used in plants, and selective leaching was
           identified as the aging mechanism.  And we created
           selective leaching, which was modeled off of Oconee.
                       And those were all the significant
           changes that were made to V, VII, and VIII.
                       Now, for the NEI continued dialogue
           items, the first one is concerned with bolting, and
           NEI feels that the aging effect and mechanism of
           crack initiation and growth due to cyclic loading
           and stress corrosion cracking for carbon steel
           closure bolting and high pressure or high
           temperature systems is not necessary.  And I'll let
           Jim Davis further --
                       MR. DAVIS:  It's the issue of the 150
           yield strength.  If it's up over 150 yield strength,
           those bolts will crack in air.  And we've raised
           this with every utility so far, and they want us to
           take that out of GALL.  But we're not going to.
                       MR. BARTON:  End of dialogue.
                       The decision has been made.
                       MR. GRIMES:  This is Chris Grimes.  I
           want to emphasize that dialogue will continue.
                       MS. RICO:  And the second item is
           concerned with additional requirements above the
           NFPA commitments.  And I'll let Tanya Eaton from the
           Plant Systems Branch just briefly go over what these
           two additional requirements are.
                       MS. EATON:  Hi.  I'm Tanya Eaton. 
           Basically, the concern that we had was that there
           was a requirement in GALL for fire protection
           systems that inspections should be performed to
           monitor through internal inspections.  NFPA does not
           have requirements that currently require licensees
           or anybody that has a fire suppression system to go
           in and look at the pipe and to trend changes over
           time to the diameter which could affect the wall
           thickness and eventually affect the pressure
           differences in the system.
                       And so in order to meet the requirements
           of GALL you have to go beyond what's currently in
           the NFPA codes.
                       MR. BARTON:  So where are you on this
                       MS. EATON:  We're still -- I don't know
           if NEI -- what NEI's position is.  We haven't spoken
           to them in a while.  So it's my understanding that
           we are just going to continue dialogue.
                       MR. BARTON:  Okay.
                       CHAIRMAN BONACA:  That's in one of the
           open issues of Hatch, still open somewhat.  Well,
           that's more because of the particular area of the
           fire protection, not the specific issue.
                       MR. GRIMES:  That's correct.  
                       CHAIRMAN BONACA:  Okay.
                       MR. GRIMES:  Arkansas and Hatch were
           both challenged by fire protection scoping issues.
                       CHAIRMAN BONACA:  Yes.
                       MR. GRIMES:  But the issue that Tanya
           described is basically our expectations about
           monitoring programs that would be relied on for
           aging management with respect to the pressure
           boundary which is -- as Tanya explained, our
           expectation goes beyond what NFPA currently
           requires, or NFPA code currently requires.
                       CHAIRMAN BONACA:  Okay.
                       MS. RICO:  Are there any further
                       MR. BARTON:  Yes.  Chapter VII -- are
           you covering VII?
                       MS. RICO:  Yes.
                       MR. BARTON:  D.2 in VII, compressed air
           systems.  If you look at the scope in that section
           it does not cover the pressurized air receivers,
           which are usually carbon steel tanks and corrode and
           get full of moisture and operators forget to bow
           them down, and la-di-da, la-di-da.  Where are they
           covered with respect to age managing and corrosion?
                       MS. RICO:  I'm not sure on that one.
                       MR. DAVIS:  I think if there's moist air
           in there it's covered.
                       MR. BARTON:  It's not covered in D.2. 
           So where is it covered?
                       MR. DAVIS:  Okay.  I'll have to look. 
           I'm not sure.
                       MR. GRIMES:  We'll find that, because
           I'm sure that the -- I remember the question coming
           up about the treatment of receivers, but I can't
           recall specifically where they're --
                       MR. BARTON:  Okay.  I didn't see it in
           the current documents in D.
                       MR. LEE:  Yes.  We will check that.  One
           of the things that we have is GALL is not a scoping
           document.  So if it is not in GALL, then the
           applicant had to address it on a plant-specific
           basis.  It was in fact within the scope, last we
           knew, for that plant.
                       MR. GRIMES:  This is Chris Grimes.
                       MR. BARTON:  I'm not comfortable with
           that answer.
                       MR. GRIMES:  This is Chris Grimes. 
           Sam's explanation is that GALL tries to treat all
           systems, structures, and components in a very broad
                       MR. BARTON:  Right.
                       MR. GRIMES:  And so my expectation is
           that somewhere that's an explanation on the
           treatment of receivers in an air-handling system.
                       MR. BARTON:  Okay.
                       MR. GRIMES:  Correct?  And a compressed
           air system.  And so even though it might be
           difficult to find, we would expect that somewhere
           there's an explanation and we'll research that.
                       MR. BARTON:  Thank you, Chris.
                       Chapter VIII, steam and power conversion
           systems.  In 8.E, you talk about a condensate system
           and you refer to condensate storage tanks, and
           material mentioned in that section only deals with
           carbon steel condensate storage tanks.  My question
           is:  what about plants that have aluminum condensate
           storage tanks?  Where are they covered?  
                       I know you've got to care about aluminum
           storage tanks because I have personal experience
           that the bottoms rot out.  And I don't see that
           covered any place.
                       MR. DAVIS:  I don't think we covered
           that, but I could check into that, too.
                       MR. BARTON:  Well, I think you need to
           look at that.
                       CHAIRMAN BONACA:  That's an important
                       MR. GRIMES:  I know we can find
           receivers, but we may have to confess that aluminum
           storage tanks would be treated on a plant-specific
           basis until we've got some further experience with
                       MR. BARTON:  I know one place where
           you've got some real experience with them.
                       MS. RICO:  And then, as for the SRP,
           your comment earlier about Section 3.3 on the -- in
           parentheses at the beginning of I think it's
           and 8, the program no longer is in use.  That was --
           I had tried to keep the numbering system the same.  
                       So like when you encountered earlier
           when something -- a program went missing from one
           version to the next, that was kind of my way of
           making it so that you knew what happened to this
           program, that it just didn't disappear off the face
           of the earth.  But we will end up just taking those
           out and just renumbering them.  But that explains
           why that is in there.
                       CHAIRMAN BONACA:  Okay.  Just pursuing
           again the issue that John Barton brought up.  You
           may have, in fact, some components out there which
           are not covered by the current guidance.  Aluminum
           storage tanks appear to be some of those.
                       In those cases, you will have an
           expectation that there will be a plant-specific
           program addressing the material, the environment,
           and the aging effects.
                       MR. GRIMES:  That's correct.
                       CHAIRMAN BONACA:  Okay.
                       MR. GRIMES:  We tried to treat -- GALL
           attempted to catalog everything we've been able to
           find so far.  And I'm -- I'm sure you'll be able to
           think of other examples of unique component
           environment configurations that perhaps we haven't
           treated, and they simply didn't come up in the
           process of our cataloguing.  That does not relieve
           the applicant from the responsibility of capturing
           them in scope and then treating the applicable aging
                       CHAIRMAN BONACA:  I imagine that at a
           later time will be included in GALL as lessons
                       MR. GRIMES:  That's correct.  As a
           matter of fact, it's the -- industry has stressed
           the importance of their expectation that as future
           lessons are learned that there will be an
           opportunity to further improve the guidance.
                       CHAIRMAN BONACA:  Yes.  I have a general
           question about GALL.  I can ask it anytime, so I'll
           ask it now.  Which is, you know, GALL provides a
           real baseline and really gives a lot of comfort when
           you look at it, because although things may have
           been missed, but there is a significant meeting of
           the industry and the NRC and the whole experiences
           brought there.
                       And I'm still surprised at some of the
           applications, including the one we are going to see
           tomorrow, and the SCRs contain very little reference
           to GALL.  I'm sure GALL has been extensively used to
           make judgments, and, you know, I was surprised that,
           for example, in the SCR we are going to review
           tomorrow there is very little reference to GALL.
                       And I just -- with respect to time,
           there will be more of that because, again, a
           reference to GALL is something that says -- like it
           is there and is acceptable and will be helpful.
                       MR. GRIMES:  The simplest explanation is
           that we have a pact, and that pact is that so long
           as GALL is still evolving, and it does not represent
           an approved tool, then it will be used carefully by
           both the industry and the NRC.  And so the lack of
           approval on the document means that we use very
           carefully, and we do not reference it -- either the
           applicants or the NRC -- until it has reached a
           stage of maturity and approval that we can say it is
           now an official agency document that can be
                       The fundamental objective of this
           demonstration project that the industry has
           undertaken is to find ways to maximize the utility
           of GALL as a reference in order to simplify the
           process.  The staff is similarly motivated to be
           able to reference GALL as a device that represents
           an official position relative to these matters.
                       And we're here today to seek your
           endorsement, in your capacity as an advisory
           committee to the Commission, to get the Commission
           to put a blessing on it that makes it an official
           document that can be referenced.
                       CHAIRMAN BONACA:  And I understand and
           that's great, because it lessens my concern.  I
           think with the time I will expect and hope that
           there will be much more reference, you know, when it
           is a finalized document.  But, still, right now --
           for example, I notice many requests for additional
           information where you went back and forth, and then
           finally the answer was, "Well, we did this because
           that's in GALL."  And the staff responded by saying,
           "Ah, great.  So we accept it."  
                       I mean, so still now, already now, GALL
           represents a significant baselining for discussion
           and agreement.  And so, okay, I understand it is not
           final yet.  Is this going to be -- is this supposed
           to be the last draft we get before it is approved in
           the final form?
                       MR. GRIMES:  We're going to talk about
           that at the conclusion of meeting.
                       CHAIRMAN BONACA:  Okay.  Because I'm
           beginning to wonder now.  We don't --
                       MR. GRIMES:  We would like this to be
           the last draft before we go to the Commission for
           approval to proceed and use it as an official
           position.  But as you've pointed out, there's still
           some room for further improvements, and I hope that
           at the conclusion of the meeting we can convince you
           that, as we've tried to convince the industry, that
           the dialogue will continue and opportunities for
           future improvements will be there for subsequent
           revisions and additions.
                       We would like this to be the final
           draft, so that we can take this guidance to the
           Commission for approval.
                       CHAIRMAN BONACA:  How does the industry
           feel about that?  Because I see a lot of issues here
           which are continued dialogue items.
                       MR. GRIMES:  I think that the -- well,
           I'll let the industry speak for itself when they
           come up to talk about their contribution with
           Revision 3 to NEI 95-10.  But I think that the
           industry is as anxious as we are to take advantage
           of what's been accomplished so far, which we think
           is fairly substantial.
                       If you'll, you know, keep in perspective
           that we're here explaining a resolution of what we
           consider to be some of the key controversies that
           came up in the comments.  But we've incorporated the
           results of about 1,000 comments for which we've very
           carefully gone through and documented in the
           companion NUREG report how we've treated each of the
                       CHAIRMAN BONACA:  Thank you.
                       MS. RICO:  Now S.K. Mitra will come up
           and discuss Chapter VI.
                       MR. LEE:  I guess before S.K. comes up,
           Dr. Leitch before had a question on the fatigue,
           environmental effects on fatigue.  I have John Fair
           from the NRR staff.  He can answer your question if
           you still have a question on that.  This is, I
           guess, SRP 4.3.
                       MEMBER LEITCH:  Yes, that's where my
           question was.  I guess my question specifically
           related to the verbiage on -- I'm referring to the
           SRP now, page 4.3-2 and 4.3-3, speaking about the
           resolution of the generic safety issue and the
           statement that the effects of reactor coolant
           environment on the fatigue life of components were
           not adequately addressed in the code of record;
           particularly, the concluding paragraph indicates the
           potential for an increase in the frequency of pipe
           leaks as plant continues to operate.
                       That is speaking now about the
           conclusion of paragraph  Thus, the staff
           concluded that licensees are to address the effects
           of coolant environment on component fatigue life as
           aging management programs are formulated in support
           of license renewal.
                       MR. GRIMES:  This is Chris Grimes.  I'd
           like to introduce John's explanation by making --
           closing the circle in terms of the -- the associated
           generic safety issue is GSI 190.  It was the issue
           that was intended to extend from GSI 168 on fatigue
           environmental effects for 40 years.  
                       And what you read was the conclusion of
           GSI 190, and actually I think it's also important to
           recognize that even though the industry did not
           specifically identify this as a potential appeal
           issue warranting further dialogue, I think it is
           their expectation that this is an issue that has an
           ongoing dialogue that will continue in the future
           and may result in future changes to this guidance.
                       But with that, I'll let John explain the
                       MR. FAIR:  Yes.  I'm sorry.  I'm John
           Fair with NRR.  I missed the crux of the question
           you had on this.
                       MEMBER LEITCH:  Well, it just left me
           with an unsettled feeling.  I guess someplace in
           here, I'm not sure I can find the sentence right
           now, but it seems like -- I had the impression that
           40 years was kind of at the margin.  And on that
           basis, I was wondering how we could proceed with 60
                       MR. FAIR:  Okay.  Originally, this issue
           was looked at for both 40 and 60 years, and we had
           an evaluation of a sample of components at a number
           of powerplants.  And what we found, that in most
           plants we could do an evaluation, remove
           conservatism with the new environmental curves and
           show they were okay for most of the locations.
                       But in addition to the evaluation of
           these locations, we also had an auxiliary risk
           assessment, and it showed that the risk was not
           significant.  And, therefore, we couldn't justify
           the backfit to the current operating plants.
                       So the basis -- the real basis of why we
           didn't have a problem with current operating plants
           was, one, we did an evaluation of high fatigue usage
           factors at most of these -- at a sample of plants,
           showed most of the locations were acceptable even
           considering environment for the 40 years.  
                       There are some cases we couldn't show it
           was good for 40 years, but we suspect that with more
           detailed information, which the licensee has
           available to them, they could probably show these
           other locations were okay for 40 years.
                       And, in addition, we had the risk
           assessment showing it was not risk-significant
           enough to warrant a backfit.  When we made the
           conclusion for 60 years, we said there's a
           likelihood that we'd have more problems at 60 years,
           obviously, with 20 years additional time.  It would
           be more difficult to show that these locations were
                       And we did a follow-on risk assessment
           in this GSI 190, and that follow-on risk assessment
           showed that there was an increase in leakage
           potential for these locations, even though the risk
           was not high.  And on that basis, we concluded we
           should do something for license renewal because of
           the potential for increased leakages.
                       So it was basically we couldn't justify
           a backfit to the current operating plants based on
           the risk assessment and the evaluation we had
           performed.  So --
                       MR. GRIMES:  I would like -- if I could,
           I need to correct a misstatement I made before, that
           the precedent to GSI 190 was GSI 166, not 168.  And
           I'd like to add that although we cannot backfit the
           design of all the fatigue analysis, we're
           approaching this from the standpoint of the
           environment is an aging -- is applicable to the
           aging effects associated with the fatigue analysis.
                       Therefore, we believe that it's within
           the scope of the renewed license to address how that
           affect is going to be treated.  And John prepared
           the guidance for the Generic Aging Lessons Learned
           Report that explains our expectation on how that
           will be treated.
                       MEMBER LEITCH:  Okay.  I guess -- is
           that found -- that most of the locations would have
           a CUF of less than the ASME code limit of one for 40
           years.  I guess that's the troubling statement, I
           guess, that I -- I'm trying to find the right
           sentence here.  Just bear with me a second here.
                       I guess at one point here it says,
           "However, because the staff was less certain that
           sufficient excessive conservatisms in the original
           fatigue calculations could be removed to account for
           an additional 20 years of operation for renewal, the
           staff recommended in SECY" -- number such -- "that
           samples should be evaluated considering
           environmental effects for license renewal."
                       So I guess maybe I'm just not sure what
           you have done as far as this issue is concerned.  Is
           additional inspection required or --
                       MR. FAIR:  No.  In license renewal for
           the plants that have gone through license renewal
           thus far, they have taken the locations that we
           originally studied --
                       MEMBER LEITCH:  Okay.
                       MR. FAIR:  -- the six locations, and
           they've done their own assessment considering
           environmental effects.  And in most cases -- again,
           in most cases, not all cases, they are able to show
           there's not a problem.  For the cases where there's
           a concern, which right now it looks like mostly a
           concern on the surge line, they're going to do some
           monitoring in the extended period of operation.
                       MEMBER LEITCH:  Okay.  Okay.  I think
           that answers my question.  Thank you.
                       MR. KUO:  If I may add, the fatigue
           program that I was talking about earlier in Chapter
           X is in Chapter X, M1.  The program is M1.
                       MEMBER LEITCH:  M1?
                       MR. KUO:  Yes.
                       MEMBER LEITCH:  Thank you.
                       MR. KUO:  You're welcome.
                       MR. MITRA:  I'm S.K. Mitra again,
           Project Manager, License Renewal.  With me today, on
           my right, is Bob Lofaro from Brookhaven National
           Lab; and on my left, Mr. Jit Vora from Office of
           Research; and Paul Shemanski from NRR.
                       Today's topic is Chapter VI, Electrical,
           and we are going to talk about the changes from the
           August version due to the public comments. 
                       The first bullet is consolidated boric
           acid corrosion programs.  The borated water leakage
           surveillance for a non-acute electrical connectors
           program, E.4.  Used to be 11.E.4.  Deleted from
           Chapter XI to eliminate the redundancy with the
           boric acid corrosion program in Chapter XI, Intent,
           which is now reference for electrical improvement
                       This is based on industry suggestions. 
           So we took that 11.E.4 out from programs and
           reference to 11.M.10, which is --
                       MR. BARTON:  Reference to 11 what?
                       MR. MITRA:  11.M.10.
                       MR. BARTON:  M.10?
                       MR. MITRA:  Yes.  That's boric acid
           corrosion program.
                       MR. BARTON:  Yes.
                       MR. MITRA:  Next bullet is we
           incorporated examples of specific insulation tests
           for medium voltage cables.  Aging management program
           in 11.E.3, for medium voltage cable exposed to
           significant moisture and significant warpage, was
           modified to include example of acceptable monitoring
           tests to provide an indication of the condition of
           conductor insulation.
                       Based on comment, ACRS has three
           changes, and there will be a new paragraph in
           11.E.3, which will give the specific test.  It says
           the specific type of test performed will be
           determined prior to the initial test, and this will
           be a proven test for detecting the duration of
           insulation system due to weighting, such as power
           factor, discharge, or polarization index, as
           described in EPRI TR203834-B1-2.  Or other testing
           that is state of the art at the time of the test is
                       MEMBER UHRIG:  This, then, is very
           different than the -- this is not the same kind of
           test -- accelerated testing that was done for the
           low voltage cables.
                       MR. MITRA:  No.
                       MEMBER UHRIG:  This is just for normal
                       MR. MITRA:  Used for medium voltage.
                       MEMBER UHRIG:  Yes.  Medium voltage is
           for normal usage --
                       MR. MITRA:  Yes.
                       MEMBER UHRIG:  -- throughout the 60
                       MR. MITRA:  Right.  But --
                       MR. LOFARO:  That's correct.
                       MR. MITRA:  The last bullet is we added
           a sentence for first inspection/test of cables to be
           completed prior to the period of extended operation. 
           And this requirement was added to the aging
           management program 11.E.1, E.2, and E.3, to the
           detection of aging effects, to make sure a 10-year
           inspection or test frequency will provide at least
           two data points during 20 years period, which can be
           used to characterize that degradation rate.  This
           was also added to be consistent with the requirement
           in the SRP.
                       CHAIRMAN BONACA:  This is typically --
           these are known EQ cables, right?
                       MR. MITRA:  Yes.
                       MEMBER UHRIG:  There are the medium
           voltage cables?
                       MR. MITRA:  Any cable.
                       MEMBER UHRIG:  Any cable.
                       MR. MITRA:  Yes.
                       MEMBER UHRIG:  Any cable, low, medium,
           or high.
                       MR. MITRA:  Yes.  And previously in GALL
           we didn't have this requirement saying that it had
           to be done at the completion of the period of
           extended operation.  So it could have been done in
           50 years and only one inspection, and that would
           have been all data points, more than one.  So this
           was added at 40.  Any time before 40 is here, and
           then there will be one more.
                       MEMBER UHRIG:  You have not specified
           any specific test.  That's just the measure test for
                       MR. MITRA:  Any specific tests?
                       MR. SHEMANSKI:  Would you repeat that,
                       MEMBER UHRIG:  Well, it says just --
           first inspection/test.  You have not indicated the
           type of test.  Is this negotiated with the utility
           at the time, or is this something that is -- they
           propose and you approve?  Or is this something that
           is currently in use?  What type of test are you
           talking about here? is really my -- I guess the
                       MR. SHEMANSKI:  Basically, what we're
           looking for is a state-of-the-art test.  We don't
           want to define the test right now, or at least the
           utilities, so that -- they would prefer to wait
           until the actual test is going to be performed and
           see what is the best test available at that point in
                       They were concerned about locking into a
           particular test right now, committing to a
           particular test, and if they chose not to do that
           test then they would have to come in for a license
           amendment type change.  So what we agreed to was
           that just prior to the conduct of the test the
           utility would come in and discuss it with us, and
           NRC would then have the opportunity to agree or
           disagree with the type of test to be conducted.
                       MEMBER UHRIG:  Also, assume that there
           would be a discussion of the criteria for acceptance
           or --
                       MR. SHEMANSKI:  Yes.  At that point,
           that would give us an opportunity to discuss the
           acceptance criteria that would be involved for that
           particular test.
                       MEMBER LEITCH:  Just back to the first
           bullet, boric acid corrosion programs -- I'm looking
           at M.10, boric acid corrosion, and it doesn't leap
           off the page, to me at least, that it's referring to
           electrical equipment.  It says the program covers
           any carbon steel, alloy steel structures and
           components which have borated -- one which borated
           reactor water may leak.
                       So where is -- I mean, it says
           "components," and I guess you could infer from that
                       MR. MITRA:  Yes.
                       MEMBER LEITCH:  And these seem to --
                       MR. MITRA:  Specifically, it was
           mentioned and, regretfully, it has not showed up in
           your version.  But I was told that it was
           incorporated in a later version.
                       MR. LOFARO:  Yes.  This is Bob Lofaro
           from Brookhaven.  Subsequent to this March version
           that you have reviewed, we did add some words to
           program M.10 to specifically call out the inspection
           of electrical components.
                       MEMBER LEITCH:  Okay.  That's good. 
           It's probably inferred here, but it's not real clear
           right here.  Thank you.
                       MR. MITRA:  Are there any other
           questions?  Thank you.
                       Next presenter is David Solorio.
                       MR. SOLORIO:  Hi.  My name is Dave
           Solorio, and to my right here is Omesh Chopra from
           the Argonne National Lab.  I'm going to talk to you
           about three things today.  First -- the first couple
           will go real quickly.  I'm going to talk about Reg.
           Guide 1.188, and then I'm going to talk about NEI
           95-10, and then I'm going to put up a slide here
           that talks about one-time inspections that you all
           asked for.
                       Reg. Guide 1.188 proposes to endorse NEI
           95-10, Rev. 3, dated March 1st, without exception,
           because 95-10 provides acceptable methods for
           complying with the requirements of the license
           renewal rule.
                       Two changes were made to the reg. guide
           in response to public comments.  First, guidance for
           submitting electronic submittals was added, and a
           note was added to clarify that if color drawings are
           used no essential information should be lost from
           printing them out in black and white, so -- for the
           benefit of the public who may not have access to
           color equipment.
                       MEMBER SHACK:  Let me just ask a
           question.  I was sort of -- you know, I was reading
           the BWRVIP POP Guide Reports, which I assume will be
           sometime referenced in the license renewal document. 
           And there's a proprietary version and a non-
           proprietary version, and by the time you get to the
           non-proprietary version, which is what the public is
           going to see, there's nothing there.
                       I mean, even the list of inspections
           that are proposed is proprietary and disappears.  Is
           there some judgment here as to, you know, what's a
           reasonable amount of information to be provided to
           the public when this is done?
                       MR. SOLORIO:  Well, the NRC -- not in
           the reg. guide -- but the NRC does have a process
           for providing -- what's the right word?  Proprietary
                       I guess it would have to be handled on a
           case-by-case basis, and it would be up to the
           project managers and the NRC managers to determine,
           you know, what appropriate information needed to be
           seen by the public, so that they had a fair shot of
           looking at what we're looking at.  We have a
           process, and we would follow that process.  
                       I really don't have any more --
                       MR. GRIMES:  This is Chris Grimes.  I
           was involved extensively in the dialogue with the --
           with EPRI and the BWR Owners Group to try and get
           them to provide us with more than a cover page and a
           table of contents in the non-proprietary version. 
           There are standards, and there is a test on the
           proprietary -- proprietary nature, but it's not
           always clear.
                       MEMBER SHACK:  Well, the one that
           disturbed me the most was the table which actually
           outlined the inspections that would be done, which
           would seem to me the thing that, you know, the
           public might well want to know.
                       MR. GRIMES:  And we listened long and
           hard to the explanation about how the BWR Owners
           Group and EPRI considered that to be marketable
           material.  And it is.  And notwithstanding our
           desire to be able to disclose those details in
           public, the standard that we apply is whether or not
           there is a -- you know, a financial gain to be made
           in terms of its marketability.  And --
                       MEMBER SHACK:  That is the crucial test,
           then, is is it marketable material?
                       MR. GRIMES:  That's correct.  And I can
           recall when I -- when similar questions came up on
           Westinghouse topical reports many, many years ago,
           we were able to convince Westinghouse that "F equals
           MA" was not a marketable quantity for them.  And
           sometimes it gets that ludicrous, but it -- but the
           test is that -- it gives the owner of the report an
           opportunity to protect their commercial materials. 
           That's its intent.  
                       That's why we have provisions for
           proprietary material and protection of confidential
           business information.  And it does make our job much
           more difficult in terms of the transparency to the
                       CHAIRMAN BONACA:  Doesn't it also
           involve, in fact, a decision on the part of the
           staff on whether or not the right of the public
           weights the marketable value of the application?
                       MR. GRIMES:  That's correct.  But you
           will find, particularly I think in the BWRVIP,
           safety evaluation that we -- we've worked very hard
           to present safety evaluation findings that describe
           enough of the contents of the material in terms of
           what we relied on to come to a reasonable assurance
           finding, without disclosing the details that the --
           that the owners groups and EPRI want to market.
                       And I would also add that I'm -- I
           believe that there is presently a rule change
           underway for 2.790.  That's 10 CFR 2.790, which
           embodies the requirement for proprietary
           withholding, that attempts to improve it, but it
           still will demand that the Commission offer an
           opportunity for that commercial business information
           to be protected.  
                       That's not unique to the NRC either. 
           All federal agencies are confronted with providing
           for the protection of confidential business
                       MEMBER SHACK:  I mean, it just seems to
           me there is some conflict with, you know -- I mean,
           I don't see how the public could look at that
           proprietary version of that document and learn
                       MR. GRIMES:  Well, the non-proprietary
                       MEMBER SHACK:  The non-proprietary
                       MR. GRIMES:  But there is -- there are
           processes by which interested members of the public
           can view proprietary material by -- through legal
           means, and that is to make, you know, some kind of
           contractual arrangement, so that they will not
           disclose that marketable material.
                       So if there is an interested public
           organization -- and as a matter of fact, I believe
           that Commissioner McGaffigan referred to it when the
           issue came up during the regulatory information
           conference when Ed Limon, you know, referred to his
           concerns about the availability of research
           information related to aging effects.
                       And there are ways that public interest
           groups can view the details, so long as they agree
           to the -- maintaining the confidence of the material
           that's being marketed.  Okay?
                       MR. SOLORIO:  My next transparency talks
           about NEI 95-10.  As you're aware, Revision 2 was
           published back in August.  You probably -- most of
           you probably saw it then.  The staff reviewed
           Revision 2 and identified a number of items that
           needed to be changed to ensure consistency with the
           standard review plan and GALL.
                       The staff met with NEI in February to
           discuss these items, and NEI revised 95-10 and
           submitted Rev. 3 in March of this year.  On this
           slide I've categorized -- or on this transparency
           I've categorized the nature of the changes into
           three areas.
                       First, there are what I would call
           consistency changes.  For example, the staff
           requests that the table of contents in 95-10 agree
           with the statement of contents in the SRP to ensure
           a consistent format for future license renewal
           applications.  Another example was that the staff
           requested NEI 95-10 include a discussion on top 10
           program elements for an aging management program,
           similar as provided in the standard review plan.
                       There was some additional guidance for
           the timing with which an applicant should address
           USIs and GSIs, in accordance with NUREG-0933.  And,
           finally, a conforming change to address changes to
           the regulation involving the accident source term,
                       I also want to mention that in March --
           in their March 1st letter transmitting Rev. 3, NEI
           indicated to support the schedule to provide this
           document, along with the other documents the staff
           has provided to the ACRS by March 1st.  They
           provided 95-10 without the benefit of industry
           review.  Therefore, there was a possibility there
           could be changes.
                       In addition, there were a few items such
           as the severe accident mitigation guidelines that
           didn't get added to Revision 3 due to timing, but
           NEI intends to add that.  NEI has informed me that
           they will be resubmitting Revision 3 very shortly,
           and when NEI does that the staff will review it to
           ensure our endorsement remains unchanged.
                       My next transparency here is in response
           to what I understand was a request by the
           subcommittee to see the one-time inspections for
           Calvert, Oconee, and GALL.
                       CHAIRMAN BONACA:  Let me just explain to
           -- for the -- I made the request because we have
           seen the one-time inspections, and we saw a large
           number for Oconee, for example -- for Calvert
           Cliffs, actually.  And they've gone down in number
           substantially to the point where Arkansas had very
                       Now, that doesn't mean the issues have
           been all gone away, but there is other ways in which
           they have been accommodated.  So, second, if I look
           at the Arkansas application and Hatch, the one-time
           inspection really represents the bulk of the new
           programs being presented -- I mean, in large part. 
           And it's --
                       MR. SOLORIO:  I'm not real familiar with
           Arkansas and Hatch, but --
                       CHAIRMAN BONACA:  Well, that's at least
           what I see from them.  And so they are important
           because earlier they represent that.  So it would be
           good for us to understand, you know, where these
           one-time inspections are, why they have been
           decreasing with time, if you have any insight on
           that that would be very useful.
                       MR. SOLORIO:  Well, just to tackle that
           right away, GALL frequently now requires a plant-
           specific aging management program be required.  So
           that could mean a licensee might have a one-time
           inspection or a licensee might have an existing
           program.  As long as there is something, that's what
           GALL is asking -- asking for.
                       So that could explain a big difference
           perhaps why you see a lot less for these other more
           recent applicants.  Again, I'm not real sure about
           their particulars, but --
                       CHAIRMAN BONACA:  Yes.  One of the
           reasons may be that Oconee was presented -- one of
           the earlier applications, I don't remember which one
           -- no, actually, Calvert Cliffs -- was much more
           focused on component by component, system by system,
           so there were a lot of programs there, many more
           numerically, while for Oconee they were grouped
           into, you know, generic programs.  So there are less
           in those.
                       But I think it would be good for us as
           we go forth in our review to understand the
           situation with the one-time inspections.
                       MR. SOLORIO:  Okay.  In this first
           column here, what I've tried to do is represent how
           these systems would be grouped in GALL.  So that's
           why you see the groupings.  That's what they are
           there.  And then, to the right, I go across trying
           to label the individual systems.
                       I also want to caution anyone near
           license renewal that we're not saying that all of
           these systems are only inspected one time for aging. 
           In fact, the majority of the cases there's an
           existing aging management program also looking at
           these systems.  It's just a particular aspect that
           they chose to do a one-time inspection for.
                       I also want to add that GALL has
           consistently applied the lessons learned of Calvert
           and Oconee regarding one-time inspections.  In fact,
           for these two plants, one-time inspections were
           incorporated into GALL, when appropriate, as a
           starting point back in '99.
                       In developing GALL we also had the
           experience of the national laboratories in helping
           us capture these one-time inspections and gained
           from their experience.  And staff associated with
           the first license renewal reviews were involved in
           reviewing these one-time inspections that were
           incorporated into GALL.
                       GALL also had the benefit of two public
           -- two rounds of public comments, and the frequent
           outcome of public's participation in the GALL now
           specifies a plant-specific aging management program
           be proposed where Calvert or Oconee might have done
           a one-time inspection, to provide flexibility in
           case a licensee is already doing something as an
           existing program.  That's really all we need.
                       A plant-specific aging management
           program could be a one-time inspection or an ongoing
           program.  At a glance, there appear to be
           differences in the number of one-time inspections
           here on this viewgraph between GALL, Calvert, and
           Oconee.  But there are a number of reasons to
           explain these differences.
                       First, there are plant-specific reasons,
           like Oconee has several features which were a little
           too unique to be included in GALL, and obviously
           were not applicable to Calvert, like the dam
           emergency power source and the safe shutdown
           facility structure, kind of some of the stuff I put
           down here.
                       MR. GRIMES:  If I could, I'd like to
           clarify that dam emergency power supports as a
           hydroelectric dam.
                       It's spelled a little differently.
                       MR. SOLORIO:  I apologize.  Maybe the
           Oconee project manager would want to make that
                       Second, in many cases Calvert proposed
           one-time inspections without being asked by the
           staff.  I mean, it was just part of their
           application when it walked in the door.
                       Third, different names are used for some
           of the systems performing the same functions, like I
           know you'll never guess this, but LPSW and HPSW at
           Oconee mean fire protection. 
                       Now I'd like to go over a few examples
           on this viewgraph to explain a little more detail
           what I have here.  Starting at the top with the
           reactor coolant system-SBP -- that's small-bore
           piping -- all three require a one-time inspection. 
           Moving on to reactor vessel internals -- can you all
           hear me okay?  I'm not sure if I'm -- this mike is
           doing funny things.
                       For reactor vessel internals, because of
           component design, the staff required a one-time
           inspection for certain components at Calvert but did
           not for Oconee because of differences in component
           design.  GALL requires a plant-specific evaluation
           of certain reactor vessel internals.
                       For steam generators, Calvert proposed a
           comprehensive program that included inspections of
           steam generator tube supports.  Oconee, having a
           different steam generator design, having an existing
           steam generator program also, but proposed one-time
           inspections for some of its supports due to gamma
           radiation concerns.  GALL requires a plant-specific
                       Moving on to the pressurizer, Calvert is
           conducting a one-time inspection of susceptible
           cladding locations, and so is Oconee.  GALL requires
           a plant-specific evaluation.
                       Those are all of the examples I have to
           go over, but, of course, you can ask more questions. 
           But I want to conclude by saying GALL has
           consistently applied the lessons learned at Calvert
           and Oconee to adequately cover the subject of one-
           time inspections.  While there appear to be some
           differences between Calvert, Oconee, and GALL, the
           differences were due to a plant-specific nature.
                       MR. GRIMES:  I would like to add to that
           the most recent experience that we had with Arkansas
           I think emphasized the plant uniquenesses and the
           variability, because even on the first item where we
           were consistent between Calvert, Oconee, and GALL,
           on small-bore piping, for Arkansas it was inherent
           in their risk-informed in-service inspection
           program.  And so it does not appear as a one-time
           inspection or even a separate issue.  It was
           embodied in our conclusions relative to aging
           effects for the affected piping.
                       So as we went back and reflected on
           this, I derived considerable comfort from the
           relative consistency we see across this, because it
           seems to be easily explained in terms of the plant-
           specific differences and also the different
           approaches that the individual utilities took to
           address specific aspects of applicable aging
                       MR. SOLORIO:  And just for anyone who
           might not have noticed, on the next page I have a
           legend there so you can make sense of all of that,
           because there's a lot.
                       CHAIRMAN BONACA:  Yes.  I wasn't able to
           read it all, but that's okay.  One of the reasons
           why I asked that question was because we discussed,
           you know, for other applications and for Arkansas. 
           I have some questions regarding the project, and the
           projects that -- you know, I am not familiar about
           the other plants.  I think that will be valuable
           information to convey to reviewers, because the --
           you learn a lot about other applications.
                 And then, for example, your logic for
           excluding this mobile piping from Arkansas as a one-
           time inspection escaped me.  For the first time now
           I understood that.  So that is important information
           that I think is good to keep in mind as we go forth
           in reviews.
                       MR. SOLORIO:  But the explanation that
           Chris gave you for Arkansas I'm sure would be
           included in their SER.  It's just probably hidden. 
           One of the things I found in going through Oconee's
           was it was very hard to find an Oconee system like
           the Calvert system, or an Oconee system like a GALL
           system, because Oconee had -- you know, they don't
           call their CVCS CVCS.  They call it something else. 
           So that does make it difficult.
                       MR. GRIMES:  We're challenged to try and
           come up with generic ways to explain license renewal
           in a plant-specific environment.  There again,
           that's something that's not unique to license
           renewal.  I think every safety evaluation is
           challenged to try and describe a safety evaluation
           basis for an individual plant in plain language. 
           We're still learning how to do that.
                       CHAIRMAN BONACA:  I just have a question
           regarding this table, the last one that you took
           out.  You put it away so quickly.  There's nothing
           wrong with it, right?
                       MR. SOLORIO:  Oh, no, no.
                       CHAIRMAN BONACA:  I just wanted to ask
           you a question.
                       MR. BARTON:  What's a depressing air
           system?  Is that one that needs psychiatric help or
                       MR. SOLORIO:  It has to do with their --
           I'm not sure what the right term -- their emergency
           power source, which is the dam.  And I don't know
           any more particulars, but it's for that system, for
           the --
                       MR. BARTON:  It's called a depressing
           air system?
                       MR. SOLORIO:  Depressing air.
                       MR. BARTON:  Okay.
                       CHAIRMAN BONACA:  It's depressing for
           the people who read it.  But anyway --
                       What about the -- why some of them are
           in bold letters and some are --
                       MR. SOLORIO:  So you've got differences
           between A, B -- you know, when a new -- when I start
           a new letter, I do bold so I can quickly look
           through it and figure out where A or B was or --
                       CHAIRMAN BONACA:  Okay.  Thank you.  Any
           other questions for Mr. Solorio?
                       MR. SOLORIO:  Thanks.
                       CHAIRMAN BONACA:  Thank you.
                       MR. GRIMES:  And I am compelled to point
           out that license renewal is right on time again.  We
           are right on schedule.
                       CHAIRMAN BONACA:  This is remarkable.
                       MR. GRIMES:  That completes the staff's
           presentation.  But before I conclude, the next
           agenda item is for NEI to describe the work that
           they've done to revise NEI 95-10.
                       MR. WALTERS:  Good morning.  My name is
           Doug Walters with Nuclear Energy Institute.  I do
           have copies of my presentation.  I'm not sure I have
           enough for people in the audience, but I wanted to
           chat with you today about the changes we're making
           to NEI 95-10, Rev. 3.  Of course, it is the guidance
           for implementing the license renewal rule.
                       A couple of key elements to the
           guidance.  First is I put up here including a
           reference to the GALL Report.  Let me just spend a
           minute on that.  We haven't completed all that work. 
           As has been mentioned in previous presentations, we
           have a demonstration program that's underway.  We
           have the Class -- we call it the Class of 2002, the
           applicants we expect to submit in 2002, working on a
           project that encompasses how they think they would
           use GALL in preparing their application.
                       Our schedule for that is to get some
           information to the staff by the end of April, and
           then have some dialogue with them, ultimately moving
           towards some agreements I think by -- in the June
           timeframe.  And then at some point thereafter we
           would go back and update our guidance as we think we
           need to to reflect what comes out of that
           demonstration program.  
                       So there are a number of changes
           actually that were identified that we need to make
           to NEI 95-10 that we deferred to this demonstration
                       The other key element of our guidance,
           though, is the standard application format and
           content, and that's in Chapter VI.  It follows the
           format and content, or certainly the format in terms
           of table of contents of the standard review plan,
           and that's kind of where we see all this heading is
           that an application would probably reflect what you
           see in those tables in the standard review plan. 
           And so we've got the standard application and format
           in our guidance.
                       A third key element, I believe, is what
           we call Appendix -- it's Appendix B to our document,
           but it's a table of components and commodity groups
           that are subject to an aging management review, and
           that's a good tool certainly for doing the screening
           once you've done scoping.
                       MR. BARTON:  Can I ask you a question on
           Appendix B?
                       MR. WALTERS:  Yes.
                       MR. BARTON:  Going down the list of
           categories --
                       MR. WALTERS:  Yes.
                       MR. BARTON:  -- under "Structures," you
           have an intake canal.  How do I inspect the Delaware
                       MR. WALTERS:  How do I what?
                       MR. BARTON:  What do I do with the
           Delaware River?
                       MR. WALTERS:  I don't know.  
                       MR. BARTON:  That's my intake canal. 
           What's included in the scope of this?  You know,
           Cooper is on the Missouri River.  What's the
           component that I do something with here?
                       MR. WALTERS:  It's a structure, and it's
           -- I mean, in my way of thinking, it's the intake
           structure that sits at the river or whatever it is,
           where you --
                       MR. BARTON:  So you're talking about the
           intake structure.
                       MR. WALTERS:  Yes.
                       MR. BARTON:  How about the -- what's
           included in the intake structure?
                       MR. GRIMES:  Let me attempt to explain. 
           Our expectation is each plant knows what it relies
           on in the way of the structural elements, in order
           to achieve the intended function, and so the
           guidance that we've given to the staff is to focus
           on intended function.
                       If they've got a pipe that extends out
           into the middle of the river that's important to be
           able to draw water from a particular place at the
           point of the intake, then that would be revealed in
           the definition of the structure that's relied on to
           achieve the function.
                       I appreciate the question because --
                       MR. BARTON:  I mean, it's so generic,
           Chris, that you -- you know, intake canal, you know,
           does it include a tunnel?  Does it include the
           discharge portion of the structure?
                       MR. GRIMES:  It may.  The answer is it
                       MR. BARTON:  It may.
                       MR. GRIMES:  And what we -- and what we
           struggle with is if we're too specific and too
           precise in trying to define the boundaries, then
           what we do is we abrogate the responsibility for the
           individual plant to go through and identify where --
           what the boundaries are.
                       At South Texas, they've got a very
           elaborate canal system.  I would expect them to go
           out and, you know, go all the way to the end of the
           structure that's associated with being able to draw
           on the heat sink.  But there we felt that we did not
           -- we didn't want to be so specific as to relieve
           the individual applicants from exercising their
           responsibility to find the extent of the structure.
                       And that's the -- the constant struggle
           that we had was give them enough guidance to know
           what the right thing to do is, but don't give them
           so much that you -- you know, you've gotten too
           focused and missed the point.
                       MR. BARTON:  Okay.  I understand what --
                       MR. WALTERS:  Good explanation.  And I
           would add to that that I think you need to look at
           the guidance in total.  We do have language in
           Section 4 that talks about establishing the
           boundaries, and the expectation is that even though
           you identify it as intake structure you've got to go
           back and do that evaluation boundary review and
           identify what you mean by the intake structure.
                       MR. BARTON:  Okay.
                       MR. WALTERS:  Revision 3, I'll be brief
           on this.  This is Revision 3 as we submitted it in
           -- I guess we submitted it in February.  Again, we
           included this reference to GALL.  We did add the PRA
           summary report and the EOPs to the table of
           potential information sources, but I will tell you
           we don't agree with that.  We think those are beyond
           design basis, shouldn't be on the table, but the
           fact that the staff was going to include them in
           their guidance, it just made sense I guess for us to
           go ahead and include it.
                       We modified the table that Mr. Barton
           was just referring to.  We've added -- I think in
           the electrical area, we've made some minor
           adjustments, and we have incorporated selected
           references.  What that means is that you may be
           aware that over the last probably two or three years
           we've been working with the staff on a number of
           issues; fuses comes to mind.
                       And what we did is we actually created
           an Appendix C to the document, and we've included
           the letters from the staff back to the industry, so
           that the user of the document doesn't, you know, get
           confused if you will about, well, what was the staff
           position on that particular issue?  And we've only
           included a couple of those, the ones that we thought
           were most significant, like fuses and consumables.
                       CHAIRMAN BONACA:  Let me just make a
           comment about bullet number two.  In part, we
           contributed to that, and we didn't intend to create
           any change to the rule.
                       MR. WALTERS:  I understand.
                       CHAIRMAN BONACA:  If that was the case,
           we recommended that.  But I thought it was more in
           terms of -- well, I'll give you an example.  We
           questioned for Arkansas the fact that the reactor
           vessel level measurement system is not in the scope.
                       Now, they presented some reasons which
           had to do with the fact that it is not used in any
           accident analysis, and so, therefore, it wasn't part
           of that.  And also, this is under the Appendix B
           program.  We accepted that answer.
                       But you may have an EOP that depends
           very importantly for some reason on that piece of
           instrumentation.  And I think that it's only prudent
           for the applicant to look at it and see if it sees
           that, you know, clearly that -- the reactor vessel
           level measurement system cannot have any other
           function than a safety function.  It is not defined
           as such maybe in 50.54.
                       But the applicant may consider it
           important enough because it relies so uniquely on
           that for some reason, okay, that the UP points out
           as an element that they would like to keep in.  It
           doesn't change the rule, but I think --
                       MR. WALTERS:  I understand.
                       CHAIRMAN BONACA:  -- it's only prudent. 
           That was the only intent.  And, in fact, I think the
           -- even the table right now in the SRP is non-
           prescriptive.  It says simply document that should
           be reviewed for --
                       MR. WALTERS:  Correct.
                       CHAIRMAN BONACA:  So --
                       MR. WALTERS:  I agree.  Mr. Solorio
           alluded to the fact that we may have additional
           changes, and I've identified at least the ones we --
           we would intend to submit as -- as enhancements, if
           you will, to Revision 3.
                       He talked about the drawings.  This is
           an issue of licensees typically send in colored --
           marked up drawings in color.  They need to be -- the
           color scheme needs to be such that if a member of
           the public wants to print it in black and white you
           don't lose the meaning on the drawings.  So we've
           got guidance to address that issue.
                       We're looking at guidance to reflect
           when an aging effect really requires management, but
           I think, frankly, with what we're doing in the area
           of GALL this may go away.  This was something that
           the industry felt they wanted to do, we needed to
           do, to be clear on when an aging effect requires
                       You've heard the words either it's
           plausible, significant, whatever.  We wanted to try
           to put together some guidance to further define what
           those terms mean.
                       We included the SAMGs as potential
           information sources, and I would add that for the
           SAMGs or for that table in general, the 3.1-1 table
           that's got the potential information sources, we did
           put some text up front in Section 3 that reflects
           how we think that table ought to be used.  And it
           kind of gets to your point, Chairman.
                       And, again, we've added some additional
           selected references.  In this particular case, it's
           only one and it was the letter that we got from the
           staff on the use of FERC maintenance and inspection
           programs on dams, as an aging management program for
                       In conclusion, on 95-10, we think
           certainly there would be changes needed in the
           future to reflect the lessons learned from this --
           the GALL demonstration, and certainly our goal is to
           continue to have the NRC endorse it without
                       And that's all I really had on 95-10.  I
           don't know if there's -- if you have any questions.
                       MR. BARTON:  Yes.  On your table 6.2-1,
           other plant-specific TLAAs --
                       MR. WALTERS:  Yes.
                       MR. BARTON:  -- you've got Appendix B
           and Appendix C as optional.  Why optional?  Is there
           a reason for why that's not --
                       MR. WALTERS:  Appendix B I think is the
           programs appendix.
                       MR. BARTON:  Right.
                       MR. WALTERS:  And we're probably going
           to change that to not be optional.  We're probably
           -- based on the -- that's one that is in the
           category of deferred until GALL demonstration is
           completed, because we need a repository for where we
           describe programs.
                       MR. BARTON:  Right.
                       MR. WALTERS:  But if it's credited in
           GALL, where does that show up?  Should it be in the
           appendix, or is it up front where you talk about the
           component and the aging and you just say, "I have a
           program, boric acid corrosion, for example, and it
           meets the description of the program in GALL."  So
           that's one that's deferred.
                       MR. BARTON:  Okay.  The other one is
           commodity groups.
                       MR. WALTERS:  That's Appendix C.
                       MR. BARTON:  Appendix C, yes.
                       MR. WALTERS:  Right.  Same issue.  We
           need to see how we use commodities in the -- when we
           do the GALL work.
                       MR. BARTON:  So it may or may not be
                       MR. WALTERS:  It may or may not be
           optional.  It may come out all together.
                       MR. BARTON:  Okay.
                       MR. GRIMES:  Doug, if I could -- this is
           Chris Grimes.  If I could ask, I think it might be
           helpful for the subcommittee if you were to describe
           what you consider to be the success expectation of
           the demonstration project.
                       MR. WALTERS:  Okay.  Well, what we
           expect is a couple of things, and let me say that
           there's one thing we don't expect.  I think the work
           that a licensee is required to do per the rule to
           prepare and submit an application is not going to
           change significantly.  It's still appropriate for
           the licensee to go back and look at components,
           materials, environments, do the aging management
                       The benefit, though, of GALL is when we
           get into the programs, and we look at existing
           programs that manage aging.  And what we envision
           GALL to provide is the one-time evaluation by the
           staff of that program, and then we can say, you
           know, does it need to be looked at again?
                       And so it's a packaging issue, I think,
           in part for us.  Once we do all this work on site,
           how can we now package it so that we're not
           describing the boric acid corrosion program every
           time we use it.  
                       And I think for us success will be that
           we see an application that's kind of formatted like
           the SRP tables, and that if it's a program that's
           evaluated in GALL and no further evaluation is
           necessary, that's all we need to say.  We don't go
           into any detail on the program.
                       Success will be understanding what level
           of detail we need to go into if it's a new program. 
           Success will be understanding the level of detail we
           need to go into if it's a program that's evaluated
           in GALL.  But maybe the way I implement it at my
           plant doesn't quite match the evaluation in GALL,
           and how do I write that up.
                       I think the biggest test or the success
           for us will be how quickly whatever we come up with
           gets through the review process by the staff and how
           many RAIs do we get.  And so -- and as you may be
           aware, we're working with the staff in the RAI area. 
           We've done some cataloging of the RAIs that were
           issued for ANO and Hatch, and we are going to
           continue to do that with subsequent reviews to see,
           you know, how are we doing, what are they
           accomplishing.  Well, we have different categories,
           etcetera, etcetera, but I won't get into that.
                       But I think the -- you know, what we're
           looking for is preparing an application that gets
           through a review in a reasonable time with minimal
           RAIs.  And I want to emphasize when I say that that
           that doesn't mean we're looking to reduce what we
           need to do as an industry, or as an individual
           licensee, to prepare the application.  It's just
           that we now have these lessons learned, and we ought
           to be able to package the application in a way that
           gets through the process in a fairly timely manner.
                       CHAIRMAN BONACA:  On the other hand, I
           agree with everything you said, but my -- I feel
           almost an urge to have the finalization of this
           document so we can begin to see some more standard
           formats coming in.  And, essentially, that minimizes
           demonstration phase because if you commit to a GALL
           program, I mean, then you have no further need of
           explaining it.
                       But, for example, the issue of only
           listing in an application the results of the
           scoping/screening, rather than scoping as we saw for
           the first applications and then the screening and
           the outcome, that, to me, is one that generates RAIs
           rather than eliminate RAIs, because there is no way
           that the license -- the reviewer can effectively do
           his job without understanding where you started
                       So isn't it counterproductive not to
           have the initial list of the scoping as the first
           applicants did, and then the screening process by
           which you -- you don't even have to have an outcome. 
           I mean, that goes into the FSAR addendum anyway.
                       MR. WALTERS:  Well, our position on that
           is -- and I think it was stated -- the rule requires
           the licensee to provide the methodology.  The
           discussion we've had -- the ongoing discussion with
           the staff is review the methodology, be comfortable
           with the methodology, and then the resulting list
           should not be too much of an issue.
                       There's no question that the applicant
           will have the list, but what we -- you know, we'd
           like to do is have the staff focus on the
           methodology.  And once they're comfortable with that
           -- in fact, that's what they did on Calvert Cliffs. 
           I mean, they looked at the methodology.  They even
           wrote an SER.  And so the resulting list you would I
           think conclude is probably the right list.
                       But we'll continue to work with the
           staff on that.  I recognize that scoping is a bit of
           an issue, and I think -- I probably should know
           this.  I believe what we've got in our guidance now
           is a suggestion that you, in fact, provide the list.
                       CHAIRMAN BONACA:  I think -- you know, I
           think if the licensees can get over it, I mean, I
           think in the long run -- because, I mean, there are
           so many ways to skin the cat at the beginning when
           you do the scopings.  The methodology is generally
           going to be acceptable.
                       If you look at the application we're
           going to see tomorrow, it's acceptable, but it
           doesn't provide the level of detail we saw for
           Arkansas, for example, where before Arkansas they
           had a quality program that was already founded on
           the questions of 50.54.
                       So in there you had an easy match, and
           you could progress through.  For Hatch you couldn't
           do that.  So it leaves, still, the reviewer in a
           quandary, and it forces the licensee to answer a lot
           of questions.  And most of all it leaves a third
           party, like the ACRS, with a question that says,
           since there are so many questions, so many
           exceptions when the answer comes, you know, are we
           really confident about adequate assurance that the
           scoping is correct?
                       I mean, I'm sure that the work is okay,
           but you are left with a --
                       MR. WALTERS:  I understand.
                       CHAIRMAN BONACA:  -- sample it by
           yourself as a -- and I view myself as a member of
           the public in that sense.
                       MR. WALTERS:  I understand.  And, like I
           said, I think we'll -- you know, we'll continue to
           work with the staff, but the fact is that the rule
           doesn't require it, and we ought to be focusing -- I
           mean, it seems to me that -- and I'm not convinced
           that the number of RAIs would be reduced.  If you
           get the whole list, it's still the negative review
           or proving the negative that is the test.
                       So you provide the whole list.  Now, why
           did you include these five systems that -- so I'm
           not convinced that -- and, frankly, I don't -- I'm
           not sure that we ought to be saying a good test here
           is the number of RAIs.  But the rule doesn't require
           it.  We're trying to get the staff to focus on the
           methodology, and we think that the list that flows
           from the methodology should provide reasonable
           assurance that everything was caught.
                       MEMBER LEITCH:  Doug, could you say
           another word or two about the demonstration project
           that is scheduled?  Who are the participants?  What
           are you trying to do there?
                       MR. WALTERS:  Yes.  The schedule is --
           well, let me start with the participants are --
           really, it's the Class of '02.  And I don't have
           that list in front of me.  I'm sorry. 
                       MEMBER LEITCH:  But it's those that are
           in the --
                       MR. WALTERS:  They are participating now
           -- some are participating in more -- in more of the
           activities than others.  But our goal is to make
           sure that that -- that the Class of '02 is satisfied
           with where we're headed, because the -- I think the
           agreement we have with the staff is that's really
           the -- where GALL will be applied is on those
                       What we've done is we've taken a -- we
           made up a list of systems, structures, and
           components, and then programs, and we're going to
           work the combination of those in a number of
           different ways.  One, we'll look at programs that
           are already evaluated in GALL where -- and let me
           caveat this by saying all this work is -- is real in
           the sense that, you know, the participants are using
           their programs.  This is what they intend to put in
           their application.  I mean, this is application work
           in progress.
                       So we'll look at a program that's
           evaluated in GALL where the applicant thinks, yes, I
           match the evaluation that's in GALL, and we'll write
           an application section.  There will be other
           programs where the applicant feels that the program
           evaluation -- their program is the same program
           that's evaluated in GALL, but maybe there's kind of
           a mismatch in terms of how they implemented their
           program and the evaluation in GALL.
                       For example, GALL might say you have a
           monitoring and trending provision in that program,
           and this particular applicant does not have that. 
           We're going to show how we would write that up.  We
           feel like we would need to address that particular
           attribute for that particular plant.
                       Then, the third thing would be a new
           program or an inspection, not in GALL.  We think we
           need to do it.  We'd show how we would write that
           up.  So, in essence, what we plan to give to the
           staff by the end of April are application sections
           that show these three -- these three scenarios, if
           you will.
                       What we need to work out with the staff
           is there are a lot of other things we're going to
           have available.  For example, how do you treat an
           aging effect that's identified in Gall that you
           don't think you have or doesn't apply to your plant? 
           How do you treat an aging effect that's not in GALL
           that you think is in your plant?
                       And we talked about that.  I mean, we
           have an obligation to -- you know, to put those in
           the application.  So we're going to try to test all
           of those different possible scenarios, give that to
           the staff, and then I'm not sure that we've -- we've
           come to agreement on whether they would actually sit
           down and write RAIs, which would be helpful, or
           whether we'll have some dialogue up front and then
           repackage the demo work, send it back in and then
           get RAIs.
                       But at the end of the day what we expect
           to walk away with is an understanding of what an
           application looks like using GALL and the -- and I
           would say actually using the SRP, because the SRP is
           the document that the staff will use.  And we've had
           this discussion with the staff, that GALL is not a
           scoping document, etcetera, etcetera.
                       So we will use GALL, but it's really,
           you know, the SRP and GALL that we're looking at. 
           And at the end of the day, what we hope to end up
           with is an understanding of how an application looks
           using, you know, GALL and the SRP.  And then, you
           know, the applicants go off and finish their work
           and submit the applications that, you know, reflect
           whatever we come up with in talking to the staff. 
           So --
                       MR. GRIMES:  This is Chris Grimes.  If I
           could add to that and clarify, first of all, with
           respect to -- Doug commented that the Class of '02
           is the first group for which GALL is going to apply. 
           We intend to use GALL for the Class of '01, but the
           Class of '01 -- the plants that are coming in in
           June and July, their applications are essentially
           complete.  They're going through peer reviews. 
           They're prepping -- they're packaging the shipments
           to send them in.
                       That does not mean that there is less
           urgency in terms of keeping to the aggressive
           schedule to complete GALL, SRP, and reg. guide for
           the Class of '01.  The Class of '02 is in the
           process right now of figuring out how to package the
           application.  So they are the first customers of the
           maximum benefits of this guidance.
                       My expectation is that at the conclusion
           of whatever we agree is an appropriate demonstration
           effort, that we will not only be able to identify
           ways to improve the guidance on the contents of the
           application, but we would also be able to provide
           guidance in the standard review plan and in the
           inspection guidance that explains how to treat these
           commitments in an application relative to
           conformance with the GALL Report.
                       So I would expect to be able to expand
           on the guidance to the staff in terms of what is --
           what does it mean when they say, "We meet the GALL
           Report"?  How far does that go?  How is that
           supposed to be tested in a safety evaluation?
                       And then, also, we need to provide
           collateral explanations to the inspectors in terms
           of how to inspect the validity of the contents of
           the application in terms of how GALL is referenced. 
           So I would expect it to complete -- a complete
           success for the demonstration project will be
           revisions that we would bring to the committee and
           say, "This is what we're going to do to enhance the
           guidance to make sure that we will all get the
           maximum benefit out of this catalogue."
                       MEMBER LEITCH:  But isn't what you're
           developing essentially a more finely divided pseudo
           GALL Report?  In other words, what I'm saying is
           suppose that half the plants in the Class of '02
           have some deviation from the GALL Report.  Then, I
           guess wouldn't you really like to see a GALL section
           that applies to that half of the plants, and say,
           "This is an acceptable approach"?
                       MR. WALTERS:  Sure.  We would.  I don't
           know -- I think we would, and I think that's
           certainly something that may come out of the demo. 
           But certainly we would be looking for, I guess as
           the Class of '01 and '02 go through the process --
                       MEMBER LEITCH:  I mean, if there's just
           one plant that's an outlier, that --
                       MR. WALTERS:  That's different.  Right.
                       MEMBER LEITCH:  -- do it on a plant-
           specific basis.  But perhaps you identify --
                       MR. WALTERS:  That's right.
                       MEMBER LEITCH:  -- the plants --
                       MR. WALTERS:  And I think we've
           understood that from day one on this, that I think
           the staff acknowledged that.  And as we go through
           the process, we might find that we missed something,
           or, hey, everybody is taking credit for this
           program.  We don't have that in GALL.  Maybe we need
           to put that in GALL.
                       So we will be looking for those.  Yes,
           that's a very good point.
                       MR. LEE:  This is Sam Lee.  I guess one
           of the presentations you heard earlier today was on
           the buried piping program.  That's a good example
           where we have one program in GALL, but it turns out
           the -- I guess the first couple applicants, they
           actually developed something quite different.  Okay? 
           But it's quite generic, so we say, "Okay.  That
           looks like a generic program.  That's acceptable to
           staff."  We actually added that in GALL.
                       And so I -- I foresee this process will
           continue.  As we learn more, we will put more
           programs together.
                       MEMBER LEITCH:  That's good.  Thank you.
                       CHAIRMAN BONACA:  I'd like maybe a
           judgment.  Are we ready to finalize GALL and the
           SRP?  I understand there is still some negotiation
           going on, but that will go on forever it seems to
                       MR. WALTERS:  Yes.  I believe we are
           ready.  We're focusing a lot on open issues, which,
           you know, we identified five and there may be some
           others.  But the flip side of that is there's an
           awful lot that's been agreed upon.  We're anxious to
           get -- you know, get moving on using GALL.  We're
           going to have issues that come up -- the small-bore
           pipe issue, for example.  We need to continue to
           work on that.
                       But, yes, we're ready to go.  We think
           it's the right thing to do at this point.  And let
           me just say that I think while we do have
           differences -- and we both -- you know, the industry
           feels pretty strongly about some of these open
           issues, very strongly, probably more from a process
           standpoint or a regulatory standpoint than a
           technical standpoint.
                       However, I think that the process we
           used -- you know, the staff developing GALL, the
           opportunity for the industry to get together, the
           frequent meetings we've had, has been a big success
           in our view.  It's worked very well.  You know,
           we've had good meetings with the staff.  We've
           gotten a lot of good insights from them, from the
           labs that they used.  
                       And so I think, you know, based on all
           of that, we're ready to move.  I think we're very
           comfortable with where we are.
                       CHAIRMAN BONACA:  Is it your -- you said
           that you will comment on that, too.
                       MR. GRIMES:  That's correct.  If this is
           the appropriate time, I would say that I agree
           entirely with what Mr. Walters has characterized as
           where we are in the process.  We afforded -- we know
           that the industry feels very strongly about the
           specific issues that are identified for future
                       We feel very strongly, too, and we
           afforded the industry an opportunity to say let's
           stop the process right here and take these issues
           through appeal.  And the industry agreed that this
           was something for which -- this isn't make it or
           break it; we'll keep talking.
                       And so we -- and I also want to echo
           what Doug explained as there has been a substantial
           amount of agreement in terms of the resolution of
           comments, clarification of treatment of aging
           effects for which we expect to see substantial
           benefits in the future reviews, and we all want to
           start seeing those benefits as soon as we possibly
                       The sooner that the Commission approves
           the improved renewal guidance -- and at this point I
           also want to mention -- but we recognize that there
           are other places where we could probably improve the
           guidance even further.  I do not want you to leave
           the impression that we're bringing to you a product
           that's good enough not to be noticed as bad.
                       This is a product that we believe might
           not be world class yet, but it certainly represents
           an excellent level of effort for which we can remove
           some more repetition, we can clarify where some of
           the unplugged pieces might have gone.  
                       We covered a lot of ground with this
           material, and we think it's ripe for the ACRS to
           endorse this product for Commission approval with
           the same recognition that the industry has that
           there is still some future fine-tuning that will
           improve its utility and its readability and its
           transparency to the public.
                       And we'll continue to work on those
           lofty expectations, with an expectation that we'll
           be able to get there in a few years, as additional
           lessons are learned, and as additional feedback is
           provided to add to some of the detail.  But we
           believe that the product that we have right now is
           good to go, and we request your endorsement.
                       CHAIRMAN BONACA:  And I would expect
           that, you know, the implementation of these
           documents in a final form, when they're used in the
           field it will also help resolve some of the open
           issues, because, I mean, we will be testing.  And
           without it, it's going to be open forever, because
           the issues are not going to be completely closed.
                       MR. WALTERS:  One of the lessons we
           learned, you know, early on when we changed the
           rule, we had a lot of good discussions with the
           staff, and they were philosophical in nature,
           "Here's how the rule should work."  But the reality
           is it's not until you get a Calvert Cliffs to
           actually put pen to paper, and you submit it and
           people can exercise the process that you really, you
           know, identify where you need to perhaps make
           changes.  And that's where I think we are with these
           guidance documents.
                       We've done a lot of talking.  We've had
           a lot of good interactions.  We now need to get on
           with the business of actually implementing it and
           applying them.  Let's see how it goes, and then, you
           know, make changes as we think we need to.
                       CHAIRMAN BONACA:  Good.
                       MR. GRIMES:  Dr. Bonaca, I also want to
           point out that we've received a lot of good feedback
           during the meeting today as well.  And there are
           some questions for which we owe you answers, and
           there are some commitments that I'm prepared to make
           in terms of things that we're going to put on the
           list for continued dialogue with the industry about
           future improvements to this guidance.
                       But we've got a fairly substantial
           package here that I'm ready to take to the
           publisher, and we have had an extensive consistency
           review with both of the labs participating, in order
           to make sure that we've gotten as much of the
           editorial improvement included without doing any
           damage.  That is, we didn't allow the latitude for
           folks to go in and try and do any fine-tuning during
           that consistency review.
                       But we will continue to respond to
           particular questions and to gather material for the
           next round when we go for the first revision in this
           guidance -- in these guidance documents.
                       MR. BARTON:  Okay.  Chris, what's your
           date to go to Commission with this?
                       MR. GRIMES:  It's scheduled to be
           delivered to the EDO on April 23rd for delivery to
           the Commission by  April 30th.
                       MR. BARTON:  Okay.
                       MR. GRIMES:  The Commission meeting is
           scheduled for June 16th, I believe.  14th.  The 16th
           is a Saturday.  I keep trying to get them to move it
           to the 16th.
                       CHAIRMAN BONACA:  Okay.  Any more
           questions for Mr. Walters? 
                       MR. WALTERS:  Thank you.  Thank you very
                       CHAIRMAN BONACA:  Before we take a
           recess for lunch, in the afternoon we have the
           review of the BWRVIPs.  But I would like to go
           around the table now and get -- see if there are any
           comments from members right now about the letter we
           will write.  I think we should write a report on
           this issue.
                       My judgment is that we should encourage
           finalization of these documents at this time.  I
           think that, you know, we already voiced in a
           previous letter recognition of the fact that there
           has been a significant effort here.  This was a
           remarkable compendium of information in GALL, has
           been restructured and has been refocused, but hasn't
           certainly been degraded as improved probably.
                       The other thing that I think is
           remarkable, as we noted, was the level of
           collaboration between the industry and the staff
           that has made these documents quite effective.  And
           it shows the importance that we begin to see
           application that makes reference to this baseline
           documentation which has been so substantial.  And
           right now it's moot in the application.
                       So, you know, I will propose that we
           will have their recommendation in a letter, and I
           will appreciate from members other insights on
           whatever else you need to see in the letter.
                       John, maybe you have some thoughts?
                       MR. BARTON:  Well, Mario, from my
           review, I think you are going to continue to have
           dialogue I think until you see more applications
           come in.  You may have to change the -- I can see
           where you will have to change --
                       CHAIRMAN BONACA:  At some point.
                       MR. BARTON:  -- the document.  But I
           think, you know, from the work that's been done to
           date, I don't have any problem supporting where they
           -- to go forward with where they are.
                       MEMBER FORD:  I'm coming from a lack of
           experience, Mario, but my main concern was the
           document would not be so cast in concrete that it
           couldn't take into account unforseen degradation. 
           Now I understand that that is taken into account.
                       CHAIRMAN BONACA:  Yes, it is.
                       MEMBER FORD:  So from my lack of
           experience, yes, I would endorse it.
                       MEMBER KRESS:  I would endorse it, too,
           Mario.  I think it's going to be a continuous
           process of slight iterations, but I think it's at
           the point where we can let those take care of
                       CHAIRMAN BONACA:  Yes, I think so.
                       MEMBER LEITCH:  I guess we are speaking
           now specifically about GALL, are we, as contrasted
           with the SRP and the --
                       CHAIRMAN BONACA:  Well, the whole thing.
                       MEMBER LEITCH:  The whole thing.  Well,
           let me, first of all, say I have no problem
           endorsing GALL.  It is, you know, one of those
           documents that's 99 percent -- maybe even a higher
           percentage than that -- satisfactory.  And there is
           a few little things that are going on that still
           need further dialogue, and that will always be the
           case I think.
                       I mean, that will be going on for some
           considerable period of time.  So I think it's -- the
           time is to endorse this and get on with it. 
                       I do also think there are some -- if
           there are issues of disagreement, there are some
           caveats at the beginning of GALL, what GALL is and
           what GALL is not, that helps clarify that issue.  I
           mean, GALL doesn't purport to be all-encompassing. 
           There could --
                       CHAIRMAN BONACA:  Or the only solution.
                       MEMBER LEITCH:  -- be systems not
           included in GALL.  Conversely, there could be
           systems in GALL that are not required.  And it also
           speaks about the plant has to ensure that programs
           that they actually have complies with the -- is in
           line with the program in GALL.
                       So with all those upfront discussions of
           what GALL really is, I have no problem with
           endorsing it.
                       Similarly, I'm not sure if we're talking
           about the standard review plan.  I guess it's,
           similarly, in draft form, is it not?  And I think --
           I guess -- yes, it is still a draft, and I think we
           probably need to get on with approving that draft.
                       And then, the last document that I
           believe is still in draft form is the Reg. Guide
           1.188, which endorses the NEI.  But I think from
           what I heard there is still some -- some changes
           proposed in the NEI document.  I think the reg.
           guide -- I think this has to get to a point where we
           say, "This is" -- that is, the NEI document has to
           say, "This is Revision X," and then this document,
           the reg. guide, has to say, "We endorse Revision X."
                       Because I think there are still some
           minor discrepancies between these two things.  So I
           think the staff has to be clear with this reg. guide
           exactly what revision is being endorsed.  But I
           think that should be pursued promptly.  I don't see
           any reason why that can't happen right away.
                       MR. GRIMES:  And I'd like to clarify, it
           is our intent to take this -- the draft regulatory
           guide, in its present form with its changes, along
           with NEI 95-10, Revision 3, in its final form.  And
           Doug explained that they're looking at some final
           changes before they give us the package that we
           would refer to.  
                       And Dave Solorio pointed out, we'll look
           at that final version to verify that they didn't
           make any changes that would undue our ability to
           endorse it without comment.  But then, that whole
           package, along with the draft standard review plan
           and the draft SRP, is the package that we would
           intend to present to the Commission the end of
                       MEMBER LEITCH:  Right.  Okay.
                       MR. GRIMES:  And we will inform you if
           there are any substantive changes beyond just trying
           to identify any typographical errors or missed
           connections, or things.  But we don't intend on
           changing the substance any more than what we've
           described to you today.
                       MR. BARTON:  You said the SRP and the
           standard review plan.  Do you also mean the GALL?
                       MR. GRIMES:  That's correct.  The
           package consists of the regulatory guide and its
           connection to NEI 95-10, Revision 3, the standard
           review plan.  And the standard review plan
           incorporates, by reference, GALL.
                       MR. BARTON:  Right.  Okay.
                       MR. GRIMES:  And then, to complete the
           package as it's presented to the Commission, there
           is the NUREG report that explains the resolution of
           all the public comment, so that is folded in, but it
           is not guidance.  It's part of the package.
                       CHAIRMAN BONACA:  Bob?
                       MEMBER UHRIG:  I support this.
                       CHAIRMAN BONACA:  Bill?
                       MEMBER SHACK:  No.  I'm sure, you know,
           we'll continue to approve it, even on the small-bore
           piping.  I like the ANO solution better than the
           staff's solution, and I hope everybody will take it
           as a precedent.
                       CHAIRMAN BONACA:  But the process allows
           that right now, so --
                       MEMBER SHACK:  But as Chris said, I
           mean, you really can't use this until it becomes an
           official document and --
                       CHAIRMAN BONACA:  Yes.  And I think we
           should stress the fact that what we review today, it
           would be -- certainly make the reviewer's job much
           easier if there was a more substantial referencing
           to establish documents of guidance, and they are
           missing right now.
                       The other thing that we -- in the
           interim letter we wrote, we also wrote that it would
           be important to update these documents frequently. 
           They sure don't reflect experience.  So there is
           already opportunity for incorporating changes.
                       Before we recess, I would like to ask
           one more question.  First of all, are there any
           other issues that you would like to see reflected in
           the letter?
                       MR. GRIMES:  I have a question, Dr.
           Bonaca.  And is there anything in particular you
           want us to prepare to present to the full committee?
                       CHAIRMAN BONACA:  Yes, I -- yes.  We
           foreclose that, however, because that may be an
           issue.  I raised the issue of scoping because it's
           one that I've been reviewing specifically, and I'm
           still somewhat concerned about, you know, the lack
           of transparency in some reviews when -- when -- I
           mean, the early applications were transparent
           because there was a scoping process.  All the
           components were there.  Then, there was a screening
           going in saying, "Well, what are the functions?" 
           Well, the function is not required, and it doesn't
           belong in license renewal.  And you see the outcome.
                       Right now, what is going to be agreed to
           is only the outcome, which is going to be leaving
           the reviewer in -- not the staff, because they have
           the benefit of being able to go and audit -- it's
           going to leave certainly a reviewer like ACRS unable
           to make a judgment.  I mean, we have to purely make
           a judgment based on process and staff statements.
                       So do you feel that that's an issue we
           should bring up or not?
                       MEMBER SHACK:  It sounds as though they
           made it a legal issue.  You know, again, I kind of
           surrender when they -- when they hit me with the
           OGC, I give up.
                       CHAIRMAN BONACA:  Well, I mean, still,
           we've got to express an opinion, you know, because I
           think ultimately we want to make sure that these
           processes by which you are licensing these plants
           are transparent the public.  And, you know, I --
           again, I view ourselves as the public in a certain
           way.  We are coming at the end of the process.  We
           are less informed than the staff and the applicant,
           and we're trying to make sense out of what is being
           done.  So --
                       MEMBER SHACK:  Well, it certainly sounds
           as though we ought to encourage them to include it.
                       CHAIRMAN BONACA:  Well, that would be
           the only way would be purely that, you know, we like
           it better one way or the other, simply not forcing
           away.  I mean, what is being proposed is acceptable. 
           I realize it meets the requirements of the rule.
                       MEMBER KRESS:  I viewed our role as
           auditing the process, to see that the process would
           result in an acceptable product.  So, personally, I
           think it's all right to do it.  You know, we've
           already looked at the process, and we know that the
           staff is diligent about following such a process. 
           So I really don't see that it needs to be that
                       CHAIRMAN BONACA:  Let me try -- if I put
           anything in, I'll just put in a paragraph, and then
           I'll let you guys make a judgment, and then we can
           decide then.  It certainly will be only in terms of
           expressing an opinion rather than giving a
           recommendation at this stage.
                       MR. BARTON:  That's a good suggestion.
                       CHAIRMAN BONACA:  All right.  Now,
           regarding the meeting next week, I think that we
           don't want to go through the specifics, but it will
           be interesting to have a categorization by a generic
           type of changes.  For example, some of them were
           repackaging.  Some of them -- and we don't need to
           hear about the repackaging issues.
                       I mean, some of them were increase
           focus.  Okay?  Some of them were minimal acceptable
           programs.  It will be interesting to understand, you
           know, the category of changes and a judgment of
           whether you see there has been any erosion of
           programs or not.  I guess the judgment would be that
           there isn't, so -- but just the categorization of
           those, it would be interesting to hear for the
           committee.  And then we'll decide how much time
           there is for this portion here.
                       The other thing that -- I can maybe
           provide some examples, give one example for each
           category, so we understand what the process of the
           change was. 
                       The other thing that I thought
           personally, and then we'll go around the table and
           see what other thoughts there are here, it would be
           to -- to talk about the one-time inspections.  I
           know that some of the other members -- for example,
           Dr. Powers -- was interested in those, and I think
           it's important that we get an understanding of that.
                       And since we are going to have a
           presentation on Hatch on the same morning, it would
           be interesting to see, you know, specifically the
           one-time inspection for Hatch spelled out, so we can
           have a correlation between what we see in the
           morning --
                       MEMBER SHACK:  Why don't we toss in ANO
           and complete --
                       CHAIRMAN BONACA:  Well, see, but that's
           -- then we have an understanding how -- we
           understood, for example, the issue of small-bore
                       MEMBER SHACK:  But ANO is a very
           interesting contrast.  I mean --
                       CHAIRMAN BONACA:  Sure.  I mean, but it
           raises questions, and there are good reasons.  But I
           think that it would be good for the whole committee
           to hear it and to see the reasons why we're going
           from so many to so little.  It doesn't mean that we
           are not doing it.  It means that something else is
           taking care of that, particularly the ISI for the
           small-bore piping, which is risk-informed.
                       Any other issues you feel that we
           should --
                       MEMBER SHACK:  Well, I think they ought
           to discuss the open issues.
                       CHAIRMAN BONACA:  Yes.
                       MEMBER SHACK:  Clarify those and flag
           those out.  Again, there has to be some emphasis on
           the perspective here.  You know, you have open
           issues, but, you know, really, you have resolved so
                       CHAIRMAN BONACA:  And, of course, you
           want to communicate your recommendation that we
           recommend finalization of the documents.
                       Anything else?  If not, then we'll take
           a recess for lunch.  We'll meet again at 20 after
                                   (Whereupon, at 12:21 p.m., the
                       proceedings in the foregoing matter went
                       off the record for a lunch break.)
                     A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                    (1:18 p.m.)
                       CHAIRMAN BONACA:  We are resuming now
           with the BWRVIP reports and their applicability to
           license renewal.  With that, I pass it to Mr.
                       MR. CARPENTER:  Yes, sir.  I'm Gene
           Carpenter.  I'm with the Materials and Chemical
           Engineering Branch, and I'll be talking to you today
           about the BWRVIP reviews for license renewal.
                       The agenda that I'll be following is an
           overview of the BWRVIP program, which will be
           basically given by Robin Dyle of the Southern
           Nuclear/BWRVIP Assessment Chairman.  Then I'll be
           talking about the staff's review of the BWRVIP
           reports with some overview of the current operating
           period, the generic aging management plan that we
           have looked at, the reports supporting the BWRVIP
           generic aging management program, and I'll be giving
           some specific examples of those, and then I'll be
           going to the conclusions.
                       Staff's perspective -- BWRVIP is a
           voluntary industry initiative that began in 1994 to
           address the Generic Letter 94-03, core shroud
           cracking issues.  As you may recall, we briefed the
           ACRS on this some years ago about this issue and
           talked to you about it at that time.  
                       Since then, it has grown to address all
           BWR internal components, reactor vessel, and Class I
           piping.  It also covers the current operating term
           and the extended operating period, and it is
           proactively addressing aging degradation issues that
           are beyond regulatory requirements.
                       The staff has been reviewing the BWRVIP
           submittals, and that includes some 15 inspection
           flaw evaluation guidelines, which I'll be going over
           in some detail today; 13 repair and replacement
           design criteria guidelines; four crack growth and
           mitigation guidelines; 22 other supporting reports;
           and 12 license renewal appendices.
                       Now, point of information -- although
           there are 15 inspection flaw evaluation guidelines,
           three of them are subsumed into two others, so that
           is -- that takes care of that, and then with the 12
           license renewal appendices it makes up the aging
           management program.
                       The staff expects to finish the reviews
           of these documents listed by the end of this year,
           and this is, of course, dependent upon timeliness
           and technical review adequacies.
                       Now, presentation is by Mr. Dyle.  He's
           going to go over some of this.  He's, as I said, the
           Technical Chair of the Assessment Committee.
                       MR. DYLE:  Thank you.  I appreciate the
           opportunity to be here.  As Gene said, my name is
           Robin Dyle.  I'm from Southern Nuclear, and I'm
           currently the Assessment Chairman -- Assessment
           Committee Chairman.
                       Now I have a little bit about the
           organization.  I consulted with Dr. Shack last week
           to try to understand --
                       MEMBER SHACK:  He happened to be in
                       MR. DYLE:  We were -- I apologize.  We
           were at Argonne last week, and I --
                       MEMBER SHACK:  For rest and recreation.
                       MR. DYLE:  Yes.  And the question I
           asked was, who on ACRS heard our presentation seven
           years ago, and he basically said three people.  So
           as Gene and I talked about how to describe this and
           the information we thought you might need, there is
           some programmatic information.  And what I'd like to
           do is explain how the program was put together, the
           things that went into it, so that you understand,
           then, the depth and the breadth of the program and
           how the licensees are using it.
                       What I am using here is a boiled-down
           version of a six-hour class that we teach for the
           licensees.  So some of these slides I will simply go
           through, but they're there for completeness, so that
           you can have them to refer to later.
                       Please stop me as I go on with any
           questions you have.
                       CHAIRMAN BONACA:  Yes.  At some point,
           whenever it's convenient, it would be probably good
           for us to have, if you have a little schematic --
           and I think you do have it -- a representation --
                       MR. DYLE:  Yes.
                       CHAIRMAN BONACA:  -- to give us just a
           brief schematic of the BWR internals, the function
           that some of these perform, like the shroud, and --
                       MR. DYLE:  Top guide.
                       CHAIRMAN BONACA:  Yes.  And then the
           location of cracks that have been experienced to
           date, and also -- the other thing which is important
           to understand is not all kinds of cracks will cause
           safety consequences.
                       MR. DYLE:  Right.
                       CHAIRMAN BONACA:  A few, however, have
           safety implications, and you could point to us which
           ones really -- you know, briefly, just so that we
           get an overview --
                       MR. DYLE:  Okay.
                       CHAIRMAN BONACA:  -- and I would see it
           as a cap to the whole package of the BWRVIP.
                       MR. DYLE:  Okay.
                       CHAIRMAN BONACA:  It will help us.
                       MR. DYLE:  When I get to the point of
           doing the detailed discussion, I'll -- if I forget,
           stop and remind me and see if there's anything else
           that I failed to address.
                       CHAIRMAN BONACA:  Okay.
                       MR. DYLE:  Because I'm going to try to
           do a broad overview, and then I've got several
           components that we talk about in more detail, so you
           can see how the program is put together.
                       I'd also like to mention that Mr. Bob
           Carter is here sitting at the table.  He is the EPRI
           task manager who has handled this program from an
           assessment standpoint since we began this effort. 
           And we've got some of the I&E documents.  Should you
           ask a question that we don't have in the
           presentation, we'll have that available.
                       As I mentioned, the purpose of the
           presentation is to give you kind of an overview of
           where the VIP came from, look at the scope of the
           program and how and why we selected the components
           we did, because all the internals are not in there,
           and there's a reason for that.
                       We need to identify the attributes that
           ought to be part of, you know, what a plant does to
           make sure they do the things that are appropriate,
           and this would apply to license renewal.  And then
           we'll talk about some of the guidelines.  
                       And the detailed review that I have
           planned based on input from Gene was the flaw
           evaluation guidelines for the shroud, the jet pump,
           the top guide, and then a discussion of what we've
           done recently on IGSCC related to piping in the
           recirc. loop.  So that will be the presentation.
                       From a historical perspective, back in
           the 1980s, IGSCC and piping was an issue.  We were
           concerned with it.  And we recognized that it could
           potentially affect internals and started working on
           that in the owners group.
                       The shroud cracking that occurred in '93
           and '94 provided additional evidence that we needed
           to address internals cracking in IGSCC.  So, in
           1994, the utility executives recognized that it was
           a big enough issue that they separated this issue
           from the owners group and formed the VIP as a stand-
           alone committee that would focus on the internals. 
           So that was the purpose of this organization.
                       And here's the executive guidance that
           we had.  We're to lead the industry toward a
           proactive generic solution.  And what we did with
           that was one of the things that Bill Russell
           actually said he thought was a good thing we had
           done was we set aside the licensing arguments.  We
           made no licensing arguments in the VIP.  We did the
           technical thing first, described what the problem
           was, what the solution would be, and then after the
           fact tried to figure out how that fit into the
           licensing arena.  So we were trying to do the right
           thing for the right reasons.
                       The other thing was to have options. 
           Because we were looking at new things, we wanted a
           cost-effective approach.  There might be one thing
           that one utility would want to do and another that a
           separate utility would like to do.  But both were
           equally adequate in addressing the safety issue, so
           we tried to build that into the program.
                       We also served as the focal point to
           interact with the staff, and that has worked well.
                       And the last item is that we share
           information among the members.  We've got the
           program set up so that periodically all the
           inspection information is funnelled back to the
           members.  It's also given to the staff, so that we
           can keep this program a living program.  If
           something new happens that we didn't anticipate,
           that's the vehicle to find out about it and modify
           the program as we go forward.
                       From a dollar standpoint, here is the
           issue.  If you look -- and that doesn't come out
           very well in the colors.  I apologize.  But in the
           early '80s, this loss of capacity due to pipe
           cracking was a big issue.  We're talking 12, 14, 20
           percent loss of capacity for the BWR fleet because
           of pipe cracking.  We didn't want that to happen,
           and we've tried to manage the internals, and we
           think we've done so.
                       Here's our biggest loss of capacity
           related to internals cracking.  So the other thing
           that this program did was let us manage the problem
           proactively, so we could continue to operate the
           plant safely and minimize the cost.  To date, we've
           spent in excess of $30 million on this program of
           utility funds to go forward.
                       The next slide is a list of the domestic
           plants.  All of the domestic plants are in the
           program.  I won't spend a lot of time.  And the next
           slide simply is to let you know the international
                       The benefit of this is they've done
           things differently.  In the early days of the shroud
           cracking, we wanted to understand better what the
           weld residual stresses might be.  The Japanese had
           actually built a shroud using their old welding
           procedures and then done the destructive analysis of
           it.  So by having them be a member, we were able to
           share that information and build that into our
                       So that was one of the benefits of
           having the international folks, and they continue to
           be members and provide active support.
                       Here is the project scope, and the scope
           for the VIP initially was we'll take care of the
           vessel and the nozzle.  So from the safe end weld
           out, that belonged to the owners group or some other
           activity.  We focused on where we needed to be
                       We did a safety assessment, and I'll
           talk a little bit more about that in just a second,
           that helped us identify what needed to be done and
           when it needed to be done.  And when it all boils
           out, these are the components that are included in
           the VIP program that are considered safety-related.
                       The other thing that we prepared -- and
           Gene mentioned those, and I did, too -- what we call
           I&E guidelines or inspection and flaw evaluation
           guidelines.  There is this one, the I&E.  This
           describes what and when to inspect, and this is done
           by the Assessment Committee.
                       You know, how is this component going to
           fail?  Where is it going to fail?  How often should
           I inspect it?  What method should I use?
                       The NDE guidelines where we have the NDE
           experts working, they develop the qualification
           criteria.  You know, how would you qualify a UT
           instrument to go down and do a shroud weld H4?  So
           they work on that and look at the errors involved.
                       We develop repair guidelines because we
           anticipated having cracking and needs that -- where
           we would need to fix things.  So they're done.  And
           then mitigation hopefully offers the silver bullet
           for the future, to find ways to turn off the
           cracking through use of hydrogen water chemistry and
           noble metal.
                       Real quick, that's the organization and
           it's no longer current because I'm now the Technical
           Chairman here.  But these are how we broke -- these
           represent the committees and the committee
           structure.  This is how we broke the work up.  And
           the other thing that was important was that we have
           an executive responsible for each section.
                       And you notice that we'll have an
           Executive Chair.  Currently, Integration is open
           because of mergers and changes like that.  We
           periodically have open slots.  But the main thing to
           see is the structure, the organization, and that
           there is an executive leading each one of these
           technical committees.  And that has been vital to
           making the program successful.
                       The next slide simply is a list of the
           Inspection Committee products or some of them, and
           we'll talk about a few of these.  But this also
           gives you an overview of how we work the program
           together.  We have the I&E guidelines, and then we
           have crack growth or fracture toughness reports, and
           they've been submitted to the staff.  We've got one
           for stainless, one for nickel-based alloys, one for
           low-alloy steels.  So those have been provided, and
           those provide additional support to the program.  
                       Again, I'll talk about the safety
           assessment on the next few slides.  Component
           configuration drawings, which we provided to the
           staff -- as we develop this program, we pull
           drawings from all available resources at GE for the
           as-designed structures.  We save those, cut and
           pasted them, and put them into a document so that
           now each owner has a list of all the documents, has
           sketches that he can look to see if cracking occurs
           at one plant.  
                       He can look and see what that
           configuration is, how it applies to his plant, and
           what actions he might need to take.  And it's all
           readily available, and it's also here for the staff
           to use, so they can understand those same issues.
                       We've done some bounding assessments. 
           This goes back as a follow-on to Generic Letter 92-
           01 looking at the vessel.  
                       The effective IHSI, one of the issues
           that we dealt with -- and I'll talk about it when I
           get to the piping -- was the effectiveness of the
           induction heating stress improvement and how well
           that works in mitigating IGSCC.  And it ties to the
           88-01, and I'll talk about that.
                       Integrated surveillance -- I'll just say
           here that we're working on a program similar to
           that, I'd say, like the B&W plants have done in the
           past where we can get a smaller group of plants that
           have the right materials and integrate our overall
           surveillance program, so that we better understand
           what's going on with vessels and adjust the capsule
           withdrawal schedules.  And that's under development
           right now.
                       The next two slides are simply a list of
           the I&E guidelines for these safety-related
           components, and I'll -- unless you have a question,
           I'll just go on past those.
                       MEMBER LEITCH:  Would the nozzles be
           under the RPV?
                       MR. DYLE:  Yes, sir.
                       MEMBER LEITCH:  It seems to me there was
           a particular problem with the CRD return line
           nozzle.  Was that return line eliminated in all
           plants?  I know many of them it was. 
                       MR. DYLE:  No, sir.  It was eliminated
           in all but two.  The two BWR-2s did not cut and cap
           the CRD return lines.  The rest of the plants did. 
           And that's addressed in NUREG-0619 that addressed
           the feedwater nozzle cracking and the control rod
           drive return line.  And then that, as it applies to
           license renewal, is addressed in BWRVIP 74, which is
           our vessel license renewal document.  So that's
           where we brought that information forward.
                       MEMBER LEITCH:  What are the two BWR-2s? 
           Do you remember off hand?  Is it Oyster Creek?
                       MR. DYLE:  The BWR-2s would be Nine Mile
           1 and Oyster Creek.
                       MEMBER LEITCH:  Thanks.
                       MEMBER FORD:  You were going at such a
           rate that I didn't want to stop you.
                       MR. DYLE:  That's fine.
                       MEMBER FORD:  Back on page 8 --
                       MR. DYLE:  Yes, sir.
                       MEMBER FORD:  -- you listed the
           components there, and I'm presuming they're going in
           terms of priority from the core shroud down to the
           RPV as the bottom priority.  What was the criteria
           for that risk assessment?
                       MR. DYLE:  You're a wonderful strike
           man.  The next slide, page 14 --
                       MEMBER FORD:  Okay.
                       MR. DYLE:  Couldn't have timed it
           better.  Thank you, Dr. Ford.
                       For years we understood that there were
           some components that were safety-related and not. 
           But when we started the VIP, we said, "Let's make
           sure.  Let's revisit that issue.  Let's go back to
           GE and talk about how this thing was designed and go
           from there."
                       So we said, "We're going to identify the
           safety-related components and separate them from the
           non-safety," and here's the criteria that we used
           when we looked at the components -- maintain a
           coolable geometry, rod insertion times, reactivity
           control, core cooling, and instrumentation
           availability.  So all of those were considered in
           determining whether something was safety-related or
                       Some components, as it turned out, were
           not.  The feedwater sparger sometimes is surprising,
           but it has no safety function.  It disperses the
           water equally about the annulus, and it improves jet
           pump performance, but it is not relied on in any way
           for safe performance of the vessel or any ECCS
           function.  So that's just an example of how we did
           that and how we separated those.
                       MEMBER KRESS:  What exactly is a safety
           assessment, contrasted to a PRA, for example?
                       MR. DYLE:  Oh.  It was a deterministic
           assessment where we looked at the failures of the
           components, and I have that discussed later in VIP
           06.  But we did a deterministic assessment, said,
           "What is this thing supposed to do?"
                       MEMBER KRESS:  If it failed --
                       MR. DYLE:  If it fails, what happens? 
           What other systems are available?  And given that
           those systems available, what happens if it fails? 
           And so one of the things we found -- and we
           determined this when we did the core shroud
           initially and did the detailed safety assessment
           that Dr. Hackett and I presented years ago.
                       But when you looked at the core spray,
           every scenario -- or the core shroud, every scenario
           said, "We need the core spray."  And if the core
           spray failed, what else did we need?  
                       So that's part of what, then, Peter, led
           us to, how do we prioritize these things?  And the
           core shroud kept coming up on top.  Every time we
           assumed a component failed, that was it.  And that's
           the way we approached these things.
                       We just said, "What happens if it fails? 
           Where can it fail?" and did the assessment from that
                       Any other questions?
                       MEMBER FORD:  But a frequency of events
           in the past didn't enter into this particular --
                       MR. DYLE:  Not per se.  We did look at
           inspection history to try to figure out what the
           nature of the cracking was.  Core spray was one of
           those things that we had had lots of inspections and
           repeated instances of cracking.  So we knew that it
           was also something that we needed to look at quick.
                       We relied on it in a lot of scenarios,
           and it was one that was degraded to the point early
           on that we found cracking.  In fact, the staff wrote
           a bulletin on it in 1980 requiring visual
           inspections every outage.  So we have been
           inspecting the core spray lines and spargers since
           1980 every outage.  So that's an example.
                       CHAIRMAN BONACA:  I think the issue of
           frequency is important when it comes down to
           mitigation.  In some cases, for example -- I don't
           know.  I was looking at top guide.  There is some
           fragile mode where you may end up with core
           movement, inability of inserting rods.  You know,
           for that particular case, there is a statement that
           says, "If that happens, you know, there is the SLC." 
           Granted.  But SLC is not supposed to be needed more
           than with a certain frequency in the original design
           of the plant.
                       And so it leaves you a little bit with
           the question of how likely is this failure mode to
           occur now because of the cracking beginning to take
           place, which is the answer that there is mitigation. 
           I don't think, in and of itself, it is enough.
                       MR. DYLE:  Well, and I understand your
           question, and I think the answer is is when we did
           the safety assessment it let us know what was
           safety-related and what the consequences of a
           failure were, which we then rolled into
           consideration of which components do we look at
           first as far as developing a program, and then it
           also led us to decide what needed to be inspected
           and how often and what method.
                       CHAIRMAN BONACA:  So that really was
           focusing -- okay, so there was a consideration.  The
           main focus was the prioritization of the efforts
           because of the significance.
                       MR. DYLE:  Right.  One of the questions
           the staff asked initially when the core shroud
           failures and cracking started to occur was, why are
           the plants safe to continue to operate?  And we felt
           this was the degree necessary to evaluate that, so
           we looked at all of the components.
                       So that's been done, and we've built
           that into these inspection and evaluation documents,
           which I guess leads into this.  
                       As far as what's in an I&E guideline,
           this is it.  Each one of them has a description of
           the component.  We look at the susceptibility of the
           IGSCC, discussion of failure consequences of each
           location, and we tried to identify every location on
           an individual component where it might fail and
           said, "What happens if it does that?"
                       We looked at the inspection history, and
           then from that we develop inspection requirements
           and flaw evaluation methods, and it also talks about
           how to report the information.
                       MEMBER KRESS:  Could you give me an
           example of a consequence, the third bullet?
                       MR. DYLE:  Yes.  For the shroud, one of
           the things we considered was if you have a 360-
           degree flaw at the H3 weld, and then you have a main
           steam line break, what's the possibility that you
           might actually lift the whole shroud now that it's
                       And if that occurred, what would happen? 
           Would you lose two-thirds core height?  If a jet
           pump disassembles, if a jet pump beam fails, and
           then I eject the jet pump ram's head, then I could
           disassemble the jet pump, and I no longer have the
           ability to maintain two-thirds core height.
                       So we have to go put together an
           inspection program that would preclude those kind of
           things, or have a monitoring program that says we do
           daily surveillance to do some tests to get that kind
           of information.
                       CHAIRMAN BONACA:  But many of these
           failure modes -- that's why I had the original
           question in the beginning -- end up with core
           movement, right?
                       MR. DYLE:  Right.  They are -- and one
           of the questions that was asked early on, and I'll
           go ahead and address it now and then I'll let the
           staff talk about their studies, was, what are the
           synergistic effects?  And we struggled with that,
           finding a way to do that evaluation and spend enough
                       So we did our deterministic view.  Then
           we did a probabilistic assessment that I'll -- that
           was very simplified.  We set the conditional failure
           probability of each component to one and let that
           help tweak, if you will, the approach in VIP 06.  
                       And then the staff, on their own, did an
           independent assessment of that.  I believe one of
           the labs did the work, and I'd leave that to the
           staff to discuss the results of that.
                       As far as the description of the
           components -- again, we have sketches, we have
           locations labeled, general plant variations.  So if
           you've looked at the -- if any of you have had a
           chance to look at these documents, you may see four
           or five configurations, so that we can adequately
           describe what a different plant would have to do. 
           And it's based on the best-available design
                       The onus we put on the owners is that
           this is the way it was designed.  If you have made
           modifications since then, you have to look at this
           document, look at the requirements, and then go
           forward from there.  So we built that in.
                       Just an example of configuration
           sketches, not to have a detailed discussion.  But
           the double-leaf riser brace for the jet pump, there
           are two different types of double leaves, so that's
           just an example of the detail that we put in the
           document so you can figure out how it applies.
                       Susceptibility discussion -- which
           locations are likely to fail.  They're either
           through IGSCC or other mechanisms like fatigue.  We
           considered that.  What are the non-susceptible
           locations?  In those where we determined that they
           weren't likely to fail because of material
           considerations and the way that the component is
           built, we didn't necessarily require inspections.
                       But one of the things is you don't
           expect cast material to suffer IGSCC.  At least it
           would occur after you've got the wrought material
           that's been welded.  So we use those as kind of a
           criteria, and then all of that goes into the
           inspection requirements.
                       And I recognize I'm going quick, but
           this is to get you a description of the program.  
                       And then your question about the
           consequences of failure.  We looked at those, what
           happens, what's the other system responses. 
           Locations that could fail and have no adverse safety
           consequences, we said, "Well, maybe we don't need to
           inspect those."  But we did look at those anyway to
           see if there's other benefits for doing the
                       There may be economic reasons to do
           that.  You may want to do something.  We do a lot of
           inspection on feedwater spargers because we want the
           plant to continue operating.  If it fails, there's
           no safety consequences.  But we still do
                       At one time, I know at Plant Hatch we
           had three pages in a procedure that were safety-
           related inspections and 51 pages that were not. 
           That's the degree that we were doing internals
           inspections on non-safety components, so we do a lot
           of things in addition to the VIP.
                       The other thing we looked at was
           inspection history.  What inspections have been
           performed?  What was the adequacy of them?  If
           somebody had done a VT-3, and then said there was no
           IGSCC, we discounted that, because a VT-3 is not
           going to find IGSCC.  It's not going to see tight
                       So we tried to understand what the
           inspection history told us.  Is it appropriate data
           to consider?  And then we used that to help guide
                       The inspection requirements list where
           to inspect, what's required for a baseline, what's
           required for reinspection, what's the reinspection
           frequency.  Sometimes the reinspection frequency
           depends on the method you use to do your baseline
                       For example, core spray.  You do an
           inspection of it visually.  You have to do something
           every outage.  If you use ultrasonic, we'll let you
           go every other outage, because you've got a better
           idea of what's going on with that piping.  So that's
           an example of how we would use that.
                       We also specified what kind of scope
           expansion needed to be done if you found cracks,
           where would you look, what would the response be. 
           And then, alternatives to inspection -- is there
           something you could do instead of inspecting?  Could
           you modify the component that eliminates the
           consequence of failure?
                       The easiest one to think of is what we
           call the core plate, which is kind of a misnomer,
           because it's a plate in the core but the fuel
           doesn't sit on it, but the inspection criteria for
           the bolts around the periphery, so that it can carry
           a seismic load.  
                       However, we allow that if an owner goes
           in and installs wedges around the periphery so that
           even if the bolts fail the core plate can't move in
           a seismic event, then we say you don't need to
           inspect the bolts because you've put something else
           in there that will preclude its movement and it'll
           still perform its intended safety function.
                       MR. BARTON:  Has anybody done that?  Or
           is this a hypothetical?
                       MR. DYLE:  Yes.  Yes, they have done
           that. In fact, in the GE design for the shroud
           repair, that is integral to what they do.  To my
           knowledge, all of the plants that have installed the
           shroud repair in the GE design have the wedges
           installed.  So that's been done that way.
                       As far as inspection methods, here's the
           definition of them.  The EVT-1 -- well, let me start
           at the bottom, and maybe this -- the CSVT-1 is the
           old core spray visual that was required in the
           Bulletin 80-13.  We started using that and found in
           some cases it wasn't adequate, and we had renamed it
           MVT.  We finally eliminated that because it was an
           interim between these two and wasn't warranted.
                       So what we have is an enhanced VT-1,
           which is a visual with a 1/2-mil wire resolution of
           the camera before you ever start the inspection, so
           you've got to be able to clearly see a 1/2-mil wire. 
           In addition to that, there is also some criteria
           about what you can see about the weld.  There's
           requirements of necessity, whether you need to clean
           or not.  But you can do appropriate examinations.
                       The VT-1, you have to be able to resolve
           a 1/32-inch wire, and this is a standard code exam
           with VT-3 as a general visual for mechanical
           condition.  And, again, that comes from ASME Section
                       And then, ultrasonic and eddy current,
           and we qualify those methods based on what the
           component needs are.  And all of the details of the
           methods are in VIP 03, and it's in a three-inch
           binder that the staff has available if you need
                       Flaw evaluation considerations -- we
           tried to describe the procedures that are necessary,
           the analysis techniques, and in some cases we
           provided equations.  And I'll address some of that
           later.  But where we had equations that we could use
           and standardize, we've developed those.  In one
           case, we've even developed a computer code to deal
           with that.
                       What kind of assumptions do you make
           when you can't inspect something?  One of the issues
           on the shroud was you go inspect the circumference,
           but you can't get all of it inspected.  What do you
           assume about that region you can't inspect?  So we
           looked at statistical studies and the behavior of
           the materials and said, "What is the appropriate
           safe thing to assume, since we couldn't inspect it
           and factor that into the flaw evaluation?"
                       NDE uncertainty -- early days of the
           shroud the cracking was such that we were trying to
           do ultrasonic examinations.  We hadn't qualified the
           techniques, and we were even using transducers on a
           long pole to try to get additional information.  If
           you've got a pole that's, you know, 60-feet long,
           you can get a lot of flexibility.  So we accounted
           for that in the calculations when you do a flaw
                       Also, limitations on use.  You know,
           once you exceed a certain fluence level you just
           can't use some of the approaches that we've got.  In
           the crack growth rates that we describe, here's a
           reference to the documents for later use if you'd
           like to look at those.  But that's where the crack
           growth studies are documented.  And the staff has
           issued initial and final SEs on that.
                       An example of how you would use all of
           this -- if you don't do an inspection, and you've
           qualified the technique using VIP 03 and you found a
           flaw -- well, you know what the uncertainty of the
           technique is.  VIP 14 has the crack growth criteria,
           what you'd use for stainless in certain situations,
           whether you want to use the K dependency or a
           baseline, a base disposition curve.  
                       VIP 20 and VIP 80 -- VIP 20 is the
           distributed length ligament computer program that
           allows you to calculate the remaining ligament and
           what's acceptable.  Vertical cracking criteria,
           because the cracks are oriented different, behave
           different.  And here is the shroud inspection
           guidelines.  All of it goes together to do the flaw
                       And then, VIP 07 is the reinspection
           criteria.  And I think I mentioned earlier, but
           we've rolled 01, 63, and 07 all into VIP 76.  We now
           have one document that addresses all of it for the
           shroud.  But that's how you'd deal with a component
           like that.
                       We want inspection guidelines.  We want
           the information provided to the staff.  And this is
           what we've put in the guidelines.  EPRI compiles a
           summary and provides it to the NRC every six months. 
           So once we finish what we call basically an outage
           cycle, we accumulate all the inspection information,
           we provide it to all our members, and then we
           provide it to the staff.
                       We've got spreadsheets that reports
           that.  And the biggest thing for us, it lets us look
           at what's going on.  Is the program headed in the
           right direction?  Do we need to make changes?  Are
           we seeing things that are different?  And go from
           that perspective.
                       And I guess the thing is is it's a
           current term and a renewal term issue.  Some related
           issues in the program that I'll discuss now is the
           impact of hydrogen water chemistry, noble metal
           chemical additions, and VIP 03 repair issues, and
           some interaction with the code, and then license
                       VIP 62 -- I guess the way we'd look at
           it is if we're going to implement hydrogen water
           chemistry and noble metal, to turn off cracking, to
           slow down cracking, to help mitigate it, can we
           then, in return, get some credit for it in our
           inspection program?  Can we inspect less often?  And
           what this document does is go through and look at
           how you would justify a reduction in inspections
           based on the mitigation aspects of this program.
                       It is currently under staff review. 
           They've issued RAIs and an initial ASE, and there
           are still some open items that we're looking at. 
           How do you fully identify what an acceptable
           hydrogen water chemistry program is?  We need to
           define the parameters, so that the staff has
           assurance that what licensees are doing is fully
                       So we're trying to come up with an
           approach that addresses factors of improvement on
           crack growth, what the ECP or conductivity levels
           ought to be in that regard, before we can take
           credit for those.  And we've got that built into the
                       MEMBER LEITCH:  You talked about how
           effective is the hydrogen water chemistry deep in
           the vessel.  In other words, there is varying
           degrees of hydrogen water chemistry.  Some just
           suppress cracking high in the vessel, and when you
           put a full-blown program in you are able to suppress
           all the way down.  Does that enter into --
                       MR. DYLE:  That does enter into it.  And
           what is identified is is the function of the
           electro-chemical potential and the availability at a
           location.  So let's say you're monitoring in the
           recirc. loop but you want to claim credit that I'm
           protecting halfway up the shroud.  You've got to be
           able to show that in the injection rates you're
           using, that the water chemistry parameter is such
           that you know that you've got the ECP at the
           appropriate level at that point on the shroud, or
           you can't take credit for it.
                       MEMBER LEITCH:  Okay.
                       MR. DYLE:  So that's the way it's
           structured.  And there is the water chemistry
           guidelines.  You can monitor ECP.  We've got
           secondary parameters that you can use to look at how
           effective the program is.  And as you're probably
           well aware, if you're using noble metal you need
           much less hydrogen, so you can lower the hydrogen
           rate.  It helps with dose issues, but you still get
           more mitigation because it's more effective up in
           the core region.
                       VIP 03, here's just an overview of
           what's in it, and I've mentioned it several times,
           so I don't know if we need to spend a lot of time on
           it.  But it's a description of the inspection
                       UT, using what kind of transducers, how
           many megahertz, what size, what angles, whether it's
           a 45 RL, 60 RL, 45 sheer, all of that, a description
           of the vendor demonstrations that are performed on
           mockups.  And we've got a lot of mockups at the NDE
           Center, and I'll go ahead and make the invitation
           for Bob.  You're welcome any time you want to go see
           what the VIP has got at the NDE Center in the way of
           mockups and how this stuff is done.  We would more
           than welcome you to come look at them.
                       We established NDE uncertainty, and we
           -- in some cases we include the flaw evaluations as
           uncertainty.  It depends on the nature of it and the
           component.  We don't worry about the uncertainty for
           determining reinspection intervals currently.
                       This thing is updated annually.  We've
           agreed to the protocol, how we'll qualify things, so
           once a year all of the new techniques have been
           qualified, are published, and everyone who has a
           copy of that book gets an update on the new
           techniques that are available to revisions that are
                       And I believe, Gene, you have a copy of
           that also.
                       And then we tried to deal with repair. 
           What if I have to do a repair?  What if I find
           something that says it's a problem?  The flaw
           evaluation says I can't operate.  We have general
           design criteria that we developed for each
           component, and those are documented, and we talked
           about those this morning.  We're in the process.  
                       We're got SEs on most of those, and
           we're trying to finalize that.  And it looks at the
           structural requirements, the material
           considerations, how it was fabricated, and what
           you're going to do in the way of inspections.
                       If component degradation is anticipated,
           you can buy contingency repair.  And in the case of
           Plant Hatch, the way we looked at it with the shroud
           -- and this is just an example of how one would do
           this -- our management said, "We're going to have
           the repair on the shelf.  Before we do the
           inspection next outage, you're going to do the
           repair.  You're going to have the repair there in
           case we need it."  That was 85 percent of the cost.
                       So we said, "Why do all this detailed
           inspection?  We're better off eliminating the circ.
           weld cracking issue with the shroud, install the
           repair preemptively, and have less to worry about." 
           So that's an example where one could do that.
                       And there's also ways to get partial
           cycles.  You know, if you really can't go a full
           cycle, you can justify one cycle, so you can have
           time to install the repair.
                       This should go without saying, but we
           wanted to make sure of this.  For the safety-related
           internals, anything you do has got to be done to an
           Appendix B program.  We didn't want licensees to
           misinterpret the VIP program, that because we had
           these design criteria that's all you had to
           consider.  No.  That's just the criteria.  You still
           have to use your Appendix B program.  
                       If this happens to be a code component,
           like the shroud or attachments to the vessel, there
           are also code criteria that must be satisfied, and
           you'd document those on the appropriate code forms. 
           And that's the way we described that.
                       MR. BARTON:  Was there any question of
           our licensees if this needed to be an Appendix B
                       MR. DYLE:  No.  
                       MR. BARTON:  Okay.
                       MR. DYLE:  What our approach has been,
           and as I've learned through the years doing some of
           these owners programs, we wrote things
           simplistically, and sometimes an owner would say,
           "Well, since you didn't discuss this, does it mean I
           don't have to do this, or is there something
           different?"  So we just -- we'll get rid of any
           ambiguity if it's safety-related to Appendix B.
                       And then the other thing -- early on we
           were asked to develop inspection criteria for
           repairs.  We don't know how.  Let's say a jet pump
           riser brace cracks.  We don't know what that repair
           would look like if it's a mechanical repair, so we
           can't specify inspection criteria now. 
                       So what we did is put the onus on the
           owner that when he has a repair developed that the
           -- the developer of that repair must specify those
           inspections necessary to assure that the repair, in
           conjunction with that component, will perform their
           intended safety function.  So we've put that on
                       Interface with the code -- as I
           mentioned, in some cases, Section 11 has got
           requirements already.  Now we have the VIP
           guidelines, and we get a safety evaluation on it. 
           We understand that until a licensee has approval to
           use that document that he also has the code
           requirements imposed by 10 CFR 50.  So there is an
           overlap, and before an owner can simply use the VIP
           criteria in lieu of the code they must come to the
           staff, document such, and get it approved.  And
           that's so we don't violate what's in the law.
                       So we're working with that, and we're
           trying to develop a template that we could use for
           owners to send that information in.
                       Now, the punchline I guess is what we're
           here for.  The I&E guidelines were developed without
           real consideration to time.  At the point in time
           the shroud cracking got as bad as it did, and we did
           the safety assessment, one set of documents that
           were available for us to use were what they called
           the industry reports for plant-life extension or
           license renewal.  
                       And it was the documentation where the
           industry and the staff had worked through a myriad
           of issues related to license renewal, what were the
           open items, what were the agreed-upon items, how
           would you address aging management programs.
                       So the degree to -- that it was
           applicable to the VIP, we looked at that.  And we
           said if the owners are going to go for license
           renewal, if this is a reality, then we ought to
           construct this program so that we don't have to do
           this twice.  We didn't want to submit I&E documents,
           have them reviewed and approved and get SE, and then
           turn around and have to resubmit those when a plant
           approached license renewal.
                       So what we tried to do was when we
           looked at the failure mechanisms, and the cracking
           issues, we jus said, "What's going to happen?  When
           is it going to happen?" and deal with it.  Let's not
           put any time limits on it.  We're not trying to
           operate a shroud for another 20 years.  It's what
           keeps the shroud functional for the life of the
           plant, however long that is.
                       So that's the approach we wrote, and
           that's what -- that's what's built into these
                       We then approached the staff and talked
           to Gene and Chris Grimes and others and said, "We've
           got another rule out there that we've got to
           satisfy, how we do this."  And the staff worked up
           their internal mechanism, and I'm not going to go
           into it because I'll probably mess it up, but where
           the technical staff could review the documents and
           find the technical adequacy of them, and at the same
           time the license renewal staff could also review
           them and see how they applied to the license renewal
                       One thing that facilitated that is we
           had some folks go through and look at each one of
           these I&E documents and say -- and show in an
           appendix how different aspects of the document
           satisfied the provisions in Part 54.  So we
           submitted to the staff a technical document, and
           then an appendix that says, "Here's how we satisfy
           the rules and the requirements of Part 54.  Please
           review it."
                       In return, the staff gives us a
           technical SE, and then we also get an SE for license
           renewal.  And that's how we built the program to go
           forward into license renewal space.
                       The next thing is just to look at some
           of the program issues.
                       MEMBER FORD:  Excuse me.  Robin, can I
           ask a question?  We heard this morning from a
           representative of NEI about an NEI document 95-10.
                       MR. DYLE:  Right.
                       MEMBER FORD:  Is the VIP actively
           collaborating on that, so in the future we'll see
           the same sort of application from a technical point
           of view?  Or you're talking very specifically about
           technical arguments?
                       MR. DYLE:  Right.
                       MEMBER FORD:  Quantitative technical
           arguments.  Will that be part of the NEI approach?
                       MR. DYLE:  I guess the more correct
           answer, Peter, would be 95-10 was in front of the
           VIP, but where we brought this all together was in
           the GALL.  As the GALL was being developed and we
           started looking at these different components, and
           they listed the shroud, degradation is irradiation
           and IGSCC, we said, "We've got a program.  Here's
           the VIP program."
                       We described why it was adequate.  The
           staff reviewed that, and I do believe that the GALL
           will come out and say, for instance, for the shroud,
           BWRVIP 76 is acceptable, and the standard review
           plan draft that I've seen also makes reference to
           those kind of things.  So that's where we tie that.
                       95-10 doesn't yet reflect implementation
           of the VIP, as far as how the licensees ought to do
           that, and we're working on that within the VIP to
           try to get that specified.  We're doing these
           training classes.  We're talking to executives to
           try to develop additional training so that licensees
           do this the same way.  We've done self-assessments.
                       Matter of fact, the third one starts
           today or tomorrow at one of the plants where we go
           in and look and say, "All right.  You've had the VIP
           program.  How are you doing with it?  What problems
           have you encountered?"  And one of the things that
           comes out of that, we found a couple of places where
           they implemented the requirements right but with
           great effort because we did a not-so-good job of
           writing it.
                       So we're going to revise those documents
           to make the requirements more clear.  But as far as
           95-10 goes, it's not integrated yet, and we're
           trying to work that direction.
                       Our belief is is if we get the people
           implementing the VIP documents right now, they just
           continue.  The license renewal is immaterial.  They
           never know that they crossed the 40-year mark,
           because this is the right kind of program for the
           current term and the renewal term.  That's our hope
           and expectation.
                       Any other questions?
                       One of the things -- and this is where
           we need to interact with the staff some more.  When
           we talk about a VIP program, we consider that any
           control process that implements this thing properly,
           and make sure that all the requirements are met and
           the plant is safe and we've maintained the integrity
           of the components.
                       I personally put together three
           different programs, and they were done three
           different ways.  And when you go to a plant, some
           people may accomplish all of these tasks in
           procedures.  Some may do it, as some plants do, they
           have an ISI program, and then they augment their ISI
           program with these VIP criteria.  
                       Others have specifications that they
           use, so we've gotten to leave the technical
           requirements as they are, not be overly prescriptive
           on what the program should look like, but identify
           the things that had to be part of it.  And that's
           another thing that's currently being assessed with
           these self-assessments.
                       Now here's what the program gets at. 
           Make sure the inspections are done when they should
           be, that they use the right techniques, that they
           are evaluated properly, use the right people.  We
           want to make sure the folks can do the exams.  Use
           the correct methodology, and, where appropriate, the
           repairs meet the code or the VIP criteria.  So
           that's what has to be done to implement one of these
                       MEMBER LEITCH:  Do the licensees that
           are part of the VIP program that you had mentioned
           earlier, are they -- are they automatically
           compliant?  Can we assume that they're complying
           with the program?  Or is that a future decision?
                       MR. DYLE:  The way we have that set up,
           because as Gene mentioned I think on his first slide
           this is a voluntary initiative --
                       MEMBER LEITCH:  Are they volunteering? I
           guess is the question.
                       MR. DYLE:  Yes, they are.  And what the
           executives have said repeatedly, and we've even put
           it in writing, is that we will implement the VIP
           documents as written.  And I -- I'll pick one. 
           Let's say jet pump.  We provide the jet pump
           document, it's out, the owners review it.  They've
           bought into it.  We submit it to the staff.
                       We expect in a reasonable amount of time
           they start implementing that document.  And it may
           be that the document comes out in February and the
           outage is in April, so you can't build that in.  But
           as soon as you can, you start doing those
                       The staff may review those, and say,
           "Well, I don't particularly like that inspection. 
           I'd rather see this."  We, the VIP, will negotiate
           with them on that issue and try to determine the
           right thing.  But in the meantime, we, the owners,
           keep implementing it the way we said we would.
                       At such time that we have what we call a
           clean safety evaluation, where the VIP members and
           the staff are in agreement, then we will reproduce
           that document with the clean SE.  And at that point,
           the licensees are committed to implementing the
           document as specified in the NRC safety evaluation.
                       And if they're not going to, if for some
           reason they can't or they've got an alternate
           technique that they want to use, they have 45 days
           to notify the staff.  So that's the arrangement we
           have worked out at this point in time.
                       Gene, would you --
                       MR. CARPENTER:  At this time, every BWR
           licensee in the U.S. has committed to following the
           BWRVIP.  And we have only seen a few instances where
           they have taken minor exceptions to the VIP
           documents, and that has usually been a matter of
           timing as opposed to actually doing the inspections.
                       MEMBER LEITCH:  Okay.  Thank you.
                       MR. DYLE:  Any other questions?  Because
           this is kind of a break from the programmatic.  Now
           I'm going to look at some of the documents in a
           little more detail.  I don't know what you all have
           in the way of schedule for a break or what
           questions, so --
                       CHAIRMAN BONACA:  No, there is still
           time.  I think when you get to your slide number 39
           or 40 --
                       MR. DYLE:  Yes, sir.
                       CHAIRMAN BONACA:  -- I would appreciate
           it if you could do what I asked you before, which is
           provide us with a brief summary.  The next one
           actually is very clear -- a summary of the function
           that they provide, those components, for example,
           the shroud, the top guide, the lower core plate, top
           guide, etcetera.
                       The location where the cracks have been
           -- mostly been experienced, because I think it would
           be interesting for us to see the location of the
           welds on the shroud.  And the other thing that I
           would like to understand is I read, for example, in
           the BWRVIP for the top guide that all the top guide
           elements have already exceeded the amount of fluence
           for which you have become susceptible to cracking.
                       And so my question -- and, again, I am
           not a material expert, so -- is you have a certain
           series of intervals for inspection that you have
           set?  Would that change with age, given that
           susceptibility is high and you would expect with age
           the number of locations where you may have cracks to
           increase or the frequency to increase?  I just would
           like to have that kind of information as part of
           this presentation, if you could.  So --
                       MR. CARPENTER:  If I could go ahead and
           address that right off the bat.
                       CHAIRMAN BONACA:  Yes.
                       MR. CARPENTER:  Basically, what the
           staff has agreed to is that once you achieve a
           fluence level of 5E+20 neutrons per square centimeter
           -- it's a threshold limit -- you fall into a crack
           growth rate of 5E-5 inches per hour, which is about
           three-quarters of an inch per year crack growth
                       When you're below that threshold
           fluence, for certain geometries, for certain
           chemistries, you would have a lessened crack growth
           rate, perhaps as low as 1E-5 inches per hour.  So,
           basically, as the plants age, they will be
           inspecting more, not less.
                       CHAIRMAN BONACA:  Okay.  So the
           inspection intervals are changing with age.
                       MR. CARPENTER:  They will be increasing.
                       CHAIRMAN BONACA:  Or they may be
           increasing.  So there are provisions within the
           guidelines to increase the inspection, depending on
           certain measurements like fluence, and so on.
                       MR. DYLE:  And that's generally
           associated with an issue if you have a flawed
           component.  For example, the top guide, there's
           nothing that says once we reach a certain interval
           or a certain fluence level we'll start inspecting
           the top guide more frequently.  But we're doing the
           inspections at what we believe is a frequent enough
           interval to catch any problems before they create a
           serious issue.  And by looking at 36 BWRs and
           integrating that information, as soon as we find a
           problem with one we can go with the other.
                       For example, we have one BWR that has
           the top web cracking.  And we've been monitoring
           that location and looking at that, and it's got the
           highest fluence level.  So we use that sort of to
           set our inspection frequency.  Given what's happened
           at this plant, how often should we inspect to make
           sure we catch that?  So that's how we tried to build
           that into the program.
                       And I'll try to answer the questions you
           asked.  I'm not a systems guy.  So I'm not going to
           be able to go into great detail about all the things
           that these different components do and recall all
           the history off the top of my head, but --
                       CHAIRMAN BONACA:  No, no, no.  I just --
           you know, I think for the benefit of the whole
           committee, to understand where the cracks have
           occurred, what the experience is.  The other one
           that I would like to point out, that's -- at least I
           give you my train of thought there.  I spoke of the
           top guide, and there -- the possible failures of
           components which link the top guide to the shroud,
           and so on, have been postulated.
                       Only a few of those failure modes have
           been identified as safety-significant.  One of them
           I think some of the pins up there --
                       MR. DYLE:  Right.
                       CHAIRMAN BONACA:  -- the failure of
           those pins may cause the core to move, so that you
           have normal insertion.  For that particular failure
           mode, I would expect that you would have a
           commensurate provision for inspection maybe more
           frequent than others.  That's the kind of insights I
           would like to have on the program.
                       MR. DYLE:  Right.  And I've got --
                       CHAIRMAN BONACA:  To understand what the
           logic is behind that.
                       MR. DYLE:  I've got some details on the
           top guide, but a simple answer to that -- not only
           does the pin have to fail, but you also have to have
           a main steam line break, so that you have sufficient
           delta P to lift the top guide above the fuel so that
           it can tip over and then you can't insert the rods.
                       CHAIRMAN BONACA:  Okay.
                       MR. DYLE:  So one of the provisions is
           is that if you can look at the delta P that's
           developed during a main steam line break, and show
           that the top guide will never lift because of the
           weight and the attachment arrangement, then there's
           much less safety concern.  So those are the kind of
           considerations we built into that.
                       The LPCI injection -- this is limited to
           BWR 5s and 6s.  They have special couplings.  It's
           arranged somewhat like core spray.  To the best of
           my remembrance -- and, Bob, correct me if I'm wrong
           -- we haven't seen any problems with LPCI yet,
           because it's installed on the newer plants, and we
           wouldn't expect to have any problems.  But that is a
           means of implementing the low pressure coolant
           injection that we would need during certain accident
                       The core spray line, which we've talked
           about in the accident scenario, it provides the core
           spray on top of the fuel.  Some plants are more
           needful of having the spray dispersal, so that the
           nozzles are more significant about being maintained
           on the sparger itself that's inside the core, that
           it sprays down appropriately.
                       We had some discussions early on four
           years ago about trying to identify which plant was
           what, so that the plants that needed the spray
           distribution would inspect the nozzles and the
           others didn't.  We finally gave up on that and said
           that doesn't make any sense.  Everybody is going to
           inspect the nozzles.  So there is some conservatism
           we built in.  Instead of worrying about that
           evaluation, we put it in.
                       The core spray piping that comes from
           the nozzle delivers that to the sparger so it cools
           things.  The top guide, as we talked about, keeps
           the fuel from shifting.  It also lets the rods
           insert.  The core plate -- here it's the same thing. 
           We've not seen any problems at the core plate. 
           There's been limited inspections, but the
           inspections to date haven't been an issue.
                       And, again, this doesn't really show it
           well, but there are bolts around the periphery, and
           depending on the unit and the diameter the number of
           bolts change.  But as long as they're there, the
           core plate is not going to shift.  We don't worry
           about it lifting because -- and I don't believe I
           have a slide to this effect.  I may have a backup.
                       But when you look at the control rod
           drive housing there is a lip on it that's a half-
           inch above the top guide.  So that even if all the
           bolts were to fail and then you had a main steam
           line break, so that you developed the delta P to try
           to lift, it can't lift more than a half-inch because
           it engages --
                       MR. BARTON:  Are you talking about the
           core plate?
                       MR. DYLE:  Right.  The core plate.  It
           would engage the bottom of -- it would engage that
           lip on the drive housings.  So that's a --
                       CHAIRMAN BONACA:  The topical says that
           you could. 
                       MR. DYLE:  It will --
                       CHAIRMAN BONACA:  That's why I asked
           that question.
                       MR. DYLE:  Now, the core plate or the
           top guide?
                       MR. BARTON:  No.  I think the thing
           you're talking about talks about the top guide.
                       MR. DYLE:  Okay.  The top guide.
                       CHAIRMAN BONACA:  Okay.
                       MR. DYLE:  The top guide can lift in
           some scenarios.  The core plate is limited
           vertically to a half-inch.  So it won't disengage.
                       CHAIRMAN BONACA:  Correct.
                       MR. DYLE:  And when we were developing
           what was the right inspection criteria, we would
           have loved to have justified not trying to get down
           here, because it's a difficult access to do.  We
           looked at some old General Electric studies that
           they had done.  How far can this thing move?  What
           happens with rod insertions?  
                       And we could postulate that the nature
           of the way the system behaved, that even though you
           had a seismic event and the core plate was going
           back and forth, the rods would insert maybe
           sporadically but eventually would go all the way in.
                       Again, we said, let's not argue that. 
           Let's just go do the inspections.  And, again, you
           either look at the bolts or you install the wedges.
                       The shroud you're probably well aware
           of.  It ensures a coolable geometry.  It supports
           the fuel.  It holds the top guide and core plate in
           place.  We have had significant cracking in multiple
           cases.  It's been inspected extensively.
                       Several plants are on their third
           inspection using the improved criteria.  We're not
           seeing much growth, which is good.  And it's
           encouraging that this thing is not a rampant problem
           that we can't deal with.  So we seem to have found
                       MR. BARTON:  Do we understand why we're
           not seeing much growth?
                       MR. DYLE:  I probably ought to say no
           and defer to some other folks sitting around the
           table.  But the --
                       MR. BARTON:  That would be all right,
                       MR. DYLE:  The simplistic answer from
           our looks is is that as you go through thickness in
           the shroud, the K distribution changes, K dies off,
           the growth mechanism slows down from a stress
           standpoint.  And that's a very simplistic answer.
                       MR. CARTER:  And mitigation.
                       MR. DYLE:  And mitigation is working
                       MR. BARTON:  And what?
                       MR. CARTER:  And mitigation.  Hydrogen
           and noble --
                       MR. BARTON:  Hydrogen.  Okay.
                       MR. DYLE:  And that's -- anything else
           is far beyond my expertise, and I'll defer there.
                       CHAIRMAN BONACA:  He said hydrogen and
           noble metal, right?  Okay.
                       MR. CARTER:  Yes.  Either separately or
           in combination.
                       MEMBER SHACK:  What fraction, again, of
           plants - of BWRs are on hydrogen now?
                       MR. CARTER:  A very high percentage.
                       MR. CARPENTER:  Last week when we were
           at Argonne discussing this, basically the GE folks
           told us that it was somewhere in the neighborhood of
           about 33, 34 plants, which is almost all of them.
                       MR. DYLE:  Worldwide.
                       MR. CARPENTER:  BWRs.  Now, worldwide,
           that's a different story, and I can't begin to
                       MEMBER SHACK:  No.  We just meant the
                       MR. CARPENTER:  Yes.  Almost every one.
                       MR. DYLE:  And a lot of them are
           seriously looking at noble metal as the augmentation
           of the hydrogen to be more effective.
                       The jet pump assembly, I'll go through
           that in some detail.  But, again, that preserves the
           two-thirds core height.  It also lets the recirc.
           flow come in and distributes it below, so that's the
           function.  But its main safety function is either to
           maintain two-thirds core height, or some of the
           threes and fours, that's the route that LPCI has
           injected, should you need that in an accident
                       That's all I see on here that's listed
           as safety-related.  Any other specific questions
           before I go on?  I don't want to skip over things
           that you're interested in.
                       MEMBER LEITCH:  In the jet pumps, for
           example, have you considered fracturing -- that is,
           debris -- as a safety issue?  Or --
                       MR. DYLE:  We did.
                       MEMBER LEITCH:  -- do you just look at
           cracking, or do you think a jet pump is -- the
           fracture is --
                       MR. DYLE:  We looked at fatigue, and we
           looked at every weld location for the jet pump.  We
           looked at fatigue issues.  We looked at IGSCC.  We
           looked at what happens.  And when I get to that
           slide, we'll talk about how we classified the jet
           pump components high, medium, or low.  That looked
           at the consequences of the fracture.
                       We did look at loose parts, in general,
           in VIP 06.  And we addressed that, and we looked at
           large, medium, and small parts, and had GE do the
           systems analysis.  This is what happens if we have a
           part this big, what happens if we have a part
           smaller that clears the recirc. pump and comes back
           in, can it block the flow to the fuel channels, and
           things of that nature.  So that was considered in
           VIP 06.
                       I'm not sure that I answered your
           question, though.
                       MEMBER LEITCH:  Well, I mean, you talk
           about the safety implications of the jet pump, for
           example, as being two-thirds core coverage and to
           provide a LPCI injection pathway.  But is there also
           a safety function that's got to remain intact? 
           Because if you -- if it fractures --
                       MR. DYLE:  Right.
                       MEMBER LEITCH:  -- it could obstruct the
           core coolability, could it not?
                       MR. DYLE:  It would be hard for -- from
           my limited systems understanding, that if the jet
           pump assembly failed that it would block the core
           cooling.  It could fail in such a way, and this is
           one of the issues we dealt with with the jet pump
           riser pipe cracking that occurred in '96 or '97 --
           and I can show you that when I get to the jet pump.
                       But if it failed down low where the
           inlet flow comes in, and then in combination with a
           fatigue failure we lost a riser brace, you could
           disassemble the jet pump so then with a recirc LOCA
           you have a freeflow path.  And you can't maintain
           the two-thirds core height, so we addressed it from
           that perspective.  We tried to look at the impact of
           all of those possibilities.
                       MEMBER LEITCH:  Okay.
                       MR. DYLE:  This is probably the most
           familiar to you because we've talked here before
           about this.  And this shows the shroud, and this is
           the general numbering scheme.  Different plants --
           H1, H2, and H3 are generally the same.  Some plants
           have an H5 weld in here.  Some would call this H5
           and H6A.  So there's different numbering sequences
           or schemes that you might see.  But, generally, this
           is how the shroud is put together.
                       The bulk of the cracking we've seen is
           up in this area, in the high fluence region and up
           top.  When we did the original shroud safety
           assessment, another conservatism -- you can argue
           that should you fail here there are no safety
           consequences.  But we still are requiring
           inspections and treating it as if it is.
                       Similarly, for most of the plants, if
           you failed at H2, depending on how the top guide
           arrangement is, that could lift -- and unless it
           damaged the core spray piping, it is still not a
           safety-significant issue, in that you could shut the
           plant down and maintain coolable geometry.  But
           we're requiring inspections all the way through.
                       The H7 weld was the one of significant
           interest early on because it's a dissimilar metal
           weld with a backing ring.  This is generally the
           filled fit-up weld where things were put together.
                       We've seen some cracking here.  The
           cracking at H3 is actually in this ring.  There's a
           lot of structural margin there, and so far we
           haven't had too many issues concerning that.  The
           biggest thing is here when you start evaluating
           flaws in this arena, and as the fluence level goes
           up, and we restrict ourselves in the allowable
           margin, we have to start inspecting more frequently.
                       So until we have a good handle on what
           the crack growth rate is of irradiated stainless,
           we're going to have conservative inspection
           schedules based on that when we do flaw evaluations.
                       H8 and H9, we consider these as part of
           the shroud support.  They're handled in VIP 38, and
           that's simply because the shroud support ring was
           such a unique beast.  
                       These are code welds, so there's ASME
           criteria there.  What we've imposed is more
           restrictive than what the code has as far as the
           quality of the examination.  But one thing we did
           look at -- and I don't have details on it, but there
           is a lot of flaw tolerance in that structure.
                       We postulated that if you had these
           legs, each one of them cracked 50 percent
           throughwall, or 50 percent of the legs gone, how
           much margin do I need in this weld for structural
           liability?  And it's 10 percent of the ligament.  So
           there's a lot of structural margin in there, and the
           details of that are in VIP 38.
                       And then here it shows the jet pump and
           the core spray piping arrangement.
                       MEMBER LEITCH:  Isn't there an access
           patch in that --
                       MR. DYLE:  Right.
                       MEMBER LEITCH:  -- that has been
                       MR. DYLE:  You're correct.  There are
           what we call access hole covers.
                       MEMBER LEITCH:  Yes.  Yes, that's what
           I'm talking about.
                       MR. DYLE:  And in some plants there's
                       MEMBER LEITCH:  Yes.
                       MR. DYLE:  And there are varying
           designs.  As we went through the generations of the
           GE BWRs, they came up with a top -- what they called
           a top hat design that eliminated having to weld and
           leave a crevice in that Inconel 600 which eliminated
           some of the cracking.
                       But those have been inspected for years. 
           There has been cracking detected.  They've been
           removed and replaced with mechanical connections to
           replace that.  And that's one thing I didn't address
           in the flaw evaluation criteria.
                       Let's say you're going to do a shroud
           repair and that requires you to drill a hole in the
           shroud to attach some hardware.  What we require
           people do is to go back and look and say, okay, what
           about the leakage if you replaced your access hole
           cover?  We know you now don't have a leak-tight
                       So you have to account for that leakage,
           any leakage that might be created with the holes
           you'd make in the shroud to attach the hardware, or
           down here, and then all of that gets rolled up to
           look at what that does to your fuel clad temperature
           limits and make sure you've got sufficient cooling
           flow.  So we've required that as part of the
           program, too.
                       MEMBER LEITCH:  Okay.
                       MR. DYLE:  Here is the inspection
           history on the shroud, and I think this is some of
           the information that you were wanting.  We've got
           significant cracking at horizontal welds, some in
           the vertical welds, and this is generally in the
           older plants.  Less structural significance because
           of the nature of it.
                       There has been a couple of instances
           where the shroud repair hardware has been installed
           and reinspection has found some degradation in that,
           and we've addressed that.  We've required
           reinspections and built that into what we're doing.
                       And then there was one plant that had
           what we called a ring segment crack, and I guess --
           I'll put this back up.  In this forging here, as you
           go around the circumference there are some places
           where these plates were welded together.  And when I
           say a "ring segment weld," that's the weld that
           joins these different ring segments together.
                       MEMBER FORD:  Robin, could you go back
           to your previous slide, 40.  I'm trying to help
                       CHAIRMAN BONACA:  The other one.
                       MR. DYLE:  Okay.
                       MEMBER FORD:  What about the penetration
           welds at the bottom of the -- through the --
                       MR. DYLE:  Oh, the CRD welds?
                       MEMBER FORD:  Yes.  What would happen
           from a safety point of view if there was an
           excessive amount of cracking at those penetration
           welds?  We saw some with a lot of hydrogen water
           chemistry -- be a devil's advocate here -- a lot of
           hydrogen water chemistry conditions, ECP,
           susceptible 182 weld.  What would happen from a
           safety point of view if you had a lot of cracking
           down on those --
                       MR. DYLE:  From the global point of
           view, even if you had significant cracking you can
           insert the rods, and with a combination of the SLC
           and other systems you can shut the reactor down,
           maintain it at a coolable situation, and it's not a
           safety issue from that perspective.  Do we want
           that?  Absolutely not.
                       But the bottom head is flaw tolerant,
           the low alloy steel is not very susceptible to the
           cracking.  The studies that we've done looking at
           the vessel shows that if I have stress corrosion
           cracking -- and I'm going to stress that these are
           studies that more knowledgeable people than I have
           done -- that the cracking, once it reaches a low
           allow steel it just dies out.  There is not the
           driving mechanism for it.
                       We have had some instances in the
           industry where down in the bottom head we've had
           some leaking CRDs that we've been able to repair by
           using the rolled repair, where you go in and roll
           and expand the joint.  And generally what happens is
           you have a leak up in the vessel, and it runs
           outside of the CRD, and you see the leak.  And by
           rolling the CRD housing back into the vessel wall
           you turn that off.
                       We also developed, as part of the repair
           program, a welded repair for that activity where you
           go in and do the same rolling situation to stop the
           leak, but then do machining and a reweld, so that
           you would structurally replace that weld that's on
           the ID.  And we've been able to get that approved
           through ASME as a code case, so that's available for
           use, too.
                       You can eject the rods.  We've looked at
           the possibility of failing and ejecting, the
           likelihood of growing 360 degrees and losing that. 
           It's not going to happen.  It's going to be
           restrained above the core plate, as long as you
           don't disconnect the connection.  Because if it
           tried to drop out, it would catch on the top guide. 
           It can only drop a half an inch as long as this
           whole assembly stays together.
                       So there's a lot of reasons that we
           don't believe that's a significant issue, but we
           still do inspections to address that.  
                       And with hydrogen water chemistry, we've
           shown that we can get adequate protection down in
           the bottom head.
                       MEMBER FORD:  Has there been a lot of
                       MR. DYLE:  There's been very limited
           inspections.  That's one of the areas where we're
           struggling and we're trying to get people, you know,
           as they have access, go do inspections, find out
           what's going on.  Those few plants that have done it
           have not found problems, other than the limited
           leakage at Nine Mile 1.
                       MR. CARPENTER:  But the staff is
           encouraging expanded inspections in those areas.
                       MEMBER LEITCH:  There's a lot of other
           stuff down there besides CRDs.  Have you taken a
           look at, like, instrument connections, core plate
           Delta P, lower head connections?
                       MR. DYLE:  We did look at that from --
           and the SLC -- as you're probably aware, the SLC and
           the core plate delta P are an integral unit.
                       MEMBER LEITCH:  Right.
                       MR. DYLE:  The studies we've looked at
           shows that if the SLC line was to crack and fail any
           place, we could still get the borated solution in
           the bottom head and shut the reactor down.  It'll
           perform its function even if it cracks throughwall.
                       The only way we could envision ever
           having a problem with the line was if you had a
           seismic event that might collapse the line, and
           we've looked at that.  In fact, that was a question
           that came out of this group in '95 that we answered,
           you know, to go look at that and show that we could
           get the adequate mixing in the bottom head.
                       The core plate delta P, if that line
           fails you have an instant recognition of it by the
           operator because they've lost the core plate delta
           P, which says what happened, and they can take, you
           know, action to try to figure out what has occurred
                       We've got the LPRMs, and those
           insertions there included in the -- what we call the
           bottom head, or the lower plenum I&E document is the
           correct name.  So we've addressed all of those
           penetrations and locations in that document and
           prescribed --
                       MEMBER LEITCH:  SRMs and IRMs as well?
                       MR. DYLE:  Correct.  They're in there,
           the dry tube, and look at all the pressure boundary
                       Do you remember the number?  I don't
           remember the number on that one.
                       MR. CARPENTER:  48.
                       MR. DYLE:  48.  Okay.
                       MR. CARPENTER:  I'm sorry.  47.
                       MR. DYLE:  47?
                       MR. CARPENTER:  47.
                       MR. DYLE:  47.  There's the shroud
                       This is a busy slide, and I -- I guess I
           wasn't going to put a whole lot of time on this, but
           it gives you an idea.  When a shroud cracking
           occurred, what we did was go through and look at all
           of the shrouds and break them up based on what their
           materials were, how long they had been operating,
           and what their initial five-year -- their first five
           years of operation what the conductivity was.
                       And we classified the plants as A, B,
           and C, and the staff agreed to that.  And this went
           from least likely to crack to most likely to crack. 
           Eventually, every plant will go from A to B.  We
           hope using mitigated technologies that no more Bs
           move to Cs, and that means it doesn't see cracking.
                       The next slide says, "Here's how you
           decide for a category B shroud to do inspections,"
           and you're probably better off looking at your
           handout.  But you go do the inspections as specified
           for H3 and H4, you've got to do one of those, H5,
           and H7.  Is the cracking less than 10 percent of the
           inspected length?
                       And if the answer is yes, then we have
           to do -- you have to do more inspections.  If the --
           you know, you've got to make sure you've got enough
           coverage, and then you can decide what to do.  If
           the question -- if the answer is no, you've got to
           make it a category C and expand scope and look at
           more welds.  So we have some conservative criteria
           for those plants.
                       And then, this next chart is similar. 
           It says, "Here is how you deal with the category C
           shroud."  And one of the first things is, and it
           goes back to the discussion we had earlier about
           uninspected length.  Is the inspected length of the
           weld greater than 50 percent of the length of the
           weld?  In other words, did I get more than 50
           percent coverage?
                       And if the answer is no, I've got to go
           do some other things to make sure that what I'm
           doing is acceptable.  If the answer is yes, then we
           had a treatment of that.  So we're trying to require
           minimum coverage, and if you didn't get that you had
           to do a lot more.
                       Similarly, there is criteria for doing
           the vertical weld inspections.  You know, how much
           cracking do you find?  And make decisions based on
           that.  And, you know, I've just showed you three
           slides that summarize what's in 40 pages of a
           document.  So it's -- I'm not sure that I gave it
           fair treatment, but that's how we set this program
                       And like I said, we've done a lot of
           shroud inspections and are staying on top of that. 
           There's more inspection requirements for the
           vertical welds, which we've changed and added more
           to.  And, again, is the vertical weld free of crack
           indentations?  Yes.  Then we have an inspection
           period.  No.  And then you work yourself through how
           much of it is, how much do you inspect, and what's
           the appropriate evaluations to perform.
                       All of this -- I should say, when we
           talked about the flaw evaluations, we applied code
           margins, so this is not -- we've got code margins in
           there on upset loads and things of that.  So when we
           say yes or no, it's safe, that includes the margins
           that ASME would put on its normal components.
                       And then we set the reinspection
           intervals based on the amount of cracking found also
           using the stress that would be applied at that weld. 
           And then we also accounted for fluence to the degree
           that low fluence plants can use limit load only.  As
           fluence increases, we require people to use LEFM to
           evaluate their flaw carrying capability.  And that's
           indicated in the notes at the bottom of that page.
                       Bob, speak up if I leave something out
           on this.  Again, this is a summary of the flaw
           evaluation for the shroud.  It depends on the
           fluence.  At the end of the evaluation period -- and
           what we mean by that is is if I find a flaw today, I
           don't look at the fluence that that component is
           going to experience today.  
                       I look at the fluence for the period of
           time I expect to operate.  So if I want to operate
           six years, I have to estimate out what the fluence
           will be then and then put that number in and do the
           calculation on the flaw tolerance.
                       Use limit load for ductile behavior,
           LEFM and elastic-plastic for the less ductile
           behavior.  And this is the code that I talked about,
           the distributed ligament length code.  It's been
           updated a couple of times.  You can also use this
           for LPCI, for core spray in the nature of the code.
                       And the last item on the shroud, here is
           the status of the review.  And I -- I think this is
           accurate.  And, again, VIP 01 was the initial, 07
           was the reinspection, 63 was the vertical welds, and
           we've rolled all of those into VIP 76, submitted
           that, and it has a license renewal appendix.  So
           that's one, once it's reviewed and approved, that'll
           include the license renewal aspects.
                       Any questions on the shroud?
                       CHAIRMAN BONACA:  I have a question
           regarding timing.  How much time do you think you
           still need?  Is this part of the rest of the
           presentation?  The agenda shows a full presentation
           later on provided by you of half an hour each.
                       MR. CARPENTER:  Yes, sir.  And I will
           not need a half hour each.  So --
                       CHAIRMAN BONACA:  Okay.  So, because
           this is part of that.
                       MR. CARPENTER:  Right.
                       CHAIRMAN BONACA:  So maybe we should
           take a break now, and then continue the presentation
                       MR. DYLE:  If you'd like.  I have three
           more components to discuss like I did the shroud,
           so --
                       CHAIRMAN BONACA:  So you need at least
           half an hour to go through it.
                       MR. DYLE:  At least a half an hour.  But
           then I believe that's -- what I tried to do was give
           a description of the program, so that when the staff
           talked about what they've done with it it makes
                       CHAIRMAN BONACA:  So why don't we take a
           break now and meet again at 10 of 3:00.
                       MR. DYLE:  Okay.
                       CHAIRMAN BONACA:  Okay?  Good.
                                   (Whereupon, the proceedings in the
                       foregoing matter went off the record at
                       2:35 p.m. and went back on the record at
                       2:51 p.m.)
                       CHAIRMAN BONACA:  We are resuming the
           meeting now, and continuing with the presentation.
                       MR. DYLE:  Okay.  The next component --
           we're on page 50 of the handout -- is the jet pump
           assembly, and this is -- we've had some questions on
           this.  What we've got -- and this is a sketch that
           comes out of VIP 41, which is the document.  The
           numbers that you see next to each one of these
           locations are individual numbers and paragraphs that
           we have a discussion in the VIP document, and the
           appropriate need to inspect or not inspect,
           depending on the materials.
                       We have these different -- there's
           different configurations on how these rings are
           attached to the shroud support.  It sometimes seems
           that our designer was trying to find a unique
           version for everything they built, because we have
           quite a few configurations here.
                       The jet pump sensing lines which measure
           the jet pump pressures and performance, we take
           those lines out.  That's one of the ways we do
           surveillance, by seeing if we have the jet pump
           operating properly.
                       You have the jet pump inlet that comes
           in here, goes up, goes through what we call the
           ram's head.  You have the jet pump hold-down beam. 
           We've had failures there.  We've had cracking,
           different types.  If you look at VIP 41, there's a
           discussion of those.
                       And then, we accelerate the fluid
           through, and then we have the nozzle here that
           allows the fluid from the annulus to be sucked in
           and then taken to the bottom head.  So that's how
           the jet pump works, and we've got a detailed
           discussion of that in the document.
                       As you ask about what's the inspection
           history, we've had indications on the hold-down
           beams.  We had at least one plant where the hold-
           down beam failed, and that ram's head that I was
           talking about came off, and then they were able to
           detect that because when they look at the jet pump
           sensing lines it shows no flow through there.  They
           understand that there's a problem.  They bring the
           unit down and then do the appropriate repairs.
                       Riser brace welds -- we've had some
           cracking there.  Riser pipe welds -- we had
           discussed that earlier, and that is actually where
           this riser pipe comes into the nozzle and is welded. 
           We had cracking down in that region that we've
           inspected and found and dealt with.
                       Riser brace-to-yolk welds, wear at the
           set screws, and one of the things we do, you can
           look at the set screws and wedges where these
           brackets attach.  And if you see evidence of wear on
           the wedges, like the jet pump has been moving, then
           we understand that there may be a fatigue issue that
           you can expand scope and do inspections from that
                       For the jet pump, all welds were ranked
           based on safety significance.  And hindsight being
           what it is, we might have done away with medium and
           low, because if you look at our document -- and I've
           got some discussion of that -- but in the VIP 41,
           the medium and low get the same inspection criteria,
           and that was to be conservative.
                       Although we could have argued less
           inspections for the low priorities, we did something
           different.  But the way we classified these were
           high was any location that if it cracked it could
           create an immediate failure, and the jet pump would
           come apart.  That had to be inspected quickly.  We
           wanted those, and we set the baseline appropriately.
                       Medium, it could crack and eventually
           lead to a jet pump disassembly, but it was a long
           period of time.  And then, low, there was really no
           significance to the cracking, but there was some
           reasons to go look.
                       MEMBER LEITCH:  In the document, it says
           that low may be -- excuse me -- low right now is
           treated as medium.
                       MR. DYLE:  Right.
                       MEMBER LEITCH:  But in the future, it
           may be reevaluated.
                       MR. DYLE:  Right.
                       MEMBER LEITCH:  Could you say what would
           be the criteria for that reevaluation?
                       MR. DYLE:  Well, one of the criteria
           would be is if we go through and do -- the fleet has
           done a series of inspections, and over the next 10
           or 12 years we find no evidence of indications in it
           or the mediums, and we better understand how the
           materials behave, we may change those inspections to
           a sampling.  We may eliminate some of them,
           depending on the materials.
                       By the same token, if we start to see
           more indications than we expected, we may change and
           make it more frequent.
                       MEMBER LEITCH:  That's one of the
           questions I had.  The inspection frequency seems to
           be based upon safety significance.
                       MR. DYLE:  Right.
                       MEMBER LEITCH:  Rather than operating
           history.  Is operating history factored in?  In
           other words, if you have something that's low safety
           significance, but there's been a significant number
           of problems with it, does it ever get to be high?
                       MR. DYLE:  It may not be high from a
           safety perspective, but we would inspect it more
                       MEMBER LEITCH:  I mean, from an
           inspection frequency.
                       MR. DYLE:  From an inspection
           standpoint, we would upgrade that and do the
           inspections more frequently if that was warranted,
           because we want the plants to operate.  We want the
           plants safe.  And if we did that, then we bring the
           document back to the staff for their review and
           approval.  So --
                       MEMBER LEITCH:  So the categories high,
           medium, and low are really safety significance.
                       MR. DYLE:  Safety significance.
                       MEMBER LEITCH:  But the operating -- but
           the inspection frequency may be biased depending
           upon operating history.
                       MR. DYLE:  Right.  Operating history and
           safety significance combined.  And what we think
           we've done -- and the staff has agreed with us -- is
           that by accelerating these high locations, they are
           precursors, if you will, they're more serious if
           they should crack, and then the same materials, and
           they're in the same general environment in the
           annulus, so they should give us some indication how
           the rest of the assembly would perform.
                       MEMBER LEITCH:  Yes.  Right.
                       MR. DYLE:  So we're kind of building on
           the totality of the program.  And part of what we
           argued to ourselves was is I've got -- you know,
           I've got 10 of these jet pumps, 20 pipes, 35 plants. 
           Over six years I'm going to have a lot of inspection
           data to let me evaluate what's going on.
                       MEMBER LEITCH:  Right.
                       MR. DYLE:  And we believe that's
                       MEMBER LEITCH:  Okay.
                       MR. DYLE:  And this is -- to your
           question, this is the inspection flow chart on how
           you would do this.  If the component is high safety
           significance, inspect 100 percent of the population
           in the next inspection cycle, which is defined as
           six years.  So for a plant that's on two-year
           cycles, over three outages I'll inspect all of
           those, with at least half of them to be inspected
           the first outage that you implement this document.
                       So right up front we're wanting to get
           information on those quickly and try to understand
           what's going on.  If you have flaws, you expand
           scope and do everything in that outage.  If you have
           no flaws, then you use the reinspection frequency
           that we specified.
                       For the medium and low, you come down
           this path, and here's the inspection scope that's
           set up.  Because they are less significant, we allow
           more time.  But, then again, depending on what
           happens here, it may affect what we do with these
           other components.  So we would move back and forth.
                       And then here's the reinspection
           frequency that's contained for the jet pump.  We
           require more inspections on high inspections, so you
           inspect 50 percent of the population the next
           inspection cycle.  So the first inspection cycle you
           do the whole population.  The next six years you do
           at least half of them from a sample perspective.
                       And you do 25 percent of the medium and
           lows, and that's consistent with the sampling
           process that the code uses.
                       MEMBER LEITCH:  These thermal sleeve
           welds that are inaccessible on the -- associated
           with the jet pumps.  It seems as though there's an
           open issue there.  Can you comment on what work is
           being done to resolve that?  Is there no inspection
           technique available for those --
                       MR. DYLE:  There is not yet one proven,
           but that's being worked on.  And you're talking
           about where this riser attaches down in the nozzle?
                       MEMBER LEITCH:  Right.  Yes.
                       MR. DYLE:  We're doing the inspections
           of all of those that we can see and get access to. 
           And that gives us some indication of how well that's
           performing.  For several years, some of the plants
           did what we call the -- the acronym we used was
           RENSA weld examinations, where we actually looked at
           where the thermal sleeve was attached to the nozzle
           from the OD of the nozzle.
                       And what you did was ultrasonically look
           through.  But what that really characterizes is
           whether you have a bond there, or whether you have a
           crack that might be propagating out of that weld
           into the safe end of the nozzle.  But it wouldn't
           look at anything below there because you couldn't
           get the sound in and back out from an inspection
                       And those examinations have resulted in
           no problems to date.  That's one of those that was
           never required by the code or anything else, but the
           owners did that.  And I know we've got a lot of
           inspection data for Hatch that we looked at for
           years doing that.  But, again, that doesn't get at
           the thermal sleeve itself.  It looks at the weld and
           then the nozzle, and that's the best effort that you
           can do right now.
                       MEMBER LEITCH:  Yes.  Okay.  Thanks.
                       MEMBER FORD:  Robin, could I follow up
           on that particular point that Graham brought up? 
           How should -- we had a similar question this morning
           about containment, corrosion -- inaccessible parts
           of the containment.  What you're saying is if you
           don't see a crack in the areas that you can inspect,
           then there's a likelihood that you won't see -- that
           there are not cracks in an area that you cannot see. 
           How sound a reasoning is that?
                       MR. DYLE:  Well, to some degree, it's
           the best we can do with the technology we have.  So
           we're requiring inspections of everything we can get
           at and try to reach conclusions, because the
           materials are similar and the environment is
                       MEMBER FORD:  But the stress may not be.
                       MR. DYLE:  But the stress may not be. 
           The other thing is -- and this is where the
           monitoring comes into play again -- we're requiring
           this jet pump monitoring of performance.  And if
           that weld were to crack to the degree that it would
           leak and degrade the flow, or affect the performance
           or completely go throughwall, then this jet pump no
           longer operates.  You do your daily surveillance and
           it says, "I don't have flow in that jet pump.  I've
           got a problem."
                       MEMBER FORD:  So your risk assessment,
           though, for any part, you would go through that kind
           of risk -- the impact of that was assumptions you
           are making.
                       MR. DYLE:  Yes.  The document where we
           looked at that is VIP 28.  When we looked at -- when
           we looked at the impact of cracking at the weld just
           outside of that one that's -- and what we found
           there is that you have IGSCC might start.  And then
           later fatigue takes over and the flaw would grow.  
                       And the window in which you have the
           opportunity that you'd have insufficient ligament to
           carry the load should I have an accident, which it
           really creates the problem, versus the thing
           separating and then I'm able to detect that the jet
           pump is not operating, was a matter of a few days. 
           And when you looked at the risk assessment from that
           perspective, it was a very low number.  
                       I don't remember what the number was,
           but that was -- we did that in '97, '98, somewhere
           in that timeframe.  And the staff has reviewed that
           and approved that as a JCO for everybody to continue
           to operate until we started doing more of these
           inspections.  So that's been considered from a risk
                       Flaw evaluation is just simply we use
           the limit load techniques, and the DLL code that I
           discussed earlier could be used for this component
           as well.  And the current status is we've gotten a
           safety evaluation from the staff in February of this
           year, and there are some guidelines that need to be
           revised based on the comments they've made.  And
           we've discussed those.  We understand what they
           want, and we're in the process of doing an update to
           incorporate that information.
                       And I guess this is an example of --
           someone asked earlier, and I don't remember who --
           about how we implement a document.  We would expect
           the owners to continue to implement VIP 41 as we
           wrote it until such time as we update the document
           to reflect the safety evaluation, and then that's
           how they would implement it.  So that's the
           agreement we have.
                       The next item is the top guide.  There
           is -- just looking down on it, and here's the side
           view of it, so you can see that configuration. 
           That's typical for the 2s through the 5s.  The BWR 6
           has got a slightly different configuration.
                       I believe, Dr. Bonaca, you were talking
           about these pins here.  These are aligner pins that
           you set the top guide down on.  It aligns it and
           holds it in place, and we've evaluated what's the
           consequences of failures of these, can the thing
           move or not, and what's the appropriate inspections. 
           And there are different configurations of those.
                       Another one is the hold-down assembly. 
           You have to study -- every time I look at this, I
           have to stop and look at it again to try to figure
           out what all we've got captured here.  But this is
           the BWR 2 through 4 hold-down device.  This is the
           5.  This is the 6.  So there are some differences. 
           And, again, you can look at the failure of this
           component and say, "If all of these failed, will the
           top guide lift?  Can it move?  Can it not?"  And
           that lets you set whether you need to inspect this
           top guide hold-down device or not.
                       Rim welds on the top guide -- and,
           again, this is just to give you an idea of the
           technical detail that's in these documents.  I don't
           know to what degree you've had the opportunity to
           review them.  But we've got -- here's the
           fabrication weld on the top plate here, and then
           you've got the rim weld that would be in this
                       And different ways to hold the core
           plate down -- the plate down on this rim and how it
           sits on the bottom plate, and then this is set down
           at the H5 weld region.  Excuse me, this is up at the
           H2 and H3.
                       I mentioned that the BWR 6 has a
           slightly different configuration, and this you can
           see -- we've got it shown here, so you can see how
           the H1 and H2 shroud welds are in relation to that. 
           And it's a slightly different configuration, and
           it's shorter.
                       The inspection history and what we've
           seen to date, there has been a lot of VT-1s and VT-
           3s.  And using VIP 26, there were previous GE SILs
           that were used, and we did inspections in relation
           to that.  
                       And I guess this is a good place to make
           the comment, one of the things the VIP program did
           is we went back and revisited all of the individual
           SILs for a given component.  If they were safety-
           related, we made sure we incorporated either those
           requirements or new requirements into the VIP
           document and replaced the safety-related SILs.
                       For those SILs that were not safety-
           related, but were suggestions that owners might
           consider, we didn't try to address that, and we left
           it to the owners to choose what of those they wanted
           to use.  So that's what we've done.
                       As I mentioned earlier, Oyster Creek has
           got indications in the top guide.  We have removed
           those samples.  We've looked at them.  We've looked
           to see if they were weld repairs.  
                       We've also taken those samples and put
           them in what we call the CIR, which is a program
           looking at cracking and irradiated stainless, and
           we're assessing the degree -- it appears that these
           flaws would be IASCC.  We haven't determined that
           yet, but that's one of the things we're going to
           look at.
                       And then, based on the results of that
           metallurgical review, see if there's anything else
           we need to do.  But to date, that's the only plant
           that's had that problem.
                       There's rim weld cracking and it
           oversees non-GE BWR, and I think that was in non-
           stabilized 347, if I remember right.  That was --
                       MEMBER SHACK:  There's no such
                       MR. DYLE:  That was the problem.
                       It was supposed to be 347, and the
           metallurgical results indicated it may not have
           been.  But we have limited access to some of that
           information, so I -- you know, I wouldn't take that
           to the bank.  That's --
                       MEMBER SHACK:  Now, the Swedes replaced
           the top guide, right?  But they did that without any
                       MR. DYLE:  There were some that replaced
           all that -- they have the removable internals. 
           They're not welded in place.  They were bolted, so
           they could remove them.  So it's a different design.
                       MEMBER LEITCH:  Talking about SILs there
           just a minute, there is a statement in VIP 41
           concerning the jet pumps on Roman numeral XI, the
           executive summary.  It says that the -- basically,
           that if you use this, you can -- that the VIP --
           these guidelines can be followed in place of prior
           GE SILs related to safety to assure the essential
           safety functions of the jet pump.
                       MR. DYLE:  Correct.
                       MEMBER LEITCH:  It seems to me that's
           too sweeping a statement.  There's some SILs that
           tell you how to read and interpret jet pump
           instrumentation, and recommend actions to do this. 
           This would seem to say "forget all that."
                       MR. DYLE:  No.  If that's what it says
           to you, then we need to take a note to look at that,
           because what we mean by that is any inspection of
           the assembly itself we've replaced those
           inspections.  We've either incorporated them into
           VIP 41 or replaced them with what we think is newer
           and more conservative or more appropriate
                       The monitoring of the jet pump
           performance is still required.
                       MEMBER LEITCH:  Okay.
                       MR. DYLE:  And we would --
                       MEMBER LEITCH:  You have another note
           back on page 3-2 that says it more clearly, but I
           just think this statement here taken at face value
           is a little too broad.
                       MR. DYLE:  And that's in the executive
                       MEMBER LEITCH:  Executive summary, Roman
           numeral XI, about the middle of the page.
                       MR. DYLE:  Okay.  Thank you.
                       Bob, we need to -- we'll just take a
           note to make that more clean.
                       MEMBER LEITCH:  Yes.  Thank you.
                       MR. DYLE:  I appreciate that.  Thank
                       And, you know, we think we did a real
           good job with these things, but obviously we're
           going to have things like that where we could have
           been more clear, and somebody reviewing it anew and
           looking at it from a different perspective.  We've
           had some of that with the staff interactions.
                       What did you mean?  We thought we knew
           what we meant, and they said, "What did you mean?" 
                       This is just an example of the table,
           and I -- we've gone a long time, and I don't want to
           bore you to tears, but here are some of the examples
           where from a table you have the location identified,
           a description of it, what's applicability, which
           plant.  For example, the grid beam, location 1 is
           applicable to 2 through 5s.  Whereas, the aligner
           pins at locations 2 and 3, if you go back to the
           figure in the document, would only apply to the BWR
                       And then there's a discussion of the
           results of the structure, what happens if it fails,
           and then based on that what inspection should be
           done.  And there are several pages of this that
           would allow you to go through and make the decisions
           for your plant, for your configuration, for your
           operating condition, what inspections are
                       MEMBER SHACK:  When I was looking
           through this, and I look at the staff RAIs on this
           -- you know, there's one, for example, that comments
           that VT-1 really can't see stress corrosion cracks
           very well, and you would have to look at an enhanced
           VT-1.  And I didn't see a response to that.
                       Now, is, in fact, in -- do you use
           enhanced VT-1 here?  Or --
                       MR. DYLE:  What we said we would do --
           this was several years ago, and it's a general
           policy -- we've had this discussion with the staff
           that we need to -- there's been discussions like
           this that went on over time and were pointed out.
                       The approach that we were going to use
           is any place that we were looking for tight IGSCC
           type flaws we would use EVT-1, because we understood
           that was the right mechanism to use.  It was that
           logic that said we'll do away with the MVT or the
           CSVT-1.  So if we're not looking for tight flaws, if
           we're looking for like a fatigue failure that might
           be more readily visible with the VT-1, we could use
           that.  But for tight IGSCC type flaws we were going
           to require that to be updated for everything.
                       MEMBER SHACK:  I saw that statement, but
           then it wasn't clear whether we considered this an
           EVT-1 or a VT-1.
                       MR. DYLE:  Well, we will --
                       MEMBER SHACK:  Everywhere it says VT-1
                       MR. DYLE:  Every place -- our commitment
           was every place that we're looking for IGSCC flaws
           we're going to bring it up to EVT-1.
                       MEMBER SHACK:  Even if the document
           doesn't say that.
                       MR. DYLE:  Because we've got to go back
           and revise these documents.  The process for this
           will be once the staff has issued a safety
           evaluation that we agree with, then we will revise
           the document to incorporate all of those comments
           and other enhancements that we've seen that have
           been necessary, like the comment that was just made.
                       We will then provide that to the staff
           and let them see that we've incorporated those
           changes, and make sure we've done what we said we
           would do and let them buy into that.  And then we
           would issue this document again with an A on it, and
           it would mean it's an approved topical, and it would
           include the safety evaluations and all of the
                       So that's the process, and that's the
           next step in the process with the staff, that over
           the next year or so -- Bob?
                       MR. CARTER:  Yes.  That one is hard to
           trace.  And we addressed that particular issue in
           response to --
                       CHAIRMAN BONACA:  Would you use the
           microphone, please?
                       MR. CARTER:  Oh, certainly.  We
           addressed that particular response or that
           particular issue in the response to the core spray
           I&E document, where we had originally some -- maybe
           not as stringent visual techniques.  And we -- in
           the response back to the staff on that, we committed
           to perform EVT-1 for detection of IGSCC.
                       MEMBER SHACK:  Yes.  I guess we got --
           it was -- you had the general statement in the
           letter that Robin just made, that when you were
           looking for tight, you know, SCC cracks you were
           going to use EVT-1.  Some of the inspection
           guidelines actually call out EVT-1, and some of them
           still call VT-1 in situations where it's clear to me
           you're looking to address SCC.  And all you're
           really saying is that those just haven't been --
                       MR. DYLE:  Yes, that's a timing issue. 
           We made that commitment in response to core spray
           after this document was already published.  So we
           wouldn't have revised the document just to fix that. 
           That's just one of the changes we understand we have
           to make and bring forward in the final approved
                       There's three more pages of the top
           guide inspections, and unless you have specific
           questions I'll go ahead, for time's sake, and skip
           over that.
                       MEMBER SHACK:  Now that you've put this
           in the public domain, can we remove the non-
           proprietary from the non-proprietary version of it?
                       MR. DYLE:  Now that I've put what?  That
           portion of the table?
                       MEMBER SHACK:  This table is
                       MR. DYLE:  Well, it's available for
           public today, that portion of it.  We have non-
           proprietary versions of all these documents
           available, because we had to do that --
                       MEMBER SHACK:  Right.  This isn't
           included in the non-proprietary version.
                       MR. DYLE:  Yes.  And that's something
           that we constantly have to discuss and consider. 
           It's in here.  It's in the public.  We're not going
           to make the whole document non-proprietary, no,
           because -- well, I'll leave it at that.  I'll let
           the lawyers discuss it.
                       Flaw evaluation criteria for the top
           guide -- we've got considerations for the grid beams
           where you use LEFM to look at that, and there's
           equations given in the appendix.  This is one of
           those where it was a unique component.  We developed
           the equations and gave them to the licensees.  The
           staff has reviewed them.
                       For other locations along the rim, or
           other things, you would use different methods.  And
           we would use the stress analysis to determine the
           acceptability of it.
                       And here is the status of the review.  I
           guess, Bill, to your comment, if you look at the SE
           data, it was in September of '99.  So that was an
           earlier document that had been submitted.
                       We're going to have an accelerated
           program this year to try to get these things brought
           up to date.
                       That's all I was going to discuss on the
           internals.  The last item that I have been asked to
           discuss was what we're doing with the IGSCC and
           piping, just because the VIP had done this, and
           that's what the next several slides are about.
                       We labeled it BWRVIP 75.  That's where
           the documentation is contained.
                       Yes, Bill?
                       MEMBER SHACK:  Just one -- your
           evaluation really looks at the cracking of the
           single beam.  I mean, this looks to me like a highly
           redundant structure.  If I broke one beam --
                       MR. DYLE:  Absolutely.
                       MEMBER SHACK:  -- nothing is going to --
           have you ever gone through a -- you know, how much
           would you really have to bust this thing up so that
           things could really begin to move?
                       MR. DYLE:  We had some finite element
           studies that looked at some of that initially, and
           the numbers were rather large.  And depending on
           what the seismic loads were, what the different --
           the specific plant configuration was, and everything
           else, it was hard to get your arms around and figure
           out what you put generically.
                       So we require the inspections, and then
           on a plant-specific basis you would look at your
           flaws for your plant.
                       MR. CARTER:  I couldn't say it any
           better, really.  Just the myriad of different loads,
           different design configurations, made it difficult
           to say, "What's the absolute minimum?" you know, so
           we didn't -- we didn't try to take that approach.
                       MR. DYLE:  Some of this stuff you all
           could present better than I could.  You know the
           history better than I do.  
                       But for the BWR piping, in the '60s we
           had some scattered incidents of IGSCC.  In the '70s,
           we had the small diameter crack, pipe cracking,
           particularly in the bypass lines around the valves,
           that the industry started dealing with.  
                       And I remember reading statements of
           large bore piping will never crack.  Well, in the
           1970s, large diameter piping cracked, and we've been
           dealing with it ever since.  
                       In response to that, there was a
           concerted effort among the industry, the old BWR
           Owners Group pipe cracking initiative, and the staff
           worked for years -- Warren Hazelton and others --
           developed Generic Letter 88-01 and NUREG-0313 to
           address the cracking issues.  And that has been in
           place for years.  What VIP 75 does is revisit that.
                       As I said, there was the owners group
           activities, BWROG-1 that lasted here, and then 2
           through 88.  A lot of plants did different things. 
           Some replaced all of their piping.  Some replaced
           parts of them, different sections.  Some did local
           repairs and then did inspections more frequently,
           because what was going on in this arena was still
           under development.
                       Mitigation people used HWC early and did
           augmented inspections.  In the end, 0313 was the
           technical basis document that was issued by Generic
           Letter 88-01.  And that's been in place since then.
                       These categories remain today, and I
           will say that we didn't -- we didn't do anything
           with these in VIP 75.  We just accepted the
           categories for what they were and addressed
           inspection criteria.  But this is how the NUREG
           categorized things from resistant material that was
           pristine, pure, to stuff that hadn't been served
           very long and that was stress-improved, to longer
           service stress-improved, no stress improvement, non-
           resistant, and so forth.  So those are the
           categories that have been in place actually since
           before '88.
                       And here's the control strategies that
           we use.  We try to detect the IGSCC before the
           damage compromises system integrity.  Obviously,
           that's what you want as a regulatory body.  That's
           what we want so we can operate the plant.
                       Remove the defects if you can.  We try
           to do that, because we don't want that to be a
           problem.  We prevent initiation by introducing
           resistant material.  Again, do the replacement, use
           L grade piping.  Some of it is 316NG.
                       The structural integrity -- we've got to
           make sure that that's there.  That's just it. 
           That's all we're going to do.  In some cases, we've
           used weld overlays to reinforce the material.  The
           weld overlays also help mitigate the cracking by
           putting compressive stresses on the ID.
                       This other -- modifying the residual
           stress distribution, it can also be done by using
           stress improvement processes, whether it's IHSI,
           which is induction heating stress improvement, or
           MSIP, which is mechanical stress improvement.
                       And then the last item is to use the
           mitigation technologies of water chemistry to slow
           things down.
                       If you think back to that slide I had
           earlier about the capacity factor losses, that was a
           problem in '84.  But things have been effective to
           slow that down, and that's no longer really an
           issue.  We've been really effective as an industry
           to be able to eliminate the problem.
                       However, continuing to do inspections
           creates a dose problem, particularly in those plants
           that use hydrogen water chemistry.  Something about
           the nature of that process causes the dose to go up,
           and that's about all I can say about it from a
           technology standpoint.  We understand that's an
                       So that was one of the concerns that we
           had.  We're really saturating people with dose to do
                       What the VIP tried to do was we went
           back and looked at all of the categories and tried
           to figure out what would be appropriate.  We looked
           at the service experience.  We looked at the
           deterministic evaluations to evaluate performance. 
           We looked at inspection results, how effective
           hydrogen water chemistry has been, how effect IHSI
           and MSIP have been.
                       BWRVIP 61 is a document that discusses
           in detail IHSI and the industry survey that we did. 
           And then we looked at the crack growth studies. 
           We've developed VIP 14 and other documents and said,
           "What do we know now about crack growth?"
                       And we did use some generic risk-
           informed studies.  We didn't do a risk assessment,
           but the different plants that have done risk-
           informed ISI, and some of the pilot studies that
           were done to develop these code cases, we looked at
           those and tried to learn from them, and said, "Based
           on those insights, what makes sense?  What is the
           right thing to do as we go forward?"
                       So we tried to incorporate all of that. 
           And here's I guess the crux of what we've done, is
           these are the proposed inspection frequencies in 75
           for normal water chemistry and for hydrogen water
           chemistry.  And I guess I should also say for normal
           water chemistry what that is today is far superior
           to what it was, you know, 15 years ago.  
                       The conductivity has been maintained
           very low.  I think the staff evaluation was that the
           average conductivity for the fleet is .15
           microsiemens.  ECPs are being managed.  We're
           keeping things under good control.
                       So even normal water chemistry is far
           better than what it was.  And then, the use of
           hydrogen water chemistry would include use of noble
           metal.  For the purposes of this document, we
           considered effective HWC, either hydrogen alone or
           hydrogen and the catalyst noble metal.  
                       Obviously, without noble metal, we have
           to inject greater rates, greater amounts of hydrogen
           to be effective.  But we've come up with tools to
           evaluate that. 
                       So those are the revisions to the
           inspection frequencies that we think are appropriate
           based on inspection history and the way things are
                       The status of VIP 75 -- you know, we
           think that the countermeasures that the NRC
           required, and the things that have been implemented,
           have been effective.  And we think the inspection
           experience over the last 12 or 13 years shows that.
                       Some of these welds have been examined
           four or five times since 1988, because of the
           original criteria and the rate that they were
           required to be inspected.  
                       We think there is -- that a revision to
           NUREG-0313 or the generic letter was warranted.  We
           put that in VIP 75.  And we've got some open items
           the staff has in the safety evaluation that we're
           working on resolution of.  One of them is tied back
           to VIP 62, which I discussed earlier.  
                       What is the appropriate level that you
           must reach with your hydrogen injection and your
           water chemistry parameters to have an effective
           water chemistry program?  So we're working on that.
                       And I guess this is what you all would
           like to see -- me conclude.
                       Not my conclusions, but just for me to
                       We think that at the direction of our
           executives, in response to a problem we had, that we
           took ownership of our problem, we developed a
           technically sound program that's broad in scope, and
           sufficiently in-depth technically to address the
           concerns of the BWR internals and the associated
                       We think we have the appropriate
           elements in regard to what we inspect, how often we
           inspect, how often we reinspect, the methods that we
           use, how we evaluate the flaws, the repair
           methodologies that we would use, the mitigated
           technologies that we can use to minimize the effect
           of IGSCC.  
                       And all of that, because we did this for
           current term and renewal term to try to address all
           known degradation mechanisms, we think it's
           appropriate for use for license renewal and have
           provided it to the staff as such and have gotten
           safety evaluations for it.  
                       So that's -- that concludes the overview
           of the program and a description.  And unless you
           have other questions, I would turn it back over to
           Mr. Carpenter.
                       MEMBER SHACK:  You're proposing to go to
           10 percent every 10 years, which is like what the
           risk-informed people do, except you want to do it
           without actually doing the risk-informed analysis?
                       MR. DYLE:  We don't do the detailed
           risk-informed analysis, but what we learned from the
           risk study is that the real locations of concern
           were on ECCS, where you had the potential for
           geometric discontinuities or dissimilar metal welds.
                       So we put in VIP 75 that you select
           those locations, and that you also select the
           locations in the piping that would be problematic,
           such as the piping between the dry weld and the
           outboard isolation valve.  Because from a risk
           perspective, if you have a failure there, it's
           harder to mitigate that.  So we said you are going
           to go look at those.
                       So we looked at those generic risk
           studies and put some deterministic criteria in for
           how to select the welds and addressed it from that
                       Any other questions?  Thank you.
                       MEMBER SHACK:  Thank you.
                       MR. CARPENTER:  Okay.  Now that Robin
           has given a fairly comprehensive overview, I'll
           continue on with what the staff has found out or has
           come to.
                       We have completed a review of almost all
           of the BWRVIP reports to date.  There are only a few
           more that are left, and we are looking at those. 
           And, basically, what we've concluded is that
           implementation of the BWRVIP guidelines, as modified
           to address the staff's comments in our various SEs,
           will provide an acceptable level of quality for
           inspection of flaw evaluation of the subject safety-
           related components.
                       And it should be stressed once more that
           the vast majority of the BWRVIP program deals with
           components that are outside the scope of the
           regulatory required inspections.  So this is a
           voluntary program that is looking at more than what
           the staff has presently required.
                       We've also done -- and this goes back to
           an earlier question by the ACRS -- an independent
           review by the Office of Research -- that's NUREG-CR-
           6677 -- and has found that the BWRVIP program and
           other such comprehensive inspection programs will
           significantly reduce core damage frequency.  And
           that's one that I'll provide you a copy with a
           little bit later.
                       CHAIRMAN BONACA:  Reduce with respect to
                       MR. CARPENTER:  I'm sorry?
                       CHAIRMAN BONACA:  Reduces it with
           respect to what?  I mean --
                       MR. CARPENTER:  In respect to not having
           such a program.  If you merely did the required
           inspections that are required by the rules and
           regulations that the NRC has --
                       CHAIRMAN BONACA:  But it doesn't reduce
           with respect to the current results of the IPEs.  I
           mean, they don't assume this kind of failure rates.
                       MR. CARPENTER:  That is correct.
                       CHAIRMAN BONACA:  Okay.
                       MR. CARPENTER:  If you go in and you do
           this, you can find things much before you would
                       MEMBER SHACK:  This is the PNNL,
           essentially, risk-informed inspection kind of
           document.  Is that what we're talking about here?
                       MR. CARPENTER:  INEL.  Right.  And I
           will provide some copies to you a little bit later.
                       What we've done with the generic aging
           management plans of the BWRVIP, we are completing
           the reviews of the various license renewal
           appendices for the 12 reports that we're looking at.
                       And what we are finding is that by
           referencing the BWRVIP aging management programs and
           completing the action items that are in the staff's
           SEs for each one of those, that there will be
           reasonable assurance that the applicant will
           adequately manage aging effects during the extended
           operating period.
                       And generic AMPs usage will
           significantly reduce staff review of license renewal
           applications, and that's one of the things that --
           one of the benefits to the staff.
                       Robin mentioned that they've spent over
           $30 million on this program.  The BWRVIP has told us
           in public meetings that by some of the inspections
           that they are doing they are looking to save
           somewhere in the neighborhood of about $100 million
           in inspections.  This is saving staff resources, so
           it's a win-win for both sides.
                       Just to go back over real quickly again
           the various I&E documents -- the core spray
           internals, the core blade top guide, standby liquid
           control (SLC), shroud supports.  You've also got the
           VIP 41, which we'll be talking about here in a
           moment, 42, LPCI, the lower plenum guidelines,
           vessel ID attachments, the penetration guidelines.
                       And the reason why I'm telling you this,
           again, is just to reinforce that this is a fairly
           comprehensive program that we've been looking at.
                       BWRVIP 74 report, which is the BWR
           reactor pressure vessel one, is one that the ACRS
           has basically looked at before because we came to
           you a few years ago and talked to you about the
           BWRVIP 05 report, which was the shell weld
           inspections.  And that has been subsumed by the 74.
                       76, which is the core shroud I&E
           guidelines, which I'll be talking about in a moment
           -- as Robin mentioned, it includes the VIP 07 and
           the VIP 63 documents.  
                       And we'll also be talking about some of
           the additional reports, which is VIP 75, here in a
           moment -- which is supported by the BWRVIP 61 on
           induction heating stress improvement effectiveness,
           and the BWRVIP 78, which is the integrated
           surveillance program, which is supported by the '86
                       There is also a variety of the repair
           and replacement design criteria, which we've already
           discussed, so I'll just go through this rather
           quickly, and also some of the mitigation reports,
           which deals with crack growth and how you also
           mitigated the VIP 62, which is the hydrogen water
           chemistry guidelines.
                       And then, you've got various other ones
           -- the VIP 03, which is the internals examinations,
           the 06, which was the safety assessment that dealt
           with what was the cracking.
                       Now, we're reviewing some of the
           proposed guidance in VIP 76, and, as I said, it
           incorporates in the BWRVIP 07 guidelines, the VIP 63
           guidelines.  And what it's basically proposing is
           that the weld inspection strategy and unrepaired
           shrouds, weld inspection strategy and the repaired
           shrouds, the inspection and evaluation reporting
           requirements, a demonstration of compliance for the
           license renewal rule.
                       And, again, it incorporates 07 and 63,
           and right now we are working with the BWRVIP to
           resolve some interpretation issues that we found in
           the -- between what we said in the 07 document, SE,
           and what they understood us to say.
                       BWRVIP 41, jet pump assemblies.  We have
           completed the plant-specific reviews.  Now we're
           completing the license renewal review.  And,
           basically, what we've seen is that the VIP 41
           document has -- provides component descriptions,
           functions, describes susceptibility factors --
           again, all of the things that Robin went through
                       MEMBER LEITCH:  A question about
           BWRVIP 41.
                       MR. CARPENTER:  Yes, sir.
                       MEMBER LEITCH:  There's a sentence in
           there that puzzles me a little bit.  It says, "The
           VIP 41 report also contains an Appendix A and
           demonstration of compliance with the technical
           information requirements of the license renewal
                       MR. CARPENTER:  Yes, sir.
                       MEMBER LEITCH:  And then it goes on to
           say, "Appendix A to the VIP 41 report is not
           evaluated in this SE report, but will be evaluated
           under a separate license renewal review."
                       MR. CARPENTER:  Yes.  What we've done,
           basically, with all of the I&E guidelines, which is
           what constitutes the aging management program, the
           generic aging management program for the BWRVIP, is
           the staff has taken in these reports.  We've
           reviewed them.  As necessary, we've issued a request
           for additional information, RAIs.
                       The BWRVIP has responded back to that. 
           If there are any additional questions, we have
           issued an initial SE with open items, which
           basically allows licensees to utilize the document
           with these -- with plant-specific addressing of
           those open items, while we're still completing the
                       Once the BWRVIP has responded back to
           the open items, and we have reached agreement as to
           the review, we have issued a final SE, and that
           takes care of the present operating term for the
           BWRVIP reports.  Once that is completed, then we go
           in and we take a look at the various license renewal
           appendices, which demonstrate how they meet the
           license renewal rule, Part 54.
                       MEMBER LEITCH:  Okay.
                       MR. CARPENTER:  And as long as they meet
           Part 54 rules, then we issue a third SE, which is
           license renewal SE, a generic SE.
                       MEMBER LEITCH:  A generic SE.
                       MR. CARPENTER:  As long as the licensee
           is showing that they are in compliance with that,
           then we don't need to look at their applications
                       MEMBER LEITCH:  Okay.  Okay.  Thank you.
                       MR. CARPENTER:  Certainly, sir.
                       One of the things that we found in the
           VIP 41 is that there were instances of cast-off
           stainless steel components in the jet pump
           assemblies that may be adversely affected by high
           fluence levels, and that is going to be looked at in
           future reviews.  So that's going to be resolved
           before the license renewal term begins.
                       So preventive actions that are also
           discussed in these documents -- obviously, you
           maintain high water purity.  That reduces stress
           corrosion cracking, susceptibility.  And also,
           again, hydrogen water chemistry and noble metal
           chemistry additions will reduce it further.
                       Some of the parameters monitored and
           inspected -- the inspection and flaw evaluations
           performed in accordance with staff approved
           guidelines, and then you go in and, as necessary,
           you have examination expansion, reinspection as
           necessary, to take a look if you have flaws. 
                       And if you detect aging effects, again,
           you look at it in accordance with the staff approved
           guidelines to ensure that the aging-related
           degradation will be detected before any loss of
           intended function occurs.
                       For monitoring and trending, the
           inspection schedules in accordance with the VIP
           guidelines ensures timely detections of cracks, and
           the scope of examination expansion, reexaminations,
           will take care of beyond baseline inspections if you
           do have flaws.
                       For acceptance criteria, degradation is
           evaluated in accordance with the approved VIP
           guidelines, staff approved guidelines I should say.
                       For corrective actions, you have the
           repair design criteria if you need to do repairs,
           and the staff is in the process of approving those
           also -- again, with some open items in those. 
                       And, again, as far as operating
           experience, as Robin mentioned, you've had several
           instances in the past 20 years where the jet pumps
           have had some problems.
                       Staff has completed its review of the
           VIP 26 guidelines.  The scope of the program is
           pretty much as Robin described earlier.  So go
           through that.
                       The VIP 26 document, the aging
           management programs, the 10 elements are similar to
           what was in the VIP 41 review.  So I really don't
           need to go through that again.
                       And the operating experience -- again,
           we've had cracking found at various locations over
           the years.  And they have also been observed in the
           Swedish BWR, which I believe Dr. Shack mentioned
                       Going into VIP 75, the technical basis
           -- now, this is where we change stride here. 
           Basically, the I&E guidelines are what constitutes
           the aging management program, the generic aging
           management program for the fleet.  But the VIP 75
           and some of the other documents are intended to be
           applicable at any time in operating life, be that
           year 39 or year 59.
                       So there is no license renewal SE that
           will be issued on this one.  Once the final SE is
           issued, and we've gotten the BWRVIP 75-A document,
           licensees will be able to utilize it at any time.
                       Robin discussed some of the revisions to
           the extent of the frequency, and why it's based on
           considerations of inspections.
                       And, again, we went through how they are
           specifically applicable to inspections, but our SE
           is not applicable to any other welds.  We need to
           stress that.  It's only applicable to the Generic
           Letter 88-01/NUREG-0313 welds.  So this is not going
           beyond the scope of that.
                       CHAIRMAN BONACA:  Here you -- your
           previous slide you talked about extent and frequency
           for piping inspections contained in GL 88-01.  That
           is the first time I see this issue of frequency of
           piping instruction.  Does it imply that -- that the
           frequency changes with time?
                       MR. CARPENTER:  I'm sorry, sir.  Could
           you repeat that?
                       CHAIRMAN BONACA:  If you go to the
           previous slide, the BWRVIP 75 report proposes
           revisions to extent and frequencies for -- plant
           frequencies.  I mean --
                       MR. CARPENTER:  Yes.
                       CHAIRMAN BONACA:  -- could you comment
           on that?  Frequencies -- what --
                       MR. CARPENTER:  Yes.  Basically, gain,
           the BWRVIP 75 report proposed to reduce the amount
           of inspections that were necessary.
                       CHAIRMAN BONACA:  Okay.
                       MR. CARPENTER:  And this is for the low
           fluence regimes.  Okay?  Again, once you get into
           the high fluence regimes where you go into less
           hydrogen water chemistry, you drop out of that and
           go into normal water chemistry, the inspection
           frequencies will increase.  So the frequencies are
           being reduced because the inspection results through
           the years and the mitigations that have been
           occurring have been improving it.  
                       Once you find that your cracking is
           increasing or is occurring, you expand that.  So
           it's not that you're forever reducing.  There will
           be a time when you will be inspecting more.
                       CHAIRMAN BONACA:  Okay.  So there is
           some consideration -- yes.  Okay.
                       MR. CARPENTER:  Anything else, sir? 
                       Basically, the scope of the program was
           that it provided a summary of the generic letter, it
           discussed the use of hydrogen water chemistry to
           inhibit initiation and growth of IGSCC, it proposed
           revised inspection criteria and associated risk
           considerations, much as we've just discussed.
                       The staff issued the SE with several
           open items, and those included proposed inspection
           frequency and scope of the category A, B, C, and E
           welds.  We didn't precisely agree with the BWRVIP on
                       We also requested more in the way of
           sample expansion, and we talked about reactor water
           coolant conductivity and what was necessary for
           that, what exactly constituted an effective hydrogen
           water chemistry and noble metal chemistry addition
           programs, and also just how do you identify safety-
           significant locations.  And that's all in the SEs
           that we provided to you.
                       And we have met with the BWRVIP.  Just
           last week we discussed this, and they're going to be
           coming in with a response to that SE here in the
           near term.
                       Again, the staff has the VIP 75 guidance
           to be acceptable except for the open items, and the
           revised 75 report can be used by licensees to
           replace inspection guidance and Generic Letter 88-
           01.  And several licensees have already started
           making use of that revised guidance addressing the
           open items as necessary.
                       And we believe that this will provide
           reasonable assurance for integrity of the subject
           BWR piping welds.
                       In conclusion -- the reason I'm going so
           fast is because Robin took care of the majority of
           the information that we wanted to provide to you --
           we have found that referencing the VIP aging
           management program, including the staff required
           action items, will provide reasonable assurance that
           applicants will adequately manage the aging effects
           during the extended operating period, and that the
           generic AMPs will significantly reduce staff reviews
           of license renewal applications.
                       I believe that will be borne out when
           you talk with the people tomorrow on Hatch regarding
           how much was reduced on that.  
                       And that concludes my presentation.  Any
                       CHAIRMAN BONACA:  Well, I just had
           question maybe for both presenters.  And I just
           mentioned it before; I still am belaboring on this
           issue.  You know, the oldest program says that, you
           know, you identify these materials which have
           different susceptibility to cracking.
                       And then for the less susceptible it
           will be every 10 years you perform an inspection. 
           For the more susceptible locations, all materials
           you do it every six years.
                       You maintain a step up to 60 years, or
           can maintain it to 100 years I guess.  It's
           counterintuitive to me that, as you continue to age
           this material, you would expect to need the same
           frequency of inspections.  I mean, I just -- maybe
           my material expert colleagues here could help me
           with that, particularly where you have this
           susceptible material in a susceptible region, high
                       MEMBER SHACK:  Well, no, this is piping
                       CHAIRMAN BONACA:  Yes.  Well --
                       MEMBER SHACK:  So you're not
           accumulating any fluence in this piping.
                       CHAIRMAN BONACA:  No.  I thought that,
           however, there are also intervals of inspections for
           intervals, for example, that would also have the
           step-wide frequency.
                       MEMBER FORD:  Essentially, your concern,
           Mario, is that -- your concern is that the
           assumption is that the damage is occurring literally
           over time.
                       CHAIRMAN BONACA:  Yes.
                       MEMBER FORD:  And if it's occurring
           exponentially with time, then having it every four
           years or 10 years is inappropriate. 
                       CHAIRMAN BONACA:  Well, at some point,
           it seems to me that because --
                       MEMBER SHACK:  It's not only linear in
           timing, because it suddenly bounces up to 5 times
           10 --
                       MEMBER FORD:  But it's just because
           you've seen it.  It's kind of up to NTE resolution
           on --
                       CHAIRMAN BONACA:  The only thing is --
           the rest I think is -- I'm very comfortable with the
           fact that there has been a very careful look at
           every component, every location, every environment,
           and it can -- you know, I think it's a very thorough
                       It just still -- and I guess if there is
           an acceleration of damage being experienced, there
           will be some response coming at some point for that. 
           And so --
                       MR. CARPENTER:  Well, if I could echo
           what Robin said earlier, if you're looking at some
           of these components, and you see degradation
           occurring at an increased frequency, obviously, what
           we have been trying to do in some of these reviews
           is that you were going to do scope expansion and
           frequency expansion.
                       So as things -- if things, I should say,
           begin to crack and degrade in greater frequency over
           the years, the VIP program is pretty much a living
           program.  It's not once you've done it you put it on
           a shelf and you're complete with it.
                       The staff has been working with them on
           this.  If need be, we will be going back to the
           BWRVIP and saying, "We need to revisit some of these
           inspection frequencies and scopes."
                       MEMBER KRESS:  That concept of
           increasing the frequency based on what you see puts
           a great deal of emphasis on the first frequency, the
           first inspection frequency.  How was that arrived
           at?  Did you have -- the six years, for example.  
                       You know, if you're looking for linear
           extrapolation and want to be sure it doesn't go up
           exponentially, and you're looking at frequency of
           inspections to keep you away from that, you know, a
           whole lot rides on that first frequency that you
           choose.  And I was just wondering how that was
                       MR. DYLE:  If I could maybe try to help
           with that.  Maybe the way the presentation went made
           it look like it was a decision on a discrete
           component basis, and that's really not the case.
                       You know, when we looked at how often
           should we inspect something that has, for example,
           182 weld metal, we looked at all of the components. 
           We said, "Have we seen cracking anywhere?  What's
           the industry-wide experience?  What's the behavior
           of this stuff?"  If it should crack, how fast would
           it grow?  If I don't find it today --
                       MEMBER KRESS:  That's the key right
                       MR. DYLE:  Right.
                       MEMBER KRESS:  You have a model for how
           fast it will grow.
                       MR. DYLE:  Right.  And those were things
           that we took into consideration.  If I look today
           and it cracks tomorrow and starts growing, what's a
           reasonable inspection frequency to look again to
           ensure integrity?
                       MEMBER KRESS:  So the -- that first one
           -- decision on how long to wait for the next
           inspection depends on the crack growth model or
           crack initiation model.  And the question I have is,
           is there any reason to expect those to be linear?
                       MR. DYLE:  No, not necessarily.  We
           tried to be conservative.  If you look at some of
           the components -- and we did this -- and you said,
           "Well, if I have a crack today," and using, let's
           say, in VIP 14 for the crack growth rate for
           stainless steel that's not irradiated, you could
           justify an inspection frequency of 20 years.
                       We'd say, "Well, that's -- that doesn't
           make sense."  So --
                       MEMBER KRESS:  So we're -- over a short
           time, linear is a good enough approximation is what
           you're saying.
                       MR. DYLE:  It would seem to be.  And
           then, again, as Gene said, we called it a living
           program.  If we find a problem in stainless that's
           welded -- I don't know, pick a component -- to core
           spray, if we find something new, we say, "All right. 
           What's the impact on that of every other location
           that's got stainless material that's welded?"  We
           need to revisit everything.
                       CHAIRMAN BONACA:  The other key thing
           that comes to mind now is you have about 30 or 40
           plants in the program.
                       MR. DYLE:  That's right.
                       CHAIRMAN BONACA:  So, really, you are
           having probably --
                       MEMBER KRESS:  So you're having
           inspections, really, pretty often, naturally.  When
           you look at the population --
                       MEMBER SHACK:  Even there, when the guy
           inspects his pipes, it's not as though he doesn't
           inspect the pipe, you know, in 10 years, and then he
           suddenly goes in the next outage and looks at it. 
           You  know, he's got to look at all of the welds over
           the 10 years.  He's looking at a sample --
                       MEMBER KRESS:  So spreading them out.
                       MEMBER SHACK:  Right.  And when you do
           that on a plant-wide basis, you've actually got a
           pretty good sample of things going on.  I mean, you
           know, the alternative to an expansion rule is to
           somehow pretend you really understand this well
                       CHAIRMAN BONACA:  I hope you're --
                       MEMBER SHACK:  I prefer the expansion
           rule myself.
                       CHAIRMAN BONACA:  I hope you would.  No,
           but I think the sheer number of plants involved in
           the program, and the sharing and communication of
           information, is sufficient, give a lot more comfort
           because you essentially have, on average, three or
           four inspections a year.
                       MR. DYLE:  Right.  And we hope that --
           and maybe I wasn't clear in the beginning of the
           presentation.  But by giving this semi-annual update
           of what's happened, it allows the staff to
           independently assess the adequacy of the program
                       So we're willing to accept that
           feedback, and this -- this has been a good effort
           where we could do what we thought was the right
           technical thing, and the staff comes back.  We're
           not worrying about licensing arguments, so we hope
           to keep that relationship.
                       MR. CARPENTER:  And I didn't bring a
           copy of what Robin was just talking about, but the
           semi-annual inspection and summary that the BWRVIP
           provides to us is approximately, you know, a
           quarter-inch thick.  So we do have a very large
           database that we are accumulating, and that has been
           coming to us for the last four or five years now.
                       Any other questions?
                       CHAIRMAN BONACA:  Any more questions for
           Mr. Carpenter?
                       MEMBER KRESS:  Are we writing a letter
           on this?
                       CHAIRMAN BONACA:  Well, we plan to
           address the review of this, you know, as part of the
           Hatch application.  The Hatch application references
           these reports.  So we did pretty much what we did
           originally for, for example, the use of the B&W
           topical in support of the Oconee application.
                       MEMBER KRESS:  But we haven't reviewed
           these models -- plant growth and initiation, on
           which a lot of this relies on.  Can we make
           judgments without reviewing those models and the
           database that underlies them?  Or we just rely on
           Bill and Peter to tell us it's okay?  Or --
                       MEMBER SHACK:  The staff has written
                       MEMBER KRESS:  Okay.  Well, the staff
           has got an SER.  Why don't we -- I mean, that
           doesn't --
                       CHAIRMAN BONACA:  We have reviewed only
           a sample of SERs.
                       MEMBER SHACK:  Yes.  I mean, it's like
           our whole review of the license renewal process.  I
           mean, we don't review every SER of every supporting
                       MEMBER KRESS:  We rely on the staff's --
                       MEMBER SHACK:  Well, I mean, you sort of
           try to sample I guess is what we've done.
                       CHAIRMAN BONACA:  Yes.  
                       MR. DURAISWAMY:  That's what you did,
           Tom.  This time we really picked four reports.  I
           think, Bill, you got two, and Graham got one, and
           John got one.  So you guys, you know, found it
           satisfactory?  Any problems?
                       MEMBER SHACK:  Yes.
                       MEMBER KRESS:  I did, too.
                       MEMBER LEITCH:  Yes.
                       CHAIRMAN BONACA:  Okay.  So that's all
           we can do -- sample it.
                       MEMBER KRESS:  Yes.  But the whole
           committee has to sample it.
                       MR. DURAISWAMY:  Well, and the next --
           next BWR plan comes in, I think we will take
           probably about 10 reports and give one to each
                       MEMBER KRESS:  Give all 10 of them to
           each member.
                       MR. DURAISWAMY:  Well, we can do that,
           too.  So -- we can do the other thing, Tom.  It's
           going to be tough.
                       MEMBER KRESS:  I know particularly in
           this area, it's -- this is a tough area.
                       MEMBER SHACK:  Yes.  I mean, you can
           count the number of man-years they spend on this,
           and then you -- you know, you go around and you try
           to figure out how we're going to do it.
                       MEMBER FORD:  Could I ask a question of
           clarification?  It relates to your crack growth
           disposition algorithms.  Are we using 5 times 10-5
           inches per hour?
                       MR. CARPENTER:  We are using that for
           the majority of the cases, and any time you get
           above the threshold fluence level inside the reactor
           vessel for 5E-5 inches per hour is what we're using. 
           In some cases, we have reduced the crack growth rate
           because the BWRVIP has been able to show that there
           is a case to do so.
                       MEMBER FORD:  So this five times 10-5
           for both higher rated and not -- it's five times --
                       MR. DYLE:  If I could, BWRVIP 14, which
           is the statistical correlation, sets a new
           disposition line at -- I think it's 2.2E-5 for
           disposition purposes.  And that's based on the
           statistical review of the data, plus with some input
           from GE with their verification in another way that
           that was an acceptable disposition curve to be used.
                       MEMBER KRESS:  Is that the main line, or
           is that a 95 percentile line through the data?
                       MR. DYLE:  95.95.
                       MEMBER KRESS:  95.95.  Okay.
                       MR. DYLE:  Of the data.
                       MEMBER SHACK:  You've got to remember,
           first you look at the crack growth curve, and then
           you have to look at the stresses.  And so, you know,
           what they've done is sort of taken --
                       MEMBER KRESS:  All the data.
                       MEMBER SHACK:  -- an approximate -- you
           know, a conservative crack growth curve, and then
           what is for most cases an approximate stress-
           intensity value, and picked it there.  You know, I
           think you would have to argue that it's an
           engineering judgment rather than a statistical
           model, because it's very hard to characterize the
           stress distributions.
                       You know, you can do something with the
           crack growth curve, but then you still have to make
           a judgment.
                       MEMBER KRESS:  I thought the crack
           growth curve had inherent in it the stress.
                       MEMBER SHACK:  No.  It says that for a
           given stress intensity I get a crack growth rate. 
           But then I have to decide what the stress intensity
           is at this weld at this point.
                       MEMBER KRESS:  Oh.  The data is not --
           is data taken in the laboratory for a given -- where
           you impose an intensity and a chemical --
                       MEMBER SHACK:  Right.  Because it's the
           only way you can do it.  I mean, because it does
           depend on the stress intensity.  You have to have
           the crack growth rate depend on the stress
                       MEMBER KRESS:  And you have a
           laboratory-based model.
                       MEMBER SHACK:  Which means, then --
           well, even if it wasn't a laboratory-based, it means
           if you did a field measurement you would have to
           know what the stress is in that weld. 
                       MEMBER KRESS:  Well, I --
                       MEMBER SHACK:  So I get out stress
           meter --
                       MEMBER KRESS:  Not if you put all the
           data on a curve and took the 95.95.  That would take
           care of it.  But if it were all field data -- that
           was where I was confused.  It's not field data,
           though, you're talking about.
                       MEMBER SHACK:  Even the field data --
           you know, then, you have to decide when the crack
           started growing.
                       MEMBER KRESS:  Yes.  Of course, you'd
           have to have the data.  Yes.
                       MEMBER FORD:  I think that this present
           discussion arises out of the comments that you all
           made.  Does the ACRS write an approving letter, or
           whatever it is that we write, for this methodology?
                       MEMBER KRESS:  Well, I think what we do
           in the case of this license renewal is to say the
           ACRS has looked at the staff's SER and the staff's
           procedure, and we approve the procedures.  But we
           don't -- I think we keep hands off on saying we
           approve the license --
                       MR. DURAISWAMY:  No, it doesn't say --
           just the word "approve," yes.
                       MEMBER KRESS:  Yes, we don't approve
           license renewal.  We agree with the staff's --
                       MR. DURAISWAMY:  Exactly.
                       MEMBER KRESS:  -- has done a good job of
           SER, and that the procedure is okay.  I think that's
           the way we have to deal with it, but we can't
           approve all of this.
                       MEMBER FORD:  Well, I was about to
           follow it up with another comment on -- that there
           has been a fair amount of discussion within industry
           about the methodology used for coming up with these
           statistically-based algorithms, which then, in turn,
           depends on the quality of the data upon which they
           are statistically derived -- however those are
           derived.  And there will always be arguments along
           those lines.
                       The question I'm really asking the staff
           is, are they happy that that disposition curve is a
           safe disposition curve?  In other words, there have
           been very few data points which exceed that value
           of, what, 2.2 or -- steady state value of 2.2 times
           10-5.  That is the -- as far as the safety point of
           view.  Forget the specifics of, you know, whether
           you agree with the methodology.
                       So the question is:  are the staff -- is
           the staff happy that this statistically-derived
           disposition algorithm is a safe upper-bound value?
                       MEMBER KRESS:  I think if you read his
           last conclusion on the slide, you would have to say
           that, yes, they're happy with it.
                       MEMBER FORD:  Yes.
                       MR. CARPENTER:  The staff hasn't seen
           that.  The staff has approved the BWRVIP 14 document
           with several caveats, which are being addressed by
           the BWRVIP.
                       MEMBER FORD:  Okay.
                       MEMBER SHACK:  So, basically, for
           application to low irradiation levels, they have
           accepted that.
                       MEMBER FORD:  As a conservative.
                       MEMBER SHACK:  As conservative, right.
                       CHAIRMAN BONACA:  The heart of the
           license renewal rule is that you have adequate
           programs to inspect passive components to assure
           that you can manage aging degradation.  
                       You know, so there is -- I think that
           you are -- the way I see it, it addresses the issue
           of looking at specific locations, looking at the
           environment in those locations, conditions for the
           aging effects there may be on those components, and
           establishing inspections and repair techniques and
                       And so I think in that sense, really, it
           seems to be totally in agreement with the license
           renewal steps that you have not questioned, that
           really we have not explored in detail for each one
           of the locations, etcetera, as the correlations. 
           And, therefore, the timing of the inspections, for
           example, and we haven't -- we can't comment on that,
           except for the specific four examples that we
                       But we can conclude that the process is
           really in line with the license renewal process.
                       MEMBER KRESS:  Yes.  And I think that's
           what we ought to -- Bill, you mentioned that the
           correlations were conservative for non-irradiated
           material.  Does the database include radiated
           material?  That seems like a pretty tough laboratory
           assignment to get --
                       MEMBER SHACK:  Well, that's why it gets
           a lot higher when you have irradiated materials.
                       MEMBER KRESS:  But do we have data on
                       MEMBER SHACK:  You have very limited
           data, which is why you have to make conservative
                       MEMBER KRESS:  I can see how it would
           have to be, yes.
                       MR. DURAISWAMY:  We're trying to get --
                       MR. DYLE:  We're trying to gather data
           from different -- we've leveraged our money.  We've
           bought into different research programs, so we can
           obtain data, say, for Halden and other activities. 
                       GE has worked to develop that.  And as
           soon as we have something that is usable that we
           think justifies a change in rate or a better
           definition of the rate, we'll give that to the staff
           for their review.  But we understand that that's
           something that we've got to deal with.
                       We're looking at fracture toughness
           also.  There are some irradiated issues that we need
           to deal with and understand.
                       CHAIRMAN BONACA:  Any other comments?
                       Let's talk just briefly about two
           things.  One is, again, the way we view -- the way
           we view this review of the BWRVIPs.  In the letter
           for Hatch, is there any other insight to provide
           here?  Or shall we just treat them the way we
           treated the B&W topicals for the Oconee application? 
           I would say that would be the approach that I would
           propose.  Any other --
                       MEMBER LEITCH:  Have you picked your two
           -- that is, one letter dealing with the BWRVIP
           program, and another letter dealing with the Hatch
           license renewal application that references this.
                       MR. DURAISWAMY:  No.  I think I
           better --
                       MEMBER LEITCH:  Because this is going to
           be used much more widely than Hatch in the future,
                       MR. DURAISWAMY:  Yes.  But, Graham, I
           think in the Hatch application, you know, they're
           referencing, what, close to 20 reports?  How many?
                       MR. CARPENTER:  Can you tell me --
           you've got something like -- well, almost every one
           of the I&E documents --
                       MR. DYLE:  Yes, for the -- and you would
           have referenced 01, 07, 63, and then 76, which is
           really just one document, but there's four
           references.  So we've referenced all the I&E
           documents where applicable.
                       An example would be core plate we
           didn't, because we've installed wedges.  So by --
           although we considered the scope of that, we looked
           at the core plate and said, "What does the VIP
           require that we do?" the answer was nothing, because
           we've installed the wedges.  The core plate can't
           move should the bolts fail.  So that's not
           specifically referenced but it was concerned.
                       The Hatch commitment is to implement the
           VIP documents as the NRC SE specifies or we'll
           notify the staff of changes that we need to make to
           do that. That's in the application, and that's the
           direction we're headed.
                       MEMBER LEITCH:  But my question is, when
           the next BWR comes in, what do we do about that?
                       CHAIRMAN BONACA:  See, their burden is
           to demonstrate that the topical -- these topical
           reports are applicable to their plant, the
           application they propose.  That's what the staff is
           supposed to review.
                       And, again, on our part, it's to assure
           that we feel comfortable that the staff has
           performed the verification.  Granted, we are
           approving -- we're not approving -- we're using or
           referencing these BWRVIPs in our review of the
           individual applications, with no complete review on
           our part of all the topicals.
                       We really have reviewed only four, and
           we have reviewed the staff presentations and the SER
           provided by the staff.  But this is not unlike other
           things that we do -- we do reference in our review
           of the applications and the SERs.
                       I don't know -- I know that there are a
           number of others that will receive separate
           evaluations that aren't completed -- totally
           completed yet.  Do we have any plan to review those
           when they come through?  I don't think so.
                       MR. DURAISWAMY:  No.  I think the next
           -- you know, next time, I think we've got to pick
           and choose, you know, some additional reports, you
           know, important reports.  I think we can do -- when
           the staff has completed the safety evaluation, so
           you've got to do the same thing what we did this
           time.  You  know?
                       So Tom is willing to, you know, look at,
           you know, some more reports.  And I think --
                       MEMBER SHACK:  Well, for example, the
           important one will be the hydrogen water chemistry,
           because that will be fundamental to a major change
           in inspection frequency.  And so, you know, I think
           when the SE for that one comes out, for example,
           that would be one that would -- we would want to
           look at.
                       CHAIRMAN BONACA:  Yes.  I think what we
           should plan to do probably is to reflect on that,
           think about it, and then make a little plan on our
           part on what we're going to review and under what
           kind of conditions.  It may be that we do it for the
           next BWR license renewal committee that we have.
                       MR. ELLIOTT:  Peach Bottom is only six
           months away, or less.  They're coming in this
           summer, I believe.
                       CHAIRMAN BONACA:  Okay.  Now, the second
           issue I would like to talk about briefly is, what
           are we asking the staff to come and tell us about
           this at the next meeting next week for the full
           meeting?  I would expect that we will have some
           condensed presentation as part of the Hatch
           application.  So that's really the way we're going
           to address the BWRVIPs anyway.
                       MEMBER KRESS:  What do we have, two
                       MR. DURAISWAMY:  How much time?  I
           forgot.  Yes.  We get two hours for Hatch and --
                       MEMBER KRESS:  Yes.  But how much time
           do we have --
                       MR. DURAISWAMY:  No, but -- yes, for the
           -- and the guidance documents and -- we have an hour
           and 10 minutes.
                       MEMBER KRESS:  Okay. 
                       CHAIRMAN BONACA:  My suggestion is that
           we try to stay within the schedule.  We may need
           less time for the guidance documents.
                       MR. DURAISWAMY:  Yes.  But they are --
           all of things are included under Hatch.  You know,
           so we can -- you know, they can address, you know,
           some of these things at that time.
                       CHAIRMAN BONACA:  Okay.  So we will have
           -- we will need a summary of the -- from the staff
           of this effort, the BWRVIP report that has been
           produced, and they are referenced in the application
           for Hatch, and then some summary of -- I guess I'm
           wrestling right now with the time available to us
           for that presentation, which is limited.  
                       So what do you think will be interesting
           to the other three members which are not here right
                       MEMBER FORD:  Could I ask, what's the
           expectation of the meeting next week for the Hatch? 
           Are we expected to come up with an approval?
                       CHAIRMAN BONACA:  No.  We are going to
           have a report on this SER, which still has open
           items.  So, therefore, we will have an opportunity
           to review it again.  But this is a time when we can
           provide some feedback if there is feedback we want
           to provide.
                       MEMBER FORD:  Okay.
                       CHAIRMAN BONACA:  So -- yes, my
           suggestion is that we will probably commit to maybe
           half an hour of the whole presentation dedicated to
           the BWRVIPs with -- probably the best way would be
           to start with those two figures of the core and the
           components, so that there is an overview for the
           other members of what components we're talking about
           here.  Very briefly, the kind of failure experience,
           the program that was implemented to address these
                       I certainly think that the members
           should see, one, the population of the BWRs involved
           in this.  The other way -- the other thing you
           should present is the -- the unavailability of the
           -- how much it has gone down since 1984, which
           definitely speaks of a success story for the program
           which has been implemented to test those.
                       And then, I think that I would focus
           purely on the four BWRVIPs that we chose, which I
           believe are pretty central.  They were regarding
           internals -- you know, the --
                       MR. BARTON:  Jet pumps and --
                       CHAIRMAN BONACA:  -- the jet pumps, the
           shroud, the --
                       MR. BARTON:  -- top guide.
                       CHAIRMAN BONACA:  -- top guide.
                       MR. BARTON:  And Class I piping.
                       CHAIRMAN BONACA:  That's fine.
                       MEMBER SHACK:  But, still, in a half an
           hour, you can barely do more than mention the
                       CHAIRMAN BONACA:  Well, I mean, I will
           be expecting only to see some conclusions as far as
           inspection frequency.  I don't think we want to have
           more than that.  For Oconee, when we have the -- I
           don't think we had almost any presentation of the
           B&W topical reports.
                       MEMBER SHACK:  No, we didn't.
                       CHAIRMAN BONACA:  We didn't.  Are you
           suggesting we don't have it?
                       MEMBER SHACK:  No.  I guess I would
           focus on primarily how successful the program has
           been in, as you say, reducing the outages, and, you
           know, the sort of incidence of cracking.
                       CHAIRMAN BONACA:  Yes.
                       MEMBER SHACK:  And, you know, which is
           in a way the proof of the effectiveness of the
           program.  Whatever you may argue about, you know,
           what we understand and what we don't understand, you
           know, we're just not getting nearly as much cracking
                       CHAIRMAN BONACA:  And, again, focusing
           on the fact that the outcome of all this work really
           is a number of guidelines which seem to pattern
           exactly the -- for example, what you find in GALL
           for other components.  Okay?  So, essentially, the
           rate of inspection required, etcetera, etcetera, the
           programmatic requirements of license renewal.
                       MR. CARPENTER:  Well, bear in mind GALL
           relies heavily on the BWRVIP program for the
           internals, so --
                       CHAIRMAN BONACA:  And that fits right
           into that.
                       MR. CARPENTER:  Right.
                       CHAIRMAN BONACA:  So it will be almost a
           presentation, you know, within that context.
                       MR. CARPENTER:  Yes.
                       CHAIRMAN BONACA:  You said a half an
           hour cannot provide much, but the -- I don't think
           we should spend more than half an hour on that,
           because there are many other issues we need to
                       MEMBER SHACK:  No.  You can't give more
           than half an hour.
                       CHAIRMAN BONACA:  Maybe 20 minutes,
                       MEMBER KRESS:  Take a look at Mr. Dyle's
           conclusions slide.  He's got three major
           conclusions.  The scope is all-inclusive and broad,
           and that it includes the appropriate elements,
           including inspection evaluation, repair, and
           mitigation.  And that the program has been
           successful, and so forth.
                       If you could choose slides to illustrate
           those three conclusions --
                       MR. BARTON:  We just have one slide that
           talks about how you looked at risk, so that will
           save George a 30-minute tirade on the --
                       MEMBER KRESS:  Yes.  We had less than --
           we had one bullet on this.
                       MR. BARTON:  At least one bullet on it.
                       MEMBER KRESS:  But, anyway, you know, if
           you could -- if you could come up with some much
           shorter supporting slides for those three
           conclusions, it would be a good approach I think.  I
           think, actually, you can go in here and choose some
           that would fit in a time period.  Might be able to
           do it.
                       CHAIRMAN BONACA:  Okay.
                       MEMBER KRESS:  I think those are
           conclusions they'd like to know.
                       CHAIRMAN BONACA:  Sure.
                       MEMBER KRESS:  Things they'd like to
           know about.
                       CHAIRMAN BONACA:  Okay.  You'll be
           providing that, or somebody?
                       Okay.  Any other comments?  If there are
           no further comments, I think we are ready to adjourn
           the meeting today.
                       MR. DURAISWAMY:  Yes.  This meeting
           tomorrow is a different -- 
                       MEMBER KRESS:  You're adjourning this
           meeting and you want to start a new one tomorrow.
                       CHAIRMAN BONACA:  Okay.  We'll start a
           new one tomorrow -- the Hatch application.
                       Okay.  If nothing -- no comments from
           the public?  Okay.  The meeting is adjourned.
                                   (Whereupon, at 4:15 p.m., the
                       proceedings in the foregoing matter were

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