Plant License Renewal-March 28, 2001

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               Plant License Renewal Subcommittee

Docket Number:  (not applicable)

Location:                 Rockville, Marylad

Date:                     Wednesday, March 28, 2001

Work Order No.: NRC-136                               Pages 1-174

                   NEAL R. GROSS AND CO., INC.
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                  1323 Rhode Island Avenue, N.W.
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                              MARCH 28, 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
           Bonaca, presiding.
           Plant License Renewal Subcommittee Members Present:
           MARIO V. BONACA,      Chairman
           F. PETER FORD
           THOMAS S. KRESS
           GRAHAM M. LEITCH
           WILLIAM J. SHACK
           ROBERT E. UHRIG
           ACR Consultant Present:
           JOHN BARTON
           ACRS Staff Present:
           Also Present:
           RAJ ANAND
           HANS ASHAR
           RAJ AULUCK
           RAY  BAKER
           JOSE CALVO
           JAMES DAVIS
           ROBIN DYLE
           BARRY ELLIOT
           WILLIAM P. EVANS
           JOHN FAIR
           DAVE GERBER
           CHRIS GRIMES
           MARK HARTZMAN
           DAVID JENG
           MEENA KHANNA
           W. KOO
           Also Present: (cont.)
           P.T. KUO
           CHANG-YANG LI
           Y.C. (RENEE) LI
           KAMAL MANOLY
           DONALD P. MOORE
           KEITH NICHMAN
           K. PARCZEWSKI
           ERACH PATEL
           FRED POLASKI
           JAI RAJAN
           JANAK H. RAVAL
           DAVID TERAO
           BRIAN THOMAS
           HAROLD WALKER
           DOUG WALTERS
                        AGENDA ITEM                        PAGE
           Opening Remarks, M. Bonaca, ACRS . . . . . . . . . 5
           Staff Introduction, C. Grimes, NRR . . . . . . . . 6
           Overview of SER Related to Hatch License
             Renewal, W. Burton, NRR. . . . . . . . . . . . . 7
           Southern Nuclear Operating Company, Inc.,
             Presentation, R. Baker, SNC. . . . . . . . . . .16
             Background, C. Pierce. . . . . . . . . . . . . .16
             License Renewal Application Scoping and
                 Screening Process (IPA), R. Baker. . . . . .20
             Aging Effects
             Aging Management Programs. . . . . . . . . . . .98
             Time Limited Aging Analyses
           SER Section 2.0 - Structure and Components
             Subject to an Aging Management Review, W.
             Burton, NRR. . . . . . . . . . . . . . . . . . .60
           SER Section 3.0 - Aging Management Review, NRR
             Staff. . . . . . . . . . . . . . . . . . . . . .98
           Operating Experience Summary
           SER Section 4.0: Time-Limited Aging Analyses,
             J. Fair, NRR . . . . . . . . . . . . . . . . . 153
           Discussion, M. Bonaca, ACRS. . . . . . . . . . . 156
           Adjourn, M. Bonaca, ACRS . . . . . . . . . . . . 174
           .                           P-R-O-C-E-E-D-I-N-G-S
                                                    (8:30 a.m.)
                       DR. BONACA:  Good morning.  The meeting
           will now come to order.  This is the meeting of the
           ACRS Subcommittee on Plant License Renewal.  I am
           Mario Bonaca, Chairman of the Subcommittee.  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 Southern Nuclear Operating Company's application
           concerning the license renewal for Edwin I. Hatch
           Nuclear Plants 1 and 2 and the associated NRC staff
           Safety Evaluation Report.
                       The Subcommittee will gather information,
           analyze relevant issues and facts and formulate
           proposed positions and actions as appropriate for
           deliberation by the full committee.
                       This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Mr. Sam Duraiswamy is the cognizant
           ACRS staff for this meeting.  Mr. Robert Elliott who
           is on rotational 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.  It will be made available as
           stated in the Federal Register notice.
                       It is requested that speakers first
           identify themselves and speak with sufficient clarity
           and volume so that they can be readily heard.
                       We have received notice of comments and
           request for time to make oral statements from members
           of the public.
                       We will now proceed with the meeting and
           I call upon Christopher Grimes of NRR to begin.
                       MR. GRIMES:  Thank you, Dr. Bonaca.  My
           name is Chris Grimes.  I'm the Chief, License Renewal
           and Standardization Branch and we've organized the
           presentation today to discuss the staff's Safety
           Evaluation Report for the Hatch License Renewal
           Application with an emphasis on identifying in the
           Safety Evaluation Report some of the uniquenesses of
           the first BWR review.
                       We're going to start off with an overview
           by the Project Manager, Butch Burton and then Southern
           Company is going to provide a presentation on the
           application.  And then we'll get into the specifics of
           the safety evaluation.
                       The staff's presentation will identify
           where there are open items and we would appreciate the
           ACRS views on the open items, but I want to stress
           that beginning tomorrow, we're going to have the first
           of what I consider to be a series of meetings in which
           Southern Company is going to appeal staff positions on
           these issues and we're going to work that process to
           develop final staff positions and the resolution of
           the open items.
                       And with that, I'll turn the meeting over
           to Butch Burton.
                       MR. BURTON:  Can everybody hear me okay? 
           I'm going to be using the mobile mike here.
                       As Chris said, my name is William Burton,
           but as you probably -- Chris probably clued you in I
           prefer to go by Butch.  
                       I am the Project Manager for the Hatch
           License Renewal Application Review.  Let me get this
           mike situated here.
                       I'll start with a little bit of background
           here.  I'll go through this briefly.
                       We've had the application in-house with
           the staff for a little over a year.  It was actually
           submitted by application by a letter dated February
           29th.  As you, I'm sure, most of you know, this is a
           Boiling Water Reactor, the first to come in for
           license renewal.  It is a BWR/4 design, and two units.
                       The plant is located on the Altamaha
           River.  I hope I pronounced that right, in Appling
           County, Georgia.  It's about 11 miles north of Baxley
           and I believe, as the crow flies, it's probably about
           70 miles from Savannah, Georgia.
                       Unit 1, the current license is due to
           expire in 2014 and they have asked for an extension of
           that additional 20 years to 2034.  Likewise, Unit 2 is
           currently scheduled to end its license in 2018 and
           they're looking to extend it to 2038.
                       One thing that I did want to do, this is
           not in your package, but I did want you to see the
           review schedule very briefly so you can see ware we
                       March 16th, we completed the second of the
           three scheduled inspections, the V inspection where
           primarily the inspection team went to the site to
           confirm that some of the commitments that are
           currently in the Aging Management Programs are
           properly being implemented at the site.  And as a
           result of that inspection we have pretty good
           confidence that they are identifying their commitments
           as identified in the Aging Management Programs and
           properly implementing them on site.
                       Right now, all of the changes that they
           have to make to the current procedures are pretty much
           in draft or proposed form, but they are u them.
                       It was my understanding that one of the
           committee's main interests was to compare the Hatch
           Plant being the first BWR with some of the previous
           applicants, in particular, to see if there was
           anything materially different between what we're
           seeing at Hatch and what we have seen at some of the
           other plants.
                       And having taken a step back and taken a
           look at that, we really do not see any new technical
           issues.  As Mr. Baker from Southern Nuclear will go
           into detail in a few minutes, Hatch took a commodity
           approach to their evaluation and as such, what we do
           is -- what they did was they identified materials of
           construction, the environments that those materials
           operate in, and then identify any applicable aging
                       And in fact, what we found is that there
           are no unique materials, there are no unique
           environments, and so we do not have any new or unique
           aging effects.  So in that respect, which is the
           primary technical issue, we really don't see any
           difference between Plant Hatch as the first BWR and
           any of the previous applicants who are all PWRs.
                       Most of the differences that I'll talk
           about between Plant Hatch and some of the previous
           applicants is really, it's really a matter of process
           and formatting and that's primarily what you see with
           the remaining bullets.  It is the first to use the
           Boiling Water Reactor Vessel and Internals Project
                       Now my plan today was not to go into a
           whole lot of detail about that since you all covered
           it pretty well yesterday.  So what we'll do is as we
           talk about it, the appropriate points, we'll point out
           where BWRVIP reports were applied in the review.
                       Plant Hatch was the first to use the
           functional approach versus the system approach in the
           scoping process.  I was going to go into a fair amount
           of detail about this, but Mr. Baker is actually going
           to be coming up after me and he's going to go into
           substantial detail on the scoping and screening
           process.  So if you don't mind, I'll hold off on that.
                       Then finally, they were the first to apply
           the Aging Management Program attributes to demonstrate
           adequacy of aging management as opposed to the Aging
           Management Programs themselves.  I do have another
           supplemental graph here, vu-graph here to show you
           what I mean by that.  Again, this is not in your
           package and I know it's hard to read, so I'll try and
                       What Southern Nuclear did was they took
           the 10 attributes that we're all familiar with and
           what we're used to seeing is having those 10
           attributes applied to each Aging Management Program. 
           And they took a unique approach which actually the
           staff found good.  And what they did was they took the
           10 attributes and at this point in addition to
           applying them to each Aging Management Program, they
           actually looked at, for instance in this case, they
           created what are called Aging Management Program
           Assessment Tables.
                       This particular one I have up here is for
           copper and alloys within a river water environment. 
           That's the commodity group and the specific aging
           effect is flow blockage due to aging mechanism
           fouling.  And what they did was they said, for
           instance, the scope, how do we ensure that we capture
           everything that we need to capture for this?  And they
           say here are the Aging Management Programs that do
                       And what they did was they actually went
           through each of the attributes and actually showed
           programmatically how they captured that.  And that was
           unique and the staff found that really very helpful in
           our review.  That was another unique aspect.
                       MR. LEITCH:  Butch, I notice that there
           seem to me, at least, to be an unusually large number
           of RAIs associated with this.  Would you say that some
           of these four differences that you've just listed are
           primarily what caused this large number of RAIs?
                       MR. BURTON:  It was --
                       MR. LEITCH:  First of all, was there an
           unusually large number of RAIs?
                       MR. BURTON:  It was hard to judge.  We
           didn't go in to the review, because it was the first
           BWR.  We didn't go in with any preconceived notions of
           how many RAIs would be appropriate.
                       Obviously, we saw with the PWRs, because
           we had some familiarity with them, we expected the RAI
           account to drop which we pretty much saw.
                       If you compare the number of RAIs for
           Plant Hatch, we had more.  
                       DR. BONACA:  It seems to me on the same
           issue that many of them are tied to the ficklety on
           the part of the staff to ascertain if certain
           components were or were not part of the license.  In
           fact, in many cases it was more of a question of why
           is the component not in and then the answer was yes or
           no.  I mean in many cases the component was ins the
           scope.  So there was an issue with the ficklety of
           checking scoping?
                       MR. BURTON:  Yes.  I'd say the majority of
           the RAIs fell into two groups, one was as Dr. Bonaca
           mentioned because of the unique approach and the
           formatting of the application, there were a number of
           RAIs that were -- had to do with clarifications of
           things.  In the beginning, the staff had a little bit
           of trouble understanding how to navigate through the
           application.  And we had a number of RAIs that were
           related to that.
                       The second thing and what accounted for
           approximately one third of the total RAIs and there
           were some 400 and some odd RAIs, I can't remember the
           exact count, 428.  Approximately, one third of those
           had to do with -- I put up the vu-graph before of the
           assessment table and how they applied the 10
                       As I said, our guidance applies to 10
           attributes to each Aging Management Program.  In the
           initial submittal of the application, as I mentioned
           before, the 10 attributes were actually applied to a
           demonstration of adequate aging management.  So what
           happened was we had a lot of RAIs that came in very
           repetitive for each Aging Management Program to say
           what is the scope, what are the parameters being
           monitored, what is the monitoring and trending? 
           Because initially, we didn't see that clearly in the
           Aging Management Program descriptions.  So what you'll
           find if you go over the RAIs, you'll see, as I said,
           fully one third of them very repetitive in asking
           those kinds of questions.
                       Had we not asked those questions, and if
           we had not had the trouble with the navigational
           problems, the RAIs probably would have been in line
           with the previous applications.
                       MR. GRIMES:  This is Chris Grimes.  I
           would like to on a very gross basis compare the
           questions on Hatch with the Calvert Cliffs and Oconee. 
           Calvert Cliffs and Oconee were in the range of 430 to
           450.  And as Butch pointed out, by virtue of the
           packaging technique, we did end up with a lot of
           duplicative questions on Hatch.
                       And if you account for those, I'd say we
           were on about the same level as we were on Arkansas
           and we did -- I did feel as I looked through the
           feedback that we got from the applicants on the nature
           of the questions that there is evidence the process
           improved and that we're learning and to the extent
           that we learned some lessons in terms of communication
           techniques, those were fed back into the Improved
           Renewal Guidance for future applicants.  
                       So on a very gross basis, I'd say that I'm
           very comfortable that the level of questions for Hatch
           were not out of line for the first BWR.
                       MR. LEITCH:  Thank you.
                       MR. BURTON:  Now in terms of the
           comparison to some of the previous applications, those
           are really the major differences, primarily process. 
           But in terms of technical differences, we really did
           not see much because as I said, they used the same
           materials.  They generally operate in the same
           environments and so therefore we have the same aging
           effects.  So we really did not see much technically
                       That's pretty much it for my overview.  I
           wanted to answer any questions, any comments you may
           have and then after that, I'll turn it over to Mr.
           Baker from Southern Nuclear. 
                       Questions?  Comments?  Okay, I'll turn it
           over to Ray.
                       MR. BAKER:  Good morning.  Charles Pierce,
           who is the manager of the License Renewal Section at
           Southern Nuclear is going to do the background and
           introduction for our part of the presentation.
                       MR. PIERCE:  I just wanted to start by
           saying it is a pleasure to be here this morning before
           the ACRS Subcommittee and Ray and I are going to spend
           probably the next 45 minutes or so discussing our
           license renewal application with you.  I'm just going
           to start with more or less the background and Ray's
           going to get into some of the details.
                       For my part, I just wanted to open it up
           by saying that I think Ray will mention and I just
           wanted to mention for my purposes that I've been in
           nuclear power for about 20 years.  I started with some
           that probably the ACRS is very familiar.  I started my
           career in environmental qualification and moved on to
           a number of other areas and now I'm in license
           renewal.  So I began license renewal activities back
           in 1991-1992 time frame with the first rule, and so
           I've been working in license renewal ever since.
                       Southern Nuclear has also put a lot of
           resources into the license renewal through the years
           as well.  We've put a lot of time and effort into
           developing the revised rule and Southern Nuclear
           actually participated in the license renewal
           demonstration project with the NRC in 1996.
                       Next slide.
                       (Slide change.)
                       MR. BAKER:  I'm not going to go into any
           details on this next slide.  I think Butch covered an
           overview of the Hatch information and background
           adequately.  I'll just mention that I've always liked
           this picture with the rainbow overhead.  I think
           that's a nice touch.
                       MR. BARTON:  Is there a pot of gold at the
           end of it?
                       MR. PIERCE:  The renewal, right.  Next
                       (Slide change.)
                       MR. PIERCE:  With regard to some of the
           things that I just wanted to touch on here, Hatch was
           the first utility to effectively file an
           electronically formatted application and drawings.  I
           think the NRC found that very useful.  The application
           and drawings were hyperlinked for ease of use.  We
           also -- as we heard earlier, worked to develop an
           alternate application format and we filed that format
           using an early version of the standard application
                       The reason I mention that is because that
           standard application format effectively was developed
           between the NRC and industry in the last few months in
           the development of our application.  We had to do a
           significant rewrite, but we felt it was important to
           do so.  I think it benefitted both sides, the NRC and
           us, to go through that process.
                       We did follow in great detail the
           development of the BG&E and Duke processes as they
           went through their activities.  We actually had either
           directly attended almost every BG&E and Duke meeting
           here at the NRC or had contractors attend on our
           behalf and write detailed meeting minutes for us.  We
           followed their letters and docket interactions and we
           incorporated those activities into our application as
           we felt appropriate.
                       Finally, in the 1999, late 1999 time
           frame, as the application was nearing completion, we
           brought together a group of what I call key industry
           experts to perform a peer review of our application. 
           We actually brought with our internal resources and
           the industry experts, the review staff amounted to
           about 30 individuals, 25 and 30 individuals.
                       MR. BARTON:  Who are these industry
                       MR. PIERCE:  People like Bob Nickell who
           is the ASME president.  I don't know if you know Bill
           Denny, electrical -- he's the individual that worked
           at Ogden that helped develop the spaces approach in
           the early stages with -- that we applied.  I think
           everybody knows Jack Roe.  He used to work here at the
           NRC.  There were some structural integrity folks as
           well that supported us at that meeting.  So there were
           several people of that stature there, along with some
           individuals from individual utilities like PECO and so
           forth that actually reviewed our application.
                       And basically the review went along
           procedural and legal lines, mechanical, structural and
           electrical.  We basically had those four areas that
           were looked at.  We divided the group up, people up
           into different groups and actually had them look at
           the information in that light.  So we broke the
           application down in four different areas for their
           review.  And we incorporated the comments from that
           peer review as well.
                       So that is the background that I really
           wanted to go through here and now I'm going to turn it
           over to Ray and let him continue with some of the
           discussion, detailed discussion on our application.
                       DR. BONACA:  At some point I would be
           interested in hearing something about this functional
           approach rather than the system approach because it's
           unique for use, at least.  This is the first time we
           see that.
                       MR. BAKER:  I'll try to address that.
                       DR. BONACA:  To understand why you took
           that direction rather than the approach taken by the
           other applicants today.  It would be interesting.
                       MR. BAKER:  All right.  Good.  Thank you,
                       As I go through the presentation this
           morning, please feel free to interrupt and ask the
           questions as they occur and we'll endeavor to answer
           them to the extent that we have that knowledge here
                       My name is Ray Baker and let me say that
           I appreciate the opportunity to speak to you today on
           behalf of Plant Hatch.  I'd also like to thank the NRC
           staff for the hard work, for the professional and
           thorough review that's gone on to this point.  The
           fact that all the milestone dates have been met to
           this point indicates a significant effort on their
           part and getting the application to this point in the
           review process.
                       I first saw Plant Hatch as a brand new
           junior engineer right out of college in 1972.  At that
           time, Unit 1 was pretty much structurally complete. 
           Unit 2 was coming out of the ground.  So I've been
           involved with Hatch for a very long time.  My entire
           career of almost 30 years at Georgia Power and now
           Southern Nuclear has been associated with Hatch.  It
           pleases me that at this point I'm able to be involved
           in the re-licensing activities for the plant that I
           participated in the original licensing activities on
           some 30 years ago.
                       As Chuck noted in his comments we began
           discussions with the NRC License Renewal Branch
           regarding a suitable application format, actually
           fairly early in the review cycle of the Calvert Cliffs
           and Oconee applications and we -- and I believe along
           with the NRC staff were interested in finding ways to
           improve on the review process and we were encouraged
           to explore different approaches.  Chuck mentioned that
           somewhat in his presentation.
                       About six months, as I recall, prior to
           the scheduled submittal date for Hatch, we, that is,
           the industry, NEI and the NRC, began to settle on an
           early version of what has become known as the standard
           application format.  We agonized over the decision
           whether to convert at that stage in the application
           preparation, but finally we did choose to adapt the
           application to match the standard format to the extent
                       The principal impact produced by that
           format conversion was the production of summary table
           results and Sections 2 and 3.  
                       In retrospect I view that as a good
           decision to format, to change the format.  The summary
           table format is a clear and concise way to present a
           lot of information so I think that on balance, the
           format conversion resulted in an improved review and
           so again, I think it was a good decision.
                       Perhaps the one place where the Hatch
           application format is most noticeably different from
           the current standard format is in the presentation of
           programs.  Butch mentioned one aspect of that and we
           may talk a bit more about that later.  But the
           standard format assumes program descriptions will be
           provided in Appendix B.  The Hatch application that we
           provided originally placed those program descriptions
           in Appendix A which is generally called the FSAR
                       There was also additional significant
           information on how those various program elements fit
           together to demonstrate adequate aging management for
           each commodity group in our Appendix C.  The level of
           detail that you find by combining those two areas is
           really not significantly different from the level of
           detail you would expect in Appendix B.  They were just
           in several places.  So early in the review, we
           concluded based on feedback from the NRC that in order
           to facilitate that review, a stand-alone Appendix B
           would be useful and we provided that supplemental
           document as part of our responses to the early round
           of RAIs that came in.
                       (Slide change.)
                       MR. BAKER:  As you can see from this 
           vu-graph, the organization of the application does
           follow familiar lines.  Section 1 provides the general
           information that's specified pursuant to 10 CFR
           54.19(a) and (b).
                       Section 2 describes and justifies the
           scoping and screening methodology and the results,
           pursuant to 10 CFR 54.21(a)(1) and (2) and again,
           that's in a tabular format.
                       Section 3 describes the process we use to
           merge component groups into commodities.  And in
           addition, although not required by the regulation,
           it's useful and so we placed it here, a description of
           the Aging Management Review process that we employed. 
           Finally, Section 3 includes also in a tabular format
           the summary results of the Aging Management Reviews.
                       Section 4 presents the time-limited aging
           analyses and exemptions.  
                       Appendix A describes the programs and
           activities for managing aging.  It also contains a
           summary description of the Time-Limited Aging Analyses
           and these items are as specified in the rule.
                       Where Section 3 presents a tabular summary
           of the aging management results, Appendix C provides
           the meat of the application from our perspective.  The
           appendix is divided into two sections.  The first
           section systematically discusses combinations of
           fabrication, materials and external and internal
           environments as Butch mentioned.  This generic
           presentation identifies aging effects requiring
           management for each combination of materials and
           environment.  I will discuss that in more detail later
           in the presentation.
                       The second part of Appendix C presents
           more detailed summaries of the Hatch specific Aging
           Management Reviews so the first part of Appendix C is
           a generic evaluation of materials and environments and
           the second part of Appendix C is on a commodity by
           commodity basis, a more specific Aging Management
           Review and again, this is grouped by materials of
           fabrication and environments for component groups that
           we call commodities.  And I will describe the process
           for grouping those components in a few moments when I
           get to vu-graph 10.
                       These detailed summaries in Appendix C
           provide the linkage of programs and activities to
           aging effects associated with the commodities and in
           that way demonstrating adequate aging management for
           each commodity group.  That is our demonstrations were
           made in Appendix C.
                       And lastly Appendices D and E contain the
           environmental report supplement and the technical
           specifications changes required for their renewal term
                       MR. LEITCH:  Ray, just before you leave
           the introductory material, I had a question on page
           1.1-10. It says SNC requests a class 104 operating
           license for Plant Hatch 1 and a class 103 operating
           license for Unit 2.  I don't understand that
           terminology nor distinction there.  What's the
           distinction between a Class 104 and 103?
                       MR. BAKER:  This is, I believe, ancient
           history that goes back to the kind of operating
           license that was granted in the original term.
                       MR. LEITCH:  I see.
                       MR. BURTON:  In the very early days, so
           the Unit 1 license was a Class 104 as I believe you
           said, and the Unit 2, Class 103.  
                       Chuck, did you have more details on that?
                       MR. PIERCE:  The Atomic Energy Act, when
           it was promulgated specified basically two types of
           licenses.  One was called a research -- I forget the
           complete name.  It was a Class 104 license.  The other
           one was a production reactor which was a Class 103
                       Actually, if you go back to some of the
           earlier applications that had recently been approved,
           they were typically 104 licenses, but Hatch sort of
           was in that in between time where the plants were now
           moving to ask-informed receiving 103 licenses, so we
           have the difference in 103 and 104.
                       MR. LEITCH:  I guess then my question is
           primarily for the NRC.  Is that something we want to
                       MR. GRIMES:  This is Chris Grimes and I'll
           attempt to respond to that.  As a matter of fact, my
           recollection is that the original licenses were called
           Demonstration Power Reactors, DPR licenses.
                       MR. BAKER:  Right.
                       MR. GRIMES:  And practically speaking for
           the purpose of the safety evaluation, there is no
           difference in the way that the safety evaluation is
                       As a procedural matter, we've concluded
           that renewed licenses should maintain the same
           numbering scheme for simplicity of the way that we
           manage the licenses.  And so you'll find that in the
           information digest as it lists the historical
           milestones of each individual plant, their class is
           104 and 103 and it's legally important in terms of the
           basis for granting a license and it's nexus to the
           Atomic Energy Act.  But I think for your purpose, you
           won't see any distinction in the treatment. 
                       I do recall that during the conversion of
           the Plant Hatch to the improved standard tech specs
           that having two very different licensing bases, I mean
           Unit 1 was reviewed prior to the Standard Review Plan
           and Unit 2 was fundamentally standardized and in
           trying to merge those two licensing bases during the
           design basis reconstitution efforts and subsequent
           tech spec conversions, that was uniquely challenging,
           but I don't think the two different license types will
           impede you in any way.
                       MR. LEITCH:  Okay, thank you.  One other
           question on the introduction.  I noticed there are
           several owners in addition to Southern Nuclear but I
           didn't see percentage ownerships.  Are they clearly
           minority owners or what is the percentage of
                       MR. BAKER:  Southern -- Georgia Power
           Company is the majority owner of Plant Hatch by a few
           fractions of a percent.  A large minority stake is
           held by Oglethorpe Power Corporation and somewhat
           smaller percentages by the Municipal Electric
           Authority of Georgia and the City of Dalton.
                       MR. LEITCH:  Okay, thank you.  Those
           percentages are the same for both units?
                       MR. BAKER:  I believe for Hatch that is
           true.  It is different ownership percentages between
           Hatch and Ogle, but the other Georgia Power Company
           plant, but Plant Hatch is the same for both units.
                       MR. LEITCH:  Thank you.
                       MR. PIERCE:  The other point I'll mention
           with that is that the operations authority has
           invested in Southern Nuclear by Georgia Power Company
           and the co-owners.  So Southern Nuclear has filed this
           application on their behalf.
                       MR. LEITCH:  Thank you.
                       (Slide change.)
                       MR. BAKER:  So this is how the application
           is organized, and now I'd like to discuss the scoping
           and screening process we used.
                       We developed a comprehensive list of
           systems and structures and we identified functions for
           each system or structure on the list.  Each function
           was evaluated against the eight scoping criteria in 10
           CFR 54.4(a)(1), (2) and (3).  On this vu-graph we
           showed that engineering and licensing documents were
           used in the evaluation of identified functions against
           the three safety-related criteria of 10 CFR 54.4(a)(1)
           and also in the evaluation of functions against the
           criterion of 54.4(a)(2) which is the nonsafety-related
           that would prevent 
           safety-related functions.
                       And I would note that with regard to this
           criterion, all functions were evaluated against this
           criterion, not just the nonsafety-related functions. 
           We evaluated safety-related functions against the
           nonsafety-related function criterion as well.
                       (Slide change.)
                       MR. BAKER:  And in a similar manner,
           engineering and licensing documentation was used in
           the identification of functions relied on for
           compliance with our Commission regulations specified
           in 10 CFR 54.4(a)(3).  The four regulations that are
           applicable to Plant Hatch were EQ, ATLAS, station
           blackout and fire protection.  Since Plant Hatch is a
           BWR, pressurized thermal shock is not included in that
           Hatch is exempt from that regulation.
                       Three separate reviews were performed as
           a part of our scoping process.  The primary review was
           a system and structure-specific review.  To supplement
           the system-structure specific review, NRC Safety
           Evaluation Reports were reviewed to assure all
           functions relied on for compliance with the four
           Commission regulations were identified and scoped. 
           And in addition, we called on in-house experts for
           further assurance that all the functions relied on for
           compliance with the four regulations were identified
           and scoped.  These separate stand-alone reviews were
           conducted for additional assurance that the scoping
           relative to this criterion was complete and
                       (Slide change.)
                       MR. PIERCE:  As I noted on the previous
           vu-graph, we have used engineering and licensing
           documents to perform the function scoping.  The block
           on the left identifies some of the major document
           sources used.  Obviously, our Final Safety Analysis
           Report was used.  We also used our Equipment Location
           Index.  We call this the ELI.  It's an engineering
           database of components.  It's not a Q-list, but it
           does provide quality and seismic class information for
           the components that are listed in that document.
                       DR. BONACA:  Did you use also the 
                       MR. BAKER:  There is not a specific 
           Q-list per se at Plant Hatch.  This is the equivalent
           of that.
                       MR. PIERCE:  The equivalent Q-list at
           Plant Hatch is actually, you go back and I think look
           at some of the earlier letters to the NRC is actually
           the Safety Evaluation Documents which is listed as
                       MR. BAKER:  It's the Systems Evaluation
                       MR. BAKER:  The reason that we don't
           solely rely on the Equipment Location Index is that
           it's not a complete listing of components.  For
           example, pipe segments are not listed in that listing.
                       We used other documents.  Chuck mentioned
           the System Evaluation Document which does, in one of
           the appendices of it contain the listing of safety-
           related components.
                       You asked why function scoping and the
           Plant Hatch Maintenance Rule Manual was selected as a
           key document due to similarities between Maintenance
           Rule Scoping criteria and the License Renewal Scoping
           criteria.  At Plant Hatch Maintenance Rule Scoping was
           done on a functional basis.  The Maintenance Rule
           Scoping identified a large number of functions and
           then they scoped those functions based on the criteria
           applicable under the maintenance rule.
                       We were able to use that as a starting
           point to have a ready-made source for most of the
           functions that we identified in the course of our
           scoping review for license renewal.  And we recognized
           that there are differences in the criteria and one of
           the things that we did was to assess and reconcile the
           differences in results obtained by the maintenance
           rule scoping and our scoping review.  For example, the
           safety-related criteria are almost identical and so
           we're able to make substantial use of those, but other
           criteria are just not applicable in license renewal
                       So the set of functions that we identified
           using all of these documents, plus other sources, we
           did not restrict our reviewers to the set.  This was
           the beginning set of documents for each person to use
           as they were doing their scoping evaluations.  If
           their reviews led them into other information sources,
           we encouraged them to go to those sources to obtain
           that information.
                       So as a result, each function that was
           identified was evaluated against the eight scoping
           criteria as stated on the previous vu-graphs and any
           function that met one or more of the eight criteria
           was classified as being in scope.
                       In the language of the rule, these are the
           functions that are the intended functions.
                       DR. BONACA:  I guess where I've been
           trying to go was how did you assure that by this
           process you have addressed every safety-related
           component in the plant?  That's the first question of
           the rule.  So now you choose a function and approach,
           but you certainly want to verify that that is the
           outcome.  That's important because then all the other
           applicable components are those that support?
                       MR. BAKER:  That's correct.
                       DR. BONACA:  Essentially those functions. 
           How do you assure that you have the correspondence
           there and you included all those components?
                       MR. BAKER:  As Chuck noted the system
           evaluation document listing of the safety-related
           components was consulted and we made sure that every
           component in that listing is within at least one or
           more evaluation boundaries where we did the screening.
                       DR. BONACA:  Yes.  The reason for me
           asking these questions, I'll be open with this, is
           that I have reviewed the application in some detail
           and I had some trouble at the beginning in
           understanding what was in scope.  For example, I found
           things like Table 2.2.1, System F-16, fuel storage
           equipment not in scope.  But then I go around and I
           find F.16.01 storage racks and they are, I believe, in
                       And then there is a statement in a note
           that says retained for continuated purposes.  So I
           didn't understand whether it -- and that was under a
           different function.  I could not trace it.  So I was
           left with some questions in my mind about what does it
           mean to retain for continuated purpose?  It is either
           in scope or it is not in scope, I guess.  I'm looking
           at it simplistically, but --
                       MR. BAKER:  You're right.
                       DR. BONACA:  And it was a little bit
           difficult and I guess so you're saying, your
           circumstances for the plant, whatever, led you not to
           use the approach that other system plants were using
           at the same time which is because all the ones we have
           seen today, they use the system approach.
                       MR. BAKER:  They used the system approach
           and I think everybody is familiar with that approach
           and comfortable with that approach.
                       DR. BONACA:  Yes.
                       MR. BAKER:  And as Butch mentioned during
           the review process early on, I believe that did lead
           to some difficulty in getting the reviews started.  In
           retrospect, that's an area that is a little more
           complicated perhaps than first appeared.
                       One of the things that we did do though is
           to generate the evaluation boundary drawings and try
           to provide those as an adjunct to the application so
           that if there was a question about a particular
           component, those drawings could be consulted to say is
           it within an evaluation boundary or is it not.  And on
           that basis if it shows up outside any evaluation
           boundary, then the conclusion was that it was not in
                       DR. BONACA:  Yes.  Now the staff, I
           understand, we'll hear later, they audited the standby
           liquid control system, the high-pressure coolant
           injection system and the service water system and you
           found --
                       MR. BURTON:  Yes.  I was going to talk
           about that a little bit later.  It's part of the
           scoping inspection, went through some of that.
                       DR. BONACA:  Okay, all right.
                       MR. LEITCH:  I guess I had a similar
           navigational problem in my review.  Perhaps you could
           just help me with this.  Table 2.2-1, the first two
           lines on there, A70 and A71, analog transmitter trip
           system and nuclear steam supply shutoff and then for
           in scope it says yes for both of those items.
                       And the third one is reactor assembly,
           B11.  So then I went back to 2.3-1 and I find the
           reactor assembly and then it seemed like all the
           others I found in this mechanical screening results,
           but I don't find A70 and A71.  I just had a little
           trouble understanding what happened to this.
                       MR. PIERCE:  Okay.  And I'd have to --
                       MR. BAKER:  Chuck has the application.
                       MR. PIERCE:  I have the application in
           front of me.  B11 is mechanical system and as such
           hit's listed under the mechanical system screening
                       A70 and A71 are more directly related to
           an electrical.  You should see those --
                       MR. BAKER:  I would expect that this kind
           of navigational difficulty is really related to the
           conversion format effort that we went through to try
           to put this into a standard format relatively late in
           the process and I believe that even for us, sometimes
           we have to look to see what part, whether it was
           mechanical, electrical or civil, any particular item
           was placed in because sometimes they are somewhat
                       MR. LEITCH:  In the SER, those first two
           items are listed under electrical.
                       MR. BAKER:  Yes, electrical.  Those first
           two items are electrical, yes.
                       MR. PIERCE:  The electrical system because
           of the implementation of the spaces approach doesn't
           have the same component discussions in that same
           section as mechanicals do.  That's why you don't see
           it there.
                       MR. LEITCH:  Okay.  So these two systems
           are in scope, but then did they -- how do I find out
           whether they screened out or not?
                       MR. BAKER:  The electrical approach that
           we used is the same as was used by Oconee and ANO, so
           most electrical components, of course, are active in
           screen out and what you're left with is the same set
           of the passive long-lived electrical components that
           the other plants had.
                       MR. LEITCH:  Yes.  I would expect that
           they would screen out.
                       MR. BAKER:  Yes, and it was a plant-wide
           spaces approach that was used.
                       MR. LEITCH:  Okay, thanks.
                       MR. BAKER:  Okay.  So the output from the
           scoping review was a set of intended functions which
           are the, as we discussed, the end scope functions. 
           These functions and again, this was a part of the
           uniqueness that was described, cross over traditional
           system boundaries and we allowed the function to go
           where it naturally goes and the best example of that
           function that crosses traditional system boundaries
           would be a containment isolation function which would
           be the active closing all lines and penetrations of
                       In our plant nomenclature, that's C61, but
           you find that that applies to components in many, many
           systems.  Every line that penetrates containment with
           isolation valves has a part of that story, but the
           function went regardless of system designation.  And
           so, as a result there's some overlap of these
           functions and you find some components showing up in
           multiple functions.
                       DR. BONACA:  Well, in part, it's because
           those, some components have multiple functions.
                       MR. BAKER:  That's right.
                       DR. BONACA:  And in your approach, you
           really identify a main function for it.
                       MR. BAKER:  Yes.
                       DR. BONACA:  And you followed through with
           that approach.  Okay, but I understand now the example
           of the containment is a good one.
                       MR. BAKER:  Yes, okay.  So I would know
           that while these functional boundaries cross the
           traditional system boundaries, all components that are
           required to perform or support the function once it's
           identified as in scope are in scope regardless of the
           system nomenclature.  So a B21 function could have and
           I'm just saying this hypothetically, an E11 component
           supporting it.
                       As an aid to the screening of the
           mechanical components, evaluation boundaries were
           produced for each in scope function.  Mechanical
           components within the evaluation boundaries were
           screened to identify those subject to aging management
                       The screening criteria used were those
           contained in 10 CFR 54.21(a)91)(i) and (ii), that is
           we screened for the passive long-lived components. 
           Within each evaluation boundary we grouped the like
           components with similar environments.  For example,
           within an evaluation boundary, all stainless steel
           valves with a demineralized water environment would be
           identified as a component group.
                       Another component group within the same
           boundary might be carbon steel valves with a
           demineralized water environment and another might be
           stainless steel pipe and so on.  Each component group
           within an evaluation boundary was designated as active
           or passive and as long or short lived.  
                       For review efficiency we performed
           additional evaluations during this stage of the
           process.  Rather than revisiting each component group
           again later, during the Aging Management Review
           process we assigned component functions and identified
           materials of fabrication and the internal and external
           environments for each component group during the
           screening step.  It was just for a matter of
                       The active-passive determinations for each
           component group were based on the original component
           list, arrived at from discussions between NEI and NRC
           and the NEI 95-10 document.
                       During our review, we created additional
           component types and assigned active-passive
           determinations based on similarity to other components
           or specific NRC guidance because during the process
           resolution was achieved on some components that in the
           original NEI 95-10 list has an asterisk.  That
           resolution was achieved during the process and we
           applied that NRC guidance to those.
                       Long list components were those not
           subject to periodic replacement based on qualified
           life.  By repeating this screening process for each
           evaluation boundary, we produced nearly 2,000
           component groups.  These component groups were then
           consolidated into commodities prior to performing the
           Aging Management Reviews.
                       (Slide change.)
                       MR. BAKER:  This is a figure from the
           application.  This figure illustrates the process used
           to consolidate component groups into commodity groups. 
           In this example, we start with two systems that are
           very similar from a materials and environment
           perspective, the high-pressure coolant injection
           system and the reactor core isolation cooling system,
           E41 and E51 in the Plant Hatch system designation. 
           Several in-scope functions may be primarily associated
           with system E-41 HPCI and I've just for illustration
           purposes indicated that there are four functions here
           and similarly, that there would be four functions for
           in-scope functions for E51.  In fact, that's not the
           case.  It's just for illustration purposes.
                       As I described on the previous vu-graph an
           evaluation boundary then is established for each of
           the in-scope functions.  And the components are
           screened into component groups.
                       Thus, on the third level, which is this
           level here, you see examples of stainless steel piping
           and stainless steel valves and as I said, the
           environments associated with each component group were
           identified for convenience during the screening step,
           so we have that information developed here.  For
           simplicity, we only showed demineralized water as an
           environment on this vu-graph.
                       But you can visualize component groups of
           stainless steel piping, demin. water, stainless steel
           valves, demin. water, from the evaluation of
           boundaries developed out of this E41 path and
           similarly, out of the E51 path.  And obviously, other
           groupings also exist due to different materials,
           components and environments.  This example is only
           intended to show the process and it's complex enough
           without adding the additional clutter of other
           materials and environments.
                       The heavy line across the middle of the
           page in this example is adjacent to the examine
           environment and materials label.  This pictorially
           represents the output of the screening step.  At this
           point, each component type, for example, stainless
           steel piping associated with E41 function 1 is a
           component group because it has a material and
           environment associated with it.  So I have a component
           group of stainless steel piping, demin. water at this
                       Subsequent to screening, but prior to
           performing the Aging Management Reviews, we further
           consolidated the groupings by collecting like
           component groups associated with all in-scope
           functions into commodity groups.  That is, all
           component groups having the same materials and
           environments were collected into a single commodity
           group and the example here shows that being collected
           into a commodity group of various stainless steel
           components with a demin. water environment.
                       This commodity grouping was performed to
           fully utilize a review and evaluation process that
           systematically evaluated research information and
           industry operating experience.  Based on those
           evaluations, it was possible to identify for each
           combination of materials and environment, a set of
           aging effects that might be detrimental.
                       DR. BONACA:  Did you use the GALL 2
           report?  Because in draft 4 there is a lot of
           information there.
                       MR. BAKER:  It was under development and
           actually we were observing and then watching the
           process, but we did not -- we were not able to make
           use of it during the development of ours.  But I will
           note that a number of the things that you see in this
           approach are similar to processes that you saw in some
           of the early development work of the GALL.
                       DR. BONACA:  Okay.
                       (Slide change.)
                       MR. BAKER:  So based on the process
           described each structure or component subject to Aging
           Management Review was included in one or more in-house
           reviews.  The Aging Management Reviews were performed
           on a commodity group basis and a total 112 Aging
           Management Reviews were performed, 96 mechanical
           reviews, 9 civil structural reviews, 5 electrical
           reviews and 2 reviews performed by our NSSS vendor,
                       The box in the upper right hand of this
           vu-graph depicts that aging effects requiring
           management were determined systematically for each
           commodity group from the set of potentially
           detrimental aging effects identified in the generic
                       I mentioned this generic evaluation
           earlier when I was describing the application format. 
           This evaluation is summarized in Appendix C1 of the
           Hatch application and it's based on work that was
           performed initially in support of the Oconee
           application and that's subsequently been used by ANO
           and Hatch and this is now an EPRI report and is being
           used by other licensees as they prepare their
           applications for submittal.  It consists of an
           extensive review of industry literature to identify
           potential aging effects for various materials and
           environments of interest and nuclear power plants. 
           The resultant information is systematically arranged
           into flow charts that can be used by qualified
           engineers in evaluating the license renewal commodity
                       NRC Generic Communications formed a part
           of the industry literature examined and synthesized. 
           In this manner, the industry operating experience is
           captured.  Plant-specific operating experiences also
           reviewed during performance of the Aging Management
           Reviews to validate the determinations of aging
           effects requiring management specifically for Plant
                       So the output of the tool is a set of
           possible or potential aging effects for any
           combination of environments and materials as an
           engineer would work through the flow charts.  And
           based on the review of the summary discussion in the
           report and a review of the plant specific operating
           experience and the review of other technical
           literature that the engineer may choose to go to, the
           engineer would then make an evaluation and
           determination of whether an aging effect that might
           occur would be an aging effect that would require
           management during the renewal term.
                       The box in the upper left hand of this vu-
           graph depicts the assessment of aging management
           activities already in place, based on a survey of
           plant and support organization procedures.  If
           necessary, program enhancements were proposed or new
           programs or activities identified.  Appropriate
           program coverage for the structures or components
           comprising each commodity group was identified or
           established.  And I would -- as you noted earlier, Dr.
           Bonaca, this process is similar to what you see in
           some of the GALL work.
                       The demonstration of adequate aging
           management is made for each commodity group by the
           combination of programs or activities credited with
           managing each aging effect for each commodity group. 
           The combination of aging management activity selected
           in an aging management review had to address all 10
           attributes we established as descriptive of an
           adequate aging management program.  The program
           attributes we chose are the same as those identified
           in the draft standard review plan for license renewal
           and Butch showed you a vu-graph of one table and how
           we assessed the programmatic coverage.  There is a
           table like that for every commodity group for every
           aging effect that was identified as requiring aging
                       As I said a moment ago, the generic
           identification of potentially detrimental aging
           effects was based, in part, on the review of NRC
           Generic Communications.  So when all the AMRs had been
           completed at the end, we conducted another review of
           the Generic Communications that had been issued
           subsequent to the initial review and this served to
           validate that all potential aging effects were
           addressed by the process.
                       (Slide change.)
                       MR. BAKER:  The output from the Aging
           Management Review is programs, programs and
                       DR. BONACA:  These programs you are going
           to present, are they the existing one, or are they the
           enhanced one, part of this?
                       MR. BAKER:  This is the presentation that
           I show here is a combination of existing enhanced and
                       DR. BONACA:  Okay, because I mean your
           application shows five existing, five enhanced
           programs and seven new programs.  But then there was
           an interaction with the staff and I believe there was
           a request by the staff for an additional 
           one-time inspection.
                       I would like at some point anyway to have
           a summary of the end of your presentation of where you
           stand right now insofar as enhanced programs and the
           one-time inspections or the new programs because I'm
           using application as a basis.  I think there have been
           some changes there?
                       MR. BAKER:  Yes sir.
                       MR. GRIMES:  Dr. Bonaca, this is Chris
           Grimes.  I'd also like to suggest that you be very
           careful about your accounting because the resolution
           of open items might end up changing the results.
                       MR. BAKER:  Right.
                       MR. GRIMES:  And we have -- we have
           promised to come back for the full committee meeting
           and the discussion of the improved renewal guidance
           and do the best that we can to do a consistent
           accounting of one-time inspections across all of the
           renewal applications.
                       DR. BONACA:  Yes, that is exactly why I
           was asking that question, so there is some flux going
                       This is more -- accounting is purely on
           the perspective we see applications coming in.  We see
           one-time inspections decreasing in number.  We're
           trying to learn as a committee where the industry is
           going and why some of these programs are not necessary
           any more.  In some cases, we understand and in others,
           we don't.  Also, it gives us an idea of what
           additional burden license renewal imposes on
           applicants.  And so that's why I asked that question.
                       MR. BAKER:  All right.  This vu-graph does
           not break it down into existing, enhanced or new, but
           I will address that in just a moment.
                       We have identified 30 programs or
           activities that will be relied on in the renewal term
           to adequately manage aging effects for the 
           in-scope structures and components.  
                       On this vu-graph I depict two types of
           programs and activities.  In these examples, we credit
           seven different chemistry activities and six different
           regulation-driven programs.  
                       (Slide change.)
                       MR. BAKER:  On the next vu-graph we have
           designated programs to implement the BWRVIP activities
           which Robin discussed with you yesterday afternoon and
           RPV monitoring.  In addition, 11 plant-specific
           programs or activities are credited for managing aging
           in the renewal term.
                       (Slide change.)
                       MR. BAKER:  And then finally on the next
           vu-graph, I illustrate four new one-time confirmatory
           inspections that we are crediting.  
                       Now another way to describe these programs
           would be 17 existing programs or activities that
           required little or no enhancement; 5 enhanced programs
           or activities; and 8 new programs or activities, half
           of which are these new one-time confirmatory
           inspections.  The reason that there's a difference in
           the number from what you said of 7 and what I said is
           8 is we have agreed to provide a 
           non-EQ cable monitoring program that will be a 30th
           program and so it shows up in that listing.
                       The distinction of existing and enhanced,
           I think is somewhat a blurred line as well because
           virtually every program will be touched and then some
           small changes made to it, but that doesn't necessarily
           rise to the level of being an enhanced program,
           enhanced in our perspective here I think means
           significantly altered.
                       DR. SHACK:  As I'm looking through your
           application, it seemed to me that although you're on
           hydrogen water chemistry, as hard as I looked through
           the application, I think I found it mentioned once and
           I assume that means that you don't think you're taking
           credit for hydrogen water chemistry, that you could
           justify the extension without it, even though you have
           chosen to implement it.  Is that a correct
           interpretation of the way you've written the
                       MR. BAKER:  That's correct, yes.  And in
           fact, the EPRI Water Chemistry Guidelines that we do
           credit have provisions for both the normal water
           chemistry regime and the hydrogen water chemistry
           regime and so as a matter of our operating flexibility
           you would want to maintain the ability to periodically
           for maintenance purposes or whatever other reason take
           the plant into a normal water chemistry regime
           temporarily while you affected those activities. 
           Certainly, obviously, our intent and desire based on
           other considerations is to operate within the regime
           that is consistent with the BWRVIP guidance in this
                       Robin, did you have anything more to add
           on that?
                       MR. DYLE:  Bill, I guess another way to
           look at it is we didn't want the HWC to be a condition
           of the relicensing process, but we absolutely intend
           to use it and because that program is structured for
           normal or HWC, if for some reason we had to stop using
           the hydrogen injection, we would still have the
           ability to manage the VIP program and do the
           inspections because it's structured for either option. 
           So we simply chose not to take credit in the
           application for it.  But we fully intend to use it. 
           Once you invest that amount of money to protect the
           plant, it doesn't seem reasonable to stop.
                       DR. SHACK:  Okay, and your argument would
           be that, in fact, your inspection program would then
           flip back and forth to cover the -- if and some reason
           you ever stopped.
                       MR. DYLE:  Right.  If for some reason we
           stopped hydrogen, we'd have to go to the normal water
           chemistry inspection programs.  As we discussed
           yesterday, there's currently only two programs that
           we've got that HWC built in.  The rest of them we're
           waiting on approval of VIP 72 and resolution of issues
           with the staff before we broaden the scope of that
           credit for HWC.
                       DR. UHRIG:  A question on the non-EQ cable
           management program.  This would be the medium voltage
           and high voltage cables primarily since most of the
           low voltage -- maybe the low voltage cables are EQ?
                       MR. BAKER:  Let me ask Jeff Mulvehill of
           our staff to discuss the scope of that program.
                       MR. MULVEHILL:  This is Jeff Mulvehill of
           Southern Nuclear.  The program would actually all
           types of cables.  It will be mainly focused on
           identifying adverse localized environments or places
           where the cable could be experiencing accelerated
           aging.  In normal plant environments, the cable is
           going to last 60 years.  That's what our analysis told
                       So it's mainly going to be focused on
           identifying those areas where cable --
                       DR. UHRIG:  This is the visual and
           inspection time?
                       MR. MULVEHILL:  That's correct.
                       DR. UHRIG:  And some physical
                       MR. MULVEHILL:  We have not identified in
           the answer to the REI the exact test that we'll use at
           that point.  Those types of things are still evolving.
                       MR. BAKER:  Jeff, is this consistent with
           the work that's being done in the industry electrical
           group working in the GALL arena?  Is that correct?
                       MR. MULVEHILL:  Our cable mirrors the
           program in the GALL Report.
                       MR. BAKER:  Thank you.
                       MR. BARTON:  Under the new NRC assessment
           process, what's the NRC's assessment of your
           corrective action program?
                       MR. BAKER:  Butch, do you want to speak to
                       MR. BURTON:  I'll take a crack at that. 
           I have to run back and look at the color.
                       MR. BARTON:  Basically, that's all --
                       MR. BURTON:  I don't know that we've got
           the results, but I know where the chart is posted and
           at the break I'll run back and check it.
                       MR. BAKER:  So in all, these 30 programs
           that I've put up on these three vu-graphs provide the
           attributes necessary to manage the aging effects that
           are identified for in-scope structures and components
           during the renewal term.
                       (Slide change.)
                       MR. BAKER:  Finally, I'd like to describe
           our process for identifying Time-Limited Aging
           Analysis.  The regulations provide six criteria, all
           of which must be met in order for a calculation or an
           analysis to be considered a Time-Limited Aging
                       As you can see on this vu-graph, we
           compiled a list of calculations to broadly include any
           with a time-limited nature.  Because of the large
           number of calculations, more than 8,300, we initially
           screened them using the time-limited nature of the
           calculation criterion.
                       Only those calculations that passed this
           first test were further screened in more detail using
           the remaining five TLAA criteria.  More than 1,200
           calculations passed this initial screening and more
           than 900 met all 6 criteria.
                       In addition to the review of calculations,
           a separate CLB review was performed to assure all
           potential TLAAs were evaluated.  In other words, we
           did a word search of our FSAR and other documents to
           try to find things that might also appear to be a TLAA
           and deal with those.
                       (Slide change.)
                       MR. BAKER:  And so the final view-graph
           that I have in this part of the presentation is this
           view-graph identifies the TLAAs for Plant Hatch that
           were identified using the screening process that I
           described.  They are fatigue, corrosion allowance, EQ,
           containment penetration pressurization analysis, RTNDT,
           upper shield energy and an analysis of a technical
           alternative to a code required inspection of RPV
           circumferential welds.  
                       The way it's broken out in the application
           is a little different.  I've combined a couple of them
           in the first bullet.
                       DR. BONACA:  In the application you have
           identified them?
                       MR. BAKER:  Right, and the last one, I
           think, we're not -- is not a TLAA based on further
           discussion.  That was in the application.  This was
           the MSIV cycle items.
                       DR. BONACA:  So, okay, the stress analysis
           for thermal fatigue.  Okay.
                       MR. BAKER:  Yes.
                       DR. BONACA:  Which one did you combine?
                       MR. BAKER:  The first one, stress
           analyses, I think is broken out as two items in the
                       That concludes my part of the
           presentation.  I'd be happy to answer any other
           questions if there are any.
                       If not, I'll turn it back to Butch.
                       DR. BONACA:  Well, I have some questions
           about some of this.  Maybe I'll wait for the NRC SER
           discussion because I have some questions.
                       MR. BAKER:  Okay.
                       MR. BURTON:  I guess we have a couple of
           options at this point.  Normally, according to the
           agenda, we'd be taking a break.  
                       DR. BONACA:  Why don't we do that.
                       MR. BURTON:  We're ahead of scheduled, do
           you want to do that?
                       DR. BONACA:  We're ahead of schedule a
           bit, but I think the best thing to do is to break now
           and then to start the NRC presentation after that.
                       So let's resume again at 10 o'clock.
                       (Off the record.)
                       DR. BONACA:  Okay, we resume the meeting
           now with the presentation by the NRC staff.
                       MR. BURTON:  Thank you, Dr. Bonaca.  What
           we're going to do now is we're going to start through
           the Safety Evaluation Report and talk a little bit
           about some of the results that the staff has as well
           as a brief discussion of some of the open items that
           are on the table.
                       Now one of the things that -- the way I
           had planned to do this was I wasn't going to go into
           a whole lot of detail if you didn't want me to, so at
           the appropriate times, please feel free to stop me. 
                       We have the appropriate staff members off
           to the side who will be able to handle any of the
           tough questions that I can't.  So let's get started.
                       Starting with scoping and screening,
           Section 2.  In Section 2.1 in both the application and
           the SER is where methodology is discussed and as Mr.
           Baker pointed out in the last session, Southern
           Nuclear scoped at the function level.  In other words,
           they looked at each system, identified all of the
           functions for the system and then took each function
           and ran it through a series of screens.  And when I
           say that, what I mean is a series of eight questions
           to basically see whether it meets the scoping criteria
           as to whether it's safety related, nonsafety related,
           whose failure could impact safety-related function and
           needed for any of the four out of five regulated
                       And anything that's -- in answer to any of
           those questions, anything that was a yes was
           considered an intended function and brought in scope.
                       Screened at the component level.  Once
           they identified the in-scope functions, then they
           looked at components in each system that were required
           to meet those functions.  And as Mr. Baker said
           earlier, along with the submittal of the application,
           they also provided us with the evaluation boundary
           drawings which was extremely helpful to the staff. 
           Basically, what they did was they took PNIDs and color
           coded them to help show us exactly where the
           boundaries were for each function.
                       DR. SHACK:  Was that in response to an RAI
           or was that part of the application?
                       MR. BURTON:  The drawings are not
           technically part of the application, but they were
           provided to us with the application.  It wasn't in
           response to an RAI.  Those turned out to be very
           helpful because as was mentioned in the last session
           and for some of you also, the staff, like you,
           experienced some what we call navigation problems.
                       DR. BONACA:  Those are not part of the
           application.  I imagine they will be retained by the
                       MR. BAKER:  Yes, that's correct.
                       DR. BONACA:  So the traceability can
           always be verified for any issue.
                       DR. SHACK:  What is the documentation look
           like when you go back and you try to pull the string
           to find out how they went through the screening
           process with the eight criterion.  Is there a
           checklist?  What do you actually see when you go back
           and you inspect?
                       MR. BURTON:  It's actually interesting. 
           Let me put this up.  I'm actually going to explain it
           to you in reverse.
                       DR. SHACK:  Everything's backwards for
           this application.
                       MR. BURTON:  Southern Nuclear started with
           the scoping and the screening and moved towards the
           Aging Management Programs.  One of the things that we
           did as a staff is we started at the Aging Management
           Programs and worked out way back to see what were the
           aspects of the Aging Management Programs, for
           instance, what was in the scope of the Aging
           Management Program and we would go back to the
           Appendix C tables to see whether or not all of that
           had been actually been captured and then from there we
           took a step further back.  So we actually worked in
           opposite directions and the fact that the application
           was electronic with point and click and it would take
           you to different places, we actually found that was
           one of the navigation problems that we had in that you
           could point and click in one direction, but it wasn't
           as easy to go in the other direction the way we were
           doing the review.  So yes, in answer to your question,
           what we actually did was we actually looked at the
           Aging Management Programs and looked at what, for
           instance, what was the scope of this particular Aging
           Management Program?  What commodity groups were
           included and then we would go from there to Appendix
           to confirm that there was proper cross referencing and
           things like that.  So it was actually -- it's actually
           like a fun jigsaw puzzle.  I guess that's how you
           would best put it.
                       DR. SHACK:  But that was on the up-front
           scoping.  That is, when you're trying, you have a
           function and you're trying to see whether it obeys the
           A criterion in the rule, how is that documented?  It's
           not in the application, but presumably when you go
           back and you do an inspection, you see some kind of
           records and what kind of record is actually produced?
                       MR. BURTON:  Actually, I guess the best
           way to explain that is to talk a little bit about what
           happened during the scoping inspection, because that
           is where we did some of the confirmative stuff.  Let
           me put this up real quick.
                       As I mentioned before, as part of the
           review process, we have three inspections that we do,
           the first being the scoping inspection which was
           actually scheduled for late October.  We actually did
           in early September.  What we did -- the purpose of
           that was to make sure that what we were seeing in the
           application in terms of what was identified as being
           in scope and what was identified as not being in scope
           was actually confirmed through looking at some of
           their source documents as Mr. Baker had identified
           before, the Maintenance Rule Scoping Manual, the
           Equipment Locator Index, things like that.  So the
           inspection team actually went down and we took a
           sampling of several systems and actually walked
           through the process and what we found was that as a
           practical matter, the scoping was actually done in
           accordance with the way it was described in their
           application and in accordance with the rule.  One of
           the things that we also found though was that the
           actual guidance documents at Southern Nuclear that was
           to explain step by step how to do it, it was results
           oriented as opposed to step by step, here's what you
           need to look at, things like that.  And we had
           identified that in the scoping reports, inspection
           report, that that was one of the areas that needed
           improvement which they subsequently did.  And in fact,
           the next time we visited them we took a second look at
           the procedures that provided the guidance for doing
           the scoping.  We found that it was much more in line
           with what we had expected.
                       So again, to answer your question, what we
           actually did was and again, a lot of it was driven
           because of some of the initial questions that we had
           as a result of navigational problems as we said well,
           let's sit down and actually take a look at this. 
           Let's look at the evaluation boundary drawings.  Let's
           see what functions are captured.  Let's look at the
           things that are in the boundary.  Let's look at the
           things that are out of the boundary.  Let's see how
           they documented that and see whether it is in line and
           appropriate.  And we found that as a practical matter,
           it was.
                       Did that answer --
                       DR. SHACK:  That helps.  The other
           question I had was this Maintenance Rules Scoping
           Manual which would sort of strike me as a secondary
           source kind of thing.  Somehow that meant that
           somebody went through an analysis, presumably from the
           FSAR, some more fundamental document and did that once
           and have other people used that as a kind of a primary
           source for this approach?
                       I assume that everybody has something like
           that.  They've done it as part of their maintenance
           rule implementation.
                       MR. BURTON:  Yeah, I really can't speak to
           how other applicants have done it.  All I can say is
           and again, correct me if I'm wrong, the Maintenance
           Rule Scoping Manual, when you looked at what was
           scoped in and you compared that to what we were
           looking at for license renewal, there was a
           significant amount of overlap, so I think from --
           again, correct me if I'm wrong, from Southern
           Nuclear's point of view, work smart, not hard.  Let's
           start with what we have and expand from there.
                       MR. BAKER:  Butch, just to amplify on that
           and actually maybe clarify a question that was asked
           during my session, Chuck mentioned that we
           participated in a demonstration project with the NRC
           back in the early days of license renewal and one of
           the things that we did in that demonstration was to
           present a full plant scoping which was done from a
           system orientation.  And the review at that time asked
           a number of very difficult questions related to
           comparing our results to maintenance rule scoping
           results and so we took out of that a task for
           ourselves to go back and redo the scoping oriented on
           functions, similar to the way that the maintenance
           rule scoping had been done.  And so that was the
           genesis of that.  In fact, the maintenance rule
           scoping that was done was an expert review panel kind
           of an approach at Plant Hatch.  You had a number of
           people that were assembled together that crossed the
           spectrum of experience, plant operations people,
           engineering personnel and so forth to cover everything
           from operating procedures to the FSAR in identifying
           the functions and then doing the scoping work in
           accordance with the maintenance rule.  And so that was
           really the genesis of that document's use for us in
           license renewal.  It was related to our experience in
           the demonstration that we did as well as having that
           ready made source of information available.
                       And I think, also in answer to your
           question, what you will find in-house is, on a
           computer data base a record for each function that was
           identified that answers for each of the eight criteria
           yes or no, in scope or not in scope as a result of any
           of those being a yes.  So the direct answer is, there
           is a data base that contains the results.
                       MR. BURTON:  And -- go on, I'm sorry.
                       MR. LEITCH:  I was going to bring up
           another issue.  I thought there was -- it seemed to me
           there were some unique problems associated with
           scoping and screening of skid-mounted equipment.  
                       MR. BURTON:  Yes.
                       MR. LEITCH:  Could you say a couple of
           words about that?
                       MR. BURTON:  That is, I believe, two 
           vu-graphs from now.
                       MR. LEITCH:  Okay, fine.
                       MR. BURTON:  I'll hold on to that one.
           But I do want to say that given some of the initial
           challenges that we had with the scoping portion of the
           application, the scoping inspection was real critical. 
           We made sure that all of the reviewers who were
           involved with the scoping had basically given us a
           list of tasks for the inspection team, in addition to
           the things that we had as part of our inspection plan
           and primarily, we did take a sampling of the systems
           and actually walked from the beginning of the
           development of the functions for that system and
           actually walked all the way through to see how they
           scoped it, how they established the evaluation
           boundaries and then ultimately how they did the
                       For the electrical portion, it was
           actually somewhat done in reverse as Mr. Baker had
           explained before.  For that, they had identified all
           of the electrical types, regardless, just all of them. 
           And then identified those that were passive and long-
           lived and then from that population identified those
           that met the scoping criteria.
                       DR. BONACA:  Now you said that you went in
           reverse, but I also saw in the SER that you reviewed
           resistance as I mentioned before.  So you went more in
           reverse, you went --
                       MR. BURTON:  Yes.  Well, those were the
           three.  The reverse process that I spoke about is what
           the reviewers pretty much did here at headquarters.
                       DR. BONACA:  And their review of two of
           those three systems showed everything that you would
           consider in scope was in scope?
                       MR. BURTON:  Yes, yes, yes.  Okay, one
           area that I know has come up with some of the previous
           applications is the issue of design-basis events and
           what population of events was actually considered in
           the development.
                       At the time that the application was
           submitted, Southern Nuclear was in the final stages of
           putting together what they call the Nuclear Safety
           Operational Analysis and that has subsequently been
           finalized and actually been incorporated into their
           FSAR, but at the time of the application, it was still
           in draft form.  One of the things that we did during
           the scoping inspection was to take a look at this
           analysis and what the analysis was was a comprehensive
           consideration of all the design basis events and as
           part of that, if you recall from the rule, one of the
           things that's done is on an annual basis there is an
           update to the application based on changes to any
           changes that may have taken place to the CLB.  What
           Southern Nuclear did was because it was in draft form
           at the time that the application was submitted, they
           did commit as part of that annual update to take a
           look at the results of that NSOA, Nuclear Safety
           Operational Analysis and to update the LRA based on
           any additional changes to the CLB that may have come
           up.  And they did that and I think as a result of that
           there was maybe one additional, the rod block monitor
           that actually came in scope as a result of that.  But
           as part of our inspection, we did take a look at that
           NSOA as to understand exactly what DBEs were
           considered in their evaluation.
                       As a result of our review of the scoping
           methodology, we did come up with one open item having
           to do with seismic II/I piping.  Seismic II/I piping
           current is not in scope.  The staff had a disagreement
           with Southern Nuclear about that.  We viewed seismic
           II/I piping as being part of the more general category
           of non-safety related SSCs whose failure could
           adversely, you know, the one scoping criteria.
                       From what Southern Nuclear has done is
           they've identified the seismic II/I piping and have
           taken the step of seismically supporting that and
           their point of view is that given that it is
           seismically supported, the fact that it could fail or
           fall on safety-related equipment is basically
           hypothetical at this point.  So it is one of the items
           that we have on the table and we are in continuing
           dialogues trying to resolve that.  So that is one of
           our open items.
                       MR. GRIMES:  Butch, and this is one of the
           appeal issues.  So for each of the open items that's
           on the agenda for the appeals session that we're going
           to have tomorrow, we'll identify those.
                       MR. BURTON:  Okay, that's right.  That is
           one of four appeal items and I'll point those out to
           you as we go.
                       DR. SHACK:  And what exactly does that
                       MR. BURTON:  Appeal?
                       DR. SHACK:  Yes.
                       MR. BURTON:  Good question.  Appeal items
           are open items where at least on the face of it the
           staff and the applicant are fairly far apart and what
           the license renewal process allows for is an appeal
           process.  The appeal process involves an airing of
           each side to -- I guess for lack of a better word, a
           panel.  The appeal meeting that we're going to be
           having tomorrow is basically at the Branch Chief level
           so what we'll have is a staff and Southern Nuclear
           each giving their view of the open item and why they
           feel the way they do and we'll have several Branch
           Chiefs and Chuck Pierce from Southern Nuclear who will
           sit and listen to both sides and question and dialogue
           and hopefully reach a resolution.  If not, the appeal
           process moves on where we will next schedule another
           meeting at the next higher management level and we
           will continue on through like that until we can reach
           a reasonable resolution.  That's what I mean when I
           say appeal process.
                       DR. SHACK:  Now was this used with the
           other application?  Somehow I don't recall hearing
           about it before.
                       MR. BURTON:  It's always --
                       MR. GRIMES:  The answer is yes.  We
           established this as part of the procedures for the
           conduct of the renewal review and it's consistent with
           the approach of the staff asks one round of questions
           and then drafts a safety evaluation with open items
           and then the resolution of the open items is either
           obvious by virtue of the staff's articulation of what
           needs to be resolved or the resolution is then
           appealed to successive levels of management and we use
           this technique for Calvert and Oconee and it was quite
                       Now for Arkansas, they had six open items,
           but there was only one appeal issue and that was on
           the scope of fire protection equipment.  And that
           issue ended up being resolved at the first appeal.  In
           the articulation of the issue, the staff and the
           applicant saw various lights and decided on a
                       And for Hatch, we've got four of the I
           believe it's 17 open items, Butch?
                       MR. BURTON:  Eighteen.
                       MR. GRIMES:  Eighteen open times.  Four of
           the 18, there's a dispute and we need to air the
           dispute in order to understand how the open item is
           going to be resolved.  If it's identified as an open
           item and we don't designate it as an appeal issue,
           then presumably you will gain some confidence that the
           staff and the applicant understand what the issue is
           and what it takes to get it resolved.
                       (Slide change.)
                       MR. BURTON:  Okay, moving on to plant
           level scoping results, Section 2.2 of the SER.  We did
           not have any open items, but I did want to take the
           opportunity to point out here and actually Dr. Bonaca
           had mentioned it in the last session.  One of the
           things that we found as the staff in reviewing, in
           particular, Table 2.2-1 which several of you have
           mentioned in the last session is that there were
           several instances where when you look at a system and
           all the functions that that system performs,
           obviously, we know that there are certain things that
           we know a certain system performs and in the
           particular case I was going to bring up was
           containment isolation.  We know, for instance, that
           main steam has a containment isolation function and
           yet when our reviewer looked at the Table 2.2-1, did
           not see that identified as one of the functions.  This
           is getting to what you were talking about before.  And
           so that naturally led to the question where is that
           function?  Why do you not have it there?  And in our
           dialogue with Southern Nuclear is when we came to
           understand that certain functions that cut across a
           number of systems, they chose to pull out and actually
           have it in its own place.  In this particular example,
           it turned out to be under C61.  But that's another
           navigational issue that the staff had had to deal
           with.  So that's what I mean when I say grouping of
           common system functions.  
                       (Slide change.)
                       MR. BURTON:  Section 2.3.1 of the SER was
           just an introduction.  And then we got into reactor
           and reactor coolant systems.  I've identified the four
           systems that make up this group.  Again, we found no
           open items.  We found that the scoping and screening
           were appropriate.  This is where we started to get
           into dialogue with them about some of the BWRVIPs and
           primarily many of the questions when we asked about
           why something not in scope and why it is or is not, we
           were referred back to some of the BWRVIP documents
           that would identify that this is not an event that we
           really think would happen and things like that and
           that's why you would not see it as a system or a
           component within a system that would have any aging
           effects that would requirement management.  And we
           found some of the references to VIP in this section.
                       MR. LEITCH:  There are a number of VIPs
           referenced that are not yet approved by the NRC.  How
           did you resolve that issue in your own mind?
                       MR. BURTON:  Yes, go ahead.
                       MR. ELLIOT:  Barry Elliot.  I was going to
           address that later, but even though some of the VIPs
           were not approved, we reviewed them and the reviews
           were far enough along that we could look into them and
           see how they applied to Hatch.  And some of our open
           items result from those reviews.  And I'm going to
           discuss that later on.
                       MR. LEITCH:  Okay, thank you.
                       MR. BURTON:  Let's see, where am I?  We're
           going to get to, Dr. Leitch, one of the things that I
           had asked you to hang on with me for a second.
                       (Slide change.)
                       MR. BURTON:  The next section involved the
           engineered safety feature systems.  There were eight
           of them and I have them listed here.  We did have a
           couple of open items that came out of that.  The
           first, scoping and screening of skid-mounted
           components for the hydrogen recombiners.  This is a
           complex assembly issue if any of you are familiar with
                       We wrestled with this issue of complex
           assemblies with Oconee and the emergency diesel
           generators.  At this point in the review, Southern
           Nuclear has committed to actually doing the scoping
           and screening in accordance with what was agreed to
           and is now in the SRP that came about as a result of
           the review of Oconee.
                       DR. BONACA:  And it's also in the NEI
           document, right?  There is addressing complex
           assemblies there.
                       MR. BURTON:  It does address complex
           assemblies.  From what I understand the latest
           revision of NEI 95-10 has made some modifications, but
           I believe it is still basically there with a few
           modifications, yeah.  So we are actually on our way to
           resolution on this one. 
                       The second issue, this is one of the
           issues that's going through the appeal meeting
           tomorrow.  Scoping and screening of housings for fans,
           dampers and heating and cooling coils for the standby
           gas treatment system.  This is actually going to come
           back again for a couple of systems in the next section
           for auxiliary systems.
                       What this involves is housings for active
           components.  Under license renewal, fans, dampers,
           these components are active.  The staff's question is
           that's fine, but what about the housings for these
           components?  We are looking at that similar to what is
           currently in NEI 95-10 where they make the distinction
           between valves and valve bodies or pumps and pump
           casings.  NEI 95-10 specifically identifies valve
           bodies and pump casings as being passive and rightly
           so.  The staff is saying in the same vein the housings
           for these active components are similarly, have
           similar functions in terms of pressure retention,
           structural integrity, things like that.  So this is
           another item that's on our appeal meeting for
           tomorrow, on the agenda for our appeal meeting.
                       MR. GRIMES:  Butch, if I may, in order for
           you to understand our terminology distinctions, the
           first is called the complex assembly issue and that
           has to do with how groups of equipment are treated
           with respect to potential passive functions and the
           second one is we refer to as a piece parts issue and
           it's not, again, it's not a new issue.  In fairness,
           from the applicant's perspective, it's how low do you
           go in terms of breaking active components looking for
           passive elements and we're going to hopefully learn
           some, another lesson in this exercise that will help
           us to clarify how you identify passive elements of
           active components.
                       DR. BONACA:  Yes.  This already, these
           issues were discussed already for the previous
                       MR. GRIMES:  Actually, not this particular
                       DR. BONACA:  I understand, but I believe
           that housing for these kind of components for other
           applications were included.
                       MR. GRIMES:  They didn't come up in the --
           this issue did not emerge in the previous reviews.
                       DR. BONACA:  Are they in scope for Oconee,
           for example?
                       MR. GRIMES:  I'm prejudiced to staff's
           findings.  We thought the previous applicants had
           treated the housings for ventilation system components
           as part of the ductwork.  And that's why it's at
           issue.  The applicant contends they didn't.  Before we
           go attack the other applicants, we're going to try to
           settle the matter on this application first.
                       DR. BONACA:  When I review this I thought
           that this issue, not in specific, but in general, but
           the components had been included.  That was my --
                       MR. BARTON:  That's the way I felt too.
                       DR. BONACA:  Now when you -- in the
           position of the staff, when you talk about, for
           example, the housing of a certain component, it
           identifies specifically a function for it and so
           you're recognizing other pressure attending function
           or obstruction contained in the function which is in
           this license renewal.
                       MR. GRIMES:  Correct.  In order for the
           staff to prevail in its position, there has to be a
           passive function that -- passive safety-related
           function that we're attempting to manage aging for.
                       DR. BONACA:  Okay, thank you.
                       MR. BURTON:  One thing I should have
           pointed out before I got into all of this is how we as
           the staff approach the scoping and screening reviews
           which we've done from Day 1 is that things that the
           applicant identifies as being within scope or being
           subject to an AMR, we don't really question that. 
           What we really focus on in our review are things that
           are not identified as being within scope or subject to
           an AMR to see if those were actually identified
           properly.  And in fact, back in Section 2.2 with the
           plant level scoping results, the primary effort for
           that portion of the review was to go through that
           Table 2.2-1 and actually look at the functions that
           were identified as not being in scope and see whether
           or not we agreed with that and we understood that.  So
           it's almost -- I don't know what you would call it, a
           negative consent kind of thing.  I don't know what
           you'd call that.  But that's how we worked through
                       (Slide change.)
                       MR. BURTON:  Section 2.3.4, auxiliary
           systems.  As you can see, we had 20 systems that were
           divvied up amongst our reviewers.
                       MR. BARTON:  Before you go past 2.3.4 are
           you going to talk about 2.3.4?
                       MR. BURTON:  No, it's in two slides.  I'm
           going to talk about it now.
                       MR. BARTON:  Okay.
                       (Slide change.)
                       MR. BURTON:  We did have some open items
           here too.  The first two are actually analogous to
           what we had in 2.3.3, the issue of complex assemblies,
           that diesel was another one where we had the same
                       DR. BONACA:  Is that being contested?
                       MR. BURTON:  No.  This is as I said
           before, they've agreed to do it like Oconee.
                       DR. BONACA:  All right.
                       MR. BURTON:  The second one here is the
           same housing issue, in addition to standby gas
           treatment in Section 2.3.3 it also applies to the HVAC
           systems for the Control Building, Outside Structures
           and Reactor Building.  So it comes up.  It's all
           captured in one open item.
                       DR. BONACA:  Sure.
                       MR. BURTON:  But it's actually identified
           in several different places.
                       A third open item in this section was
           scoping and screening of fire protection system in the
           radwaste building.  Initially, this was not captured
           as being in scope.  The staff went through the fire
           hazards analysis and disagreed with that being
           appropriate.  And I think at this point we have
           actually gone through and Southern Nuclear actually is
           going to bring this suppression system within scope.
                       MR. BARTON:  That resolves one of my
                       MR. BURTON:  Okay.
                       DR. BONACA:  I thought in addition to that
           was a proposal to have a one time inspection that the
           staff wants to see as a program, is it?
                       MR. BURTON:  That is going to come up in
           the discussion in Section 3 when we do the Aging
           Management Programs.  And understand that as with
           anything, if the final resolution is that something is
           going to be brought in scope, we're also going to be
           bringing in the Aging Management Review and any
           applicable Aging Management Programs and assessment of
           the effects, all the things that go along with
           bringing that in scope.
                       MR. LEITCH:  While you're on the auxiliary
           systems, I guess I was a little confused about the
           river water intake structure.  How is that done at
           Hatch?  Not the circulating water, but the 
           -- I don't know what they would call it, the RHR.
                       MR. BURTON:  I know, plant service water.
                       MR. LEITCH:  Plant service water.  Okay.
                       MR. BURTON:  Okay, let me talk a little
           bit about that.  Commodity-wise, what -- the way the
           application breaks down is they have an environment
           that they call raw water.  Raw water is made up
           actually of -- consists of two different entities. 
           One is river water from which -- which is the source
           for the plant service water.  Another one is well
           water which is used primarily for fire protection.  
           But they are both captured under the environment of
           raw water. 
                       So yeah, if you're asking about structural
           stuff, that comes up in Section 2.4.  But in terms of
           the actual service water and that environment and
           things like that, we actually have plant service water
           that actually captures that.
                       MR. LEITCH:  I guess my question is really
           the pathway that leads to the ultimate heat sink.  In
           other words, you've got the RHR heat exchanger that's
           cooled by plant service water.
                       MR. BURTON:  Oh no, I'm sorry.  Yeah, and
           I don't have it listed separately out here, but
           there's actually a plant service water and an RHR
           service water.
                       MR. BAKER:  Butch, if I could interject.
                       MR. BURTON:  Please.
                       MR. BAKER:  RHR service water doesn't have
           a separate designation in Plant Hatch's numbering
           scheme.  It's a part of RHR, so it shows up on the
           previous vu-graphs about the engineered safeguards
                       MR. LEITCH:  Okay, and what source does
           that RHR service water -- where does it take suction
                       MR. BAKER:  It's at the intake structure. 
           The intake structure is a common structure for both
           units.  It has both plant service water and RHR
           service water for each unit, specifically the Altamaha
                       MR. BURTON:  And it actually is called out
           separately as one of the titles for one of the Aging
           Management Programs.  We actually have PSW and RHR
           service water both what, chemistry and inspections.
                       MR. BARTON:  Leave that on there, Butch.
                 MR. BURTON:  Sure.
                       MR. BARTON:  Maybe some of my problems
           here are navigational also.  I haven't consulted a GPS
           on my boat that didn't help me.
                       Access door systems is talking about
           containment doors.  Within the reactor building there
           are also, I would imagine, fire barrier doors and I
           didn't see those covered under access doors although
           I find fire doors and their management under fire
           protection or is it not included at all in the
                       MR. BURTON:  Probably the best thing for
           me to do is let them explain how they did it and then
           I can turn it over to our reviewers.
                       MR. BAKER:  Fire doors are covered under
           the fire protection activities.  Some of the access
           doors may also be fire doors, so they may do double
                       MR. BURTON:  And the actual commodity
           group is actually structural steel when you go to the
           Section 3 tables.
                       MR. BARTON:  All right, and also in this
           section control rod drive system?  It's in this
           section some place.  Page 256.
                       Control rod drive system.  I couldn't find
           where the Aging Management Program is for the SCRAM
           discharge volume.
                       MR. BURTON:  Oh, oh, okay, okay.  That was
           actually -- I'm glad you said that because that helped
           clarify things for me.
                       The SCRAM --
                       MR. BARTON:  I'm glad it helped you.
                       MR. BURTON:  We actually, if you go into
           the SER, our scoping guy actually had a question about
           the SCRAM discharge volume and how that actually was
           captured, where is it, because it's not specifically
           identified.  You're right.  This is a navigational
           problem.  It's very typical of many of the issues that
           the staff had.
                       Now again, correct me if I'm wrong, but I
           recall that the SCRAM discharge volume was actually
           captured as piping, does that sound right?
                       MR. BARTON:  Yeah.
                       MR. BURTON:  It was actually captured as
           piping and we had a phone call about that which is
           documented in the SER.  I can point that out to you.
                       MR. BARTON:  See, my problem is I only had
           certain sections of the SER to review, so it may be
           some place else.
                       MR. BURTON:  That's an issue.  But I can
           show you where that is.  But that's very typical of
           some of the navigational issues that we had.
                       DR. BONACA:  In fact, on access doors, by
           the way, you had request for additional information on
           seals because you thought that they were not in scope
           and then the answer was they were in scope, but the
           reality they were not subject to AMR because they were
           replaced or repaired based on   the performance and
           conditions under the preventive maintenance
           procedures.  And you accepted that answer that says
           they are in scope.
                       That applies to any doors and seals, those
           that function as fire protection barriers?
                       MR. BAKER:  That's correct.  It is both
           the access doors, the fire barriers as well.
                       Those are -- all of the heavily traveled
           doors, especially see continuous use and require
           maintenance replacement of those seals.
                       MR. BARTON:  So they're covered under your
           preventive maintenance program?
                       MR. BAKER:  Yes.
                       MR. BARTON:  Cranes, hoists and elevators.
                       MR. BARTON:  You're going to be here a
                       MR. BARTON:  I can't find where reactor
           building, polar crane, well, that's not a polar crane. 
           The refueling crane, the 125 ton hook and the
           auxiliary hook, where in their program are they
           captured for tests?  Don't you check the hooks for 
           -- inspect them and do mag particle and crack checks
           or whatever?  Aren't they covered in your program some
           place?  You talk about the component, the structural
           steel and the crane, but how about the hooks? 
                       MR. BURTON:  I have to turn over to him
           for those specifics.  I'm not sure.
                       MR. BAKER:  The lifting function part of
           the crane was an active activity.  The scope of our
           review focused on preventing the crane from falling on
           the safety-related components.
                       MR. BARTON:  You don't care about dropping
           a load, just that the crane doesn't fall?
                       MR. BAKER:  Interestingly, the hatch
           refueling floor, the main crane, the 125 ton crane is
           a single failure proof crane with redundant rigging
           and breaking in the CLB.  It's probably unique in the
                       MR. GRIMES:  Actually, I'm not sure --
           this is Chris Grimes.  I'm not sure whether it's
           unique, but I recall there are certain elements, the
           design of cranes that include linnets and stops and
           administrative procedures to reduce the likelihood of
           dropped loads, but it's an interesting question in
           terms of the distinction between active and passive
           features and so we can explore that further for you. 
           But I don't know that it came up during the course of
           our review.
                       MR. BURTON:  I certainly know that NUREG
           0612 and 0554 for single failure proof, I know they
           have a lot of provisions for just that kind of thing
           and I'm sure as Mr. Baker would verify, I'm sure that
           in the evaluation of a lot of these, where does active
           end and passive begin is sometimes a question.  That's
           all I can say about that, but --
                       MR. BARTON:  Drywell pneumatic system?
                       MR. BURTON:  Okay.
                       MR. BARTON:  I can't where air receiver
           and drywell pneumatic nuclear boiler system
           accumulator are subject to AMR.  Are they someplace
           else or not in the program?
                       MR. BURTON:  That rings a bell as another
           navigational item and let me just double check that.
                       The reason why I'm saying that rings a
           bell is I think that that was a question that our
           reviewer asked about those kinds of things.  I know in
           several cases, I'm not sure whether drywell is one of
           them, but the issue of accumulators and tanks and how
           were they identified, because when you go to the table
                       MR. BARTON:  Air receiver is another
           example.  I can't find air receiver.  
                       MR. BURTON:  It's a tank.
                       MR. BARTON:  It's under tanks?
                       MR. BURTON:  Tanks.  And we had a number
           of things like that.
                       MR. BARTON:  All right.
                       MR. BURTON:  The questions you're asking
           are not unusual. I mean it's the exact same kind of
           questions the staff had.  Navigational questions.  Go
                       MR. BARTON:  The question on insulation. 
           It didn't -- I couldn't see where insulation within
           the drywell was subject to AMR.  Is there a specific
           reason for that or did I miss it?  You talk about
           insulation and what was in scope.  I didn't see
           anything within the drywell covered in that section.
                       MR. BURTON:  All right, I promised I
           wouldn't do this, the person who actually -- go ahead,
           if you want to --
                       MR. GRIMES:  Ray's volunteering to answer,
           so let's let him answer.
                       MR. BURTON:  Okay, go ahead, please.
                       MR. BAKER:  The insulation inside the
           drywell was initially scoped in during our review, but
           during the process before we submitted the
           application, Plant Hatch completed it's evaluation of
           ECCS suction strainer issues, clogging issues and
           we've determined based on the results of that that
           there was no intended function for the insulation
           inside the drywell and so we removed it from scope.
                       MR. BURTON:  Okay.
                       MR. BARTON:  The other system primary
           containment chill water, but the piping inside the
           drywell is covered in the program, but piping outside
           is not?  Is there a reason for that?
                       MR. BAKER:  The purpose of the piping to
           the extent that it's in scope is to form a part of the
           containment pressure boundaries, to closed-loop inside
           containment in that respect.  So the piping outside
           the isolation valves outside containment serves no
                       MR. BARTON:  This one is a little bit
           different than navigation.  The traveling water screen
           and trash racks system, the SER describes screen and
           racks must remain structurally intact during an
           accident, but not required to move.  
                       My question is based on this statement,
           the applicant did not include screen wash lines and
           motors and scope.  What happens to the service water
           flow as screens get plugged with debris during an
                       MR. BAKER:  There are two aspects.  You
           have the trash racks and you have the traveling water
                       MR. BARTON:  Right.
                       MR. BAKER:  As I understand our CLB, the
           structure, the intact structure part of that was to
           protect against something like a barge impact or other
           impacts from things on the river.  There is no
           indication of a problem with clogging due to the
           design of the structure and the bays, the way that
           that is arranged.  It just is not an issue.
                       MR. BARTON:  Then why do you have a screen
           wash system?
                       MR. BAKER:  That's an operational, as I
           understand it. 
                       MR. BARTON:  It's not to take care of
           grass or stuff that flows down a river after a storm
           which gets through the racks.  The smaller it gets
           through the racks and it can't plug your screens and
           it can't impact your service water flow?
                       That's an impossible scenario at Hatch?
                       MR. BAKER:  I would not say anything is
           impossible.  I don't know the detailed --
                       MR. BARTON:  I guess my question, why
           aren't the screens in the program?  It seems if you've
           got them and they're there to remove debris so you
           don't impact service water flow, I don't understand
           how you exclude that from the program.  That's my
                       MR. PIERCE:  Well, one other aspect of
           that and I'm not that familiar with the technical
           discussion that you're bringing up, but I do know that
           the CLB specifically states that the only credit being
           taken for the traveling screens is the structural
           aspects of it staying in place.  If you go back into
           our FSAR and look at that, that's specifically stated
           and I'd have to go back to my people and discuss the
           technical reasons of why that is.
                       MR. BARTON:  You may want to talk to
           people at Salem also.
                       MR. PIERCE:  We owe you one on that one. 
                       MR. BARTON:  Yes.  The condensate transfer
           system, pumps and piping are discussed as not being
           essential water sources for accident mitigation, but
           my question is aren't they a backup source and if
           they're a backup source why aren't they included in
           the program?
                       MR. BURTON:  Could you repeat?
                       MR. BARTON:  Condensate transfer system,
           pumps and piping, it's in the SER, says may not being
           essential water sources for accident mitigation, but
           my question is aren't they a backup source and if
           they're a backup source why aren't they included in
           the program?
                       MR. BAKER:  I don't believe they're a
           backup source.
                       MR. BARTON:  They're not a backup?
                       MR. BURTON:  The condensate transfer
           provides the transfer of demineralized water from the
           chemical plant to the condensate storage tank.
                       MR. GRIMES:  This is Chris Grimes and Mr.
           Barton makes a good point in terms of the scoping
           technique that's used for license renewal includes
           those things that are credited in the accident
           analysis as part of the current licensing basis. 
           Particularly in a BWR where there are so many
           overlapping ECCS capabilities, we only capture for the
           purpose of the Aging Management Review, those things
           that are explicitly credited as performing intended
           safety functions.  There are going to be a series of
           backup capabilities.  They might not be captured in
           the review because they are not explicitly treated or
           relied on in preventing or mitigating accidents in the
           current licensing basis.
                       MR. BARTON:  That's all I've got.
                       MR. BURTON:  So I guess to piggyback on
           what Chris said, the thing that has really come
           through with all of the applications is how -- what's
           really come through is how important it is to really
           know your CLB.  The better you know it, the better it
           is for all concerned.  
                       And we found that in particular where
           we've had problems like in fire protection, just the
           whole history of fire protection is that people have
           done a lot of different things with it and there have
           been all kinds of exemptions to things and the issue
           of the -- that I pointed out before about the fire
           suppression system and whether or not it was in scope. 
           Being able to track through exemptions and changes to
           the FHA and things like that speaks to the importance
           of really knowing and understanding your CLB.  And it
           has come up from time to time.
                       DR. BONACA:  Let me just propose that
           these are good questions.
                       MR. BARTON:  I'm done.
                       MR. BURTON:  These are very good
                       DR. BONACA:  Because it provides some
           comfort to the committee that we can trace back some
           of these issues although the navigation issues may be
                       Could we get maybe an answer next week?
                       MR. GRIMES:  Yes.  I've noted the -- Mr.
           Barton's questions.  And we are going to go back and
           explore each of those in terms of traceability for
           Hatch specifically and then all these questions about
           to what extent the current licensing bases capture
           these capabilities.  And I've got crane hooks, the air
           receivers, the intake design and the condensate
           storage tank water source.
                       Whether or not debris accumulation during
           an accident is considered as part of the design basis.
                       MR. BURTON:  Good, very good questions. 
           Okay.  Moving right along to steam and power
           conversation systems.
                       (Slide change.)
                       MR. BURTON:  Again, no open items.  When
           all was said and done we saw that the scoping and
           screening was proper.  We did have a question on main
           condenser and why it was actually captured in scope,
           but at Unit 2, main condenser is credited as a hold up
           volume during accidents, sort of played out things
           like that.  But no open items there.
                       Next we went into structures and
           structural components.
                       (Slide change.)
                       MR. BURTON:  We have 13 items in this
           category.  No open items.  Again, we had several
           requests for additional information.  Some of them
           were navigational in nature, but bottom line is once
           we understood where the applicant was going, we saw
           that they had actually scoped and screened
           appropriately, so we had no open items in this
                       The next section was electrical.
                       (Slide change.)
                       MR. BURTON:  Fourteen systems were
           identified in the application.  These first couple Dr.
           Leitch had already made mention of in terms of where
           you could find them and actually as you were looking
           in Section 2.3 you couldn't find them they were
           actually in Section 2.5 under electrical.  Again, no
           open items, given that electrical -- the electrical
           scoping and screening was actually sort of reversed of
           how it was done with the mechanical and civil.  They
           identified component types.  Identified those that
           were passive and long-lived, in that population,
           looked at the ones that actually met the scoping
                       That's pretty much what I have for Section
           2, the scoping and screening.  I've got to do list. 
           Any other comments, questions on any of this?
                       DR. BONACA:  I don't think so.  Any
                       MR. BURTON:  Okay, moving into Section 3,
           I'm actually going to have some of the lead reviewers
           actually discuss their sections, so I'll have them
           come up and try and clear some of this out of the way.
                       MR. GRIMES:  While Butch is doing a set
           up, I think this might be an appropriate time to
           respond to Mr. Barton's question about the Quality
           Assurance Program and Rob, did you find --
                       MR. ELLIOTT:  I couldn't find it on my 
                       MR. GRIMES:  Okay, couldn't find it on the
           web, but the latest posted chart outside Sam Collins'
           office of the Reactor Oversight Program is dated
           January 25th and it shows to all of the performance
           indicators for Hatch Units 1 and 2 are green, except
           for one category and the EP03 category is designated
           as unique, so it's not color coded for Hatch.  So
           they're green across the board on the performance
                       For the inspection findings, there are
           seven categories of inspection findings and some have
           findings for one unit, but not the other.  There are
           five greens on the chart for the inspection findings
           and nine no finding areas.  So all of the oversight
           indicators for Plant Hatch are in the green.
                       MR. BARTON:  Thank you.
                       (Slide change.)
                       MS. KHANNA:  Good morning.  My name is
           Meena Khanna and I'll be talking to you about Section
           3.1 which is the Aging Management Programs of the
           Hatch SER.
                       SNC originally identified 29 Aging
           Management Programs.  After a staff review, the staff
           identified the need for an additional Aging Management
           Program which is on non-EQ cables.  Later, the
           applicant did agree to add this Aging Management
           Program on cables.
                       I'll be discussing the significant open
           items that the staff has identified for the Aging
           Management Programs listed on this vu-graph.  Then
           after my discussion, Jay Rajan will discuss open items
           on the Fire Protection Aging Management Program.
                       Okay, the first one is Reactor Water
           Chemistry Control Program.  The applicant based its
           Reactor Water Chemistry Control Program on EPRI
           TR103515 which is the BWR Water Chemistry Guidelines,
           Rev. 2.  The staff is familiar with Revision 1, so
           what we're asking, we've asked the applicant to
           address the differences between Rev. 1 and Rev. 2 so
           that we can understand what the aging effects for the
           Reactor Water Chemistry Control Program, the
           differences in the aging management effects that are
           addressed in the reports.  We're just asking for the
           differences, so that we know, you know, what we need
           to understand to review the program.
                       Okay, for the Diesel Fuel Oil Testing
           Program, the applicant indicated that corrosion is an
           aging effect for these diesel fuel oil tanks.  So
           therefore, the staff has requested that the applicant
           address corrosion and lack of inspection for the
           diesel fuel oil tanks.
                       DR. BONACA:  And here, if I understand the
           issue, the concern is --
                       MS. KHANNA:  The one time inspection.
                       DR. BONACA:  -- stagnant water?
                       MS. KHANNA:  Right.
                       DR. BONACA:  In the bottom that may cause
                       MS. KHANNA:  Corrosion.
                       DR. BONACA:  Corrosion.
                       MS. KHANNA:  In these tanks, right.  And
           actually, in the report, if you look at the SER,
           that's where we actually talk about the one time
                       DR. BONACA:  Yes.
                       MS. KHANNA:  Okay.
                       DR. BONACA:  If I remember, this was
           already an issue with previous application.
                       MS. KHANNA:  Right.  We've done that with
           all the other applications, we've asked for that.
                       DR. BONACA:  This is an open item being
                       MR. BURTON:  No, this is not an appeal
           item.  In fact, what has gone on since issuance of the
           SER is that Southern Nuclear has actually, I don't
           know if you want me to speak on that or if you wanted
           to -- they've actually done an inspection of one of
           their large diesel generator fuel oil storage tanks. 
           Found no significant corrosion in the tank bottoms and
           so now the argument is how applicable is that result
           to the other three diesel fuel oil storage tanks as
           well as the two smaller fuel oil storage tanks for the
           diesel fire pumps.  So we are in dialogue on that.
                       MS. KHANNA:  Okay, going on to the Torque
           Activities Program, the applicant did not identify
           stress corrosion cracking as an aging effect for high-
           strength bolting, however, 
           high-strength bolting is susceptible to SCC if it has
           been heat treated to a high hardness.  Therefore, the
           staff requested that the applicant address the
           susceptibility of stress corrosion cracking to high
           strength pressure boundary bolting.
                       All right, for the Reactor Pressure Vessel
           Monitoring Program --
                       DR. BONACA:  Again, I would like to --
           every time you go through one of these I would like
           you to comment if it is, in fact, one which is being
           appealed or not.
                       MS. KHANNA:  Okay, I can do that.
                       DR. BONACA:  To give us an understanding.
                       MR. BURTON:  No, this is not an appeal
           item, and in fact, this was spoken on a little bit
           yesterday by Jim Davis with the high strength bolting.
                       MR. GRIMES:  This is Chris Grimes.  This
           isn't a plant-specific appeal.  This is an 
           industry-level appeal.  As Jim explained yesterday,
           the industry has challenged us in terms of the
           evaluation guidelines, making the high strength bolts
           or differentiating high strength bolts on a generic
                       But the applicant understands what our
           expectations are for our ability to get to a plant
           specific resolution of this.
                       MR. BURTON:  Let me just say that none of
           the items on this page are part of tomorrow's appeal
                       MS. KHANNA:  Okay, thanks.  For the
           Reactor Pressure Vessel Monitoring Program, the
           applicant indicated that it plans to implement the ISP
           which is the Integrated Surveillance Program, but is
           currently under staff review.  However, if the ISP is
           not improved by the staff or if it is modified such
           that Hatch is not going to be covered by the ISP, the
           applicant has indicated that it would develop an RPV
           Surveillance Program for the renewal period. 
           Therefore, this will remain an open item until the ISP
           is approve.d
                       Finally, the RHR Heat Exchanger Augmented
           Inspection and Testing Program, the applicant did not
           identify vibration-induced cracking as an aging effect
           for the RHR heat exchanges.  The staff requested that
           the applicant provide details regarding how the RHR
           heat exchanger augmented-inspection testing program
           manages vibration-induced cracking.
                       Okay, and if you don't have any further
           questions on these Aging Management Programs, Jai
           Rajan will continue on with Fire Protection Aging
           Management Program.
                       MR. BARTON:  Are you still on 3.1?
                       MS. KHANNA:  Yes.
                       (Slide change.)
                       MR. RAJAN:  I am Jai Rajan and I will be
           discussing the two open items which were identified in
           the Fire Protection Program.
                       The first item is related to the testing
           of sprinkler heads in the fire suppression system. 
           And the second one relates to the sprinkler head
           inspections intervals.
                       MR. BARTON:  What was the second one
                       MR. RAJAN:  Sprinkler head inspection
                       MR. BARTON:  Intervals, okay.
                       MR. RAJAN:  The applicant routinely
           performs sprinkler piping float tests to check for
           clogging from corrosion products.  And this is done as
           part of its normal fire protection activities.
                       MR. BARTON:  They actually run water
           through sprinkling systems?
                       MR. RAJAN:  Through the sprinkler header. 
           The way they run this test is they open the sprinkler
           head valve and the farthermost sprinkler in the system
           and look for the flow through the valve to check for
           clogging.  If there is unobstructed flow, the flow
           normally proceeds and that indicates there is no
           clogging in the system.
                       The staff was initially concerned that
           these may not be adequate for demonstrating
           operability of all the sprinkler heads during the
           extended period of operation.  However, as the staff
           position has evolved, the staff is no longer requiring
           additional testing for checking flow blockage and
           clogging in the piping headers, so this issue most
           likely is going to be resolved.
                       MR. BURTON:  Let me break in just for a
           second.  We spoke in some of the earlier sessions
           about the impact of GALL, in particular, on the Hatch
           license renewal application and I think we had
           explained that due to the timing, they weren't always
           able to incorporate some of the lessons learned from
           GALL, but what we're finding is, as we're going
           through this stage, as GALL, as some of the issues
           related to GALL are being resolved, we're at a point
           in our review where we can actually incorporate them
           and this is one of them, the whole issue of the flow
           testing of the fire headers.
                       DR. BONACA:  And what's the solution that
           GALL suggests?  The question that was raised here was
           that the testing of the just farthest most head in the
           system is not a demonstration that the other heads are
                       MR. GRIMES:  This is Chris Grimes.  The
           way that the issue was described yesterday in relation
           to GALL, it was described to us -- I've forgotten the
           word.  But it's the flow plugging issue where we made
           the distinction between the active features of system
           flow and the crud deposits' impact on corrosion and
           the attack on the pressure boundary and so we do not
           look at flow, loss of flow as a passive element, but
           we do look at the impact of the crud build up as its
           impact on an aging effect.  And that's -- we've
           applied that conclusion in this case.
                       And I don't know if you want us -- whether
           or not you want to pursue the question about how these
           tests -- how the active tests are performed relative
           to how they test, flow through the sprinkler without
           sprinkling safety-related stuff which is an issue that
           has come up before.
                       DR. BONACA:  Sure.
                       MR. GRIMES:  And Mr. Barton says no, we
           don't have to explain it again.
                       MR. RAJAN:  Okay, now with regard to the
           second open item, the sprinkler head inspection
           intervals, the applicant is proposing a one-time
           inspection at or before 50 years of service life.  The
           staff is concerned that this may not be sufficient for
           an Aging Management Program throughout the extended
           period of operation.  The staff position which is
           based on the National Fire Protection Association
           Codes and Standards requires that where sprinklers
           have been in place for 50 years, they shall be
           replaced or representative samples tested for field
           service operation in a recognized laboratory.  And
           after this initial testing, thereafter every 10 years. 
           So there is a clear distinction between the staff
           position and what the applicant is proposing and so
           this remains an open item.
                       DR. BONACA:  Is this being contested?
                       MR. BURTON:  Yes.  I was going to say
           neither one of these items are on the agenda for the
           appeal meeting right now.
                       DR. BONACA:  So that would substitute a
           one-time inspection with a program?
                       MR. BURTON:  Yes.
                       MR. RAJAN:  That concludes my
                       MR. BARTON:  I have a question on 3.1,
           Butch.  Torus Submerged Components Inspection Program
           talks about lots of components within the torus --
           where is the torus itself covered?
                       MR. BURTON:  Yes, containment.
                       MR. BARTON:  It's under containment? 
                       DR. BONACA:  I have a question on the
           embedded components.  This is listed under passive
           component inspection activity.  There is a program, I
           believe, the Passive Component Program.  Okay, so it's
           an existing program right now.  Right?  Or is it a new
           program?  New program.
                       And if I understand it.  It's similar to
           what we have seen in other applications which is
           essentially in case you have maintenance activities or
           design changes that will expose embedded piping, then
           you will perform inspections.  Okay, so that's the
           same program that we have seen before?
                       MR. BURTON:  Yes.  Let me speak to that
           very briefly, because that was one of the items that
           we looked at in our second inspection which we just
           completed a couple of weeks ago.
                       The issue of buried and embedded
           components, both mechanical and structural, you know,
           our concern was -- and the purpose of the second
           inspection was to see how these things were actually
           implemented with the on-site procedures.  And what is
           actually done is yes, the Aging Management Program
           that you mentioned also the Protective Coatings
           Program and the Structural Monitoring Program also
           have provisions to make sure that when structures or
           buried components are dug up for some reason that we
           take that opportunity to inspect them and take a look
           at them and we actually have looked at their
           excavation procedure on site and they have actually
           proposed changes to that procedure to make sure that
           when they do excavation, there's a heads up in the
           procedure to actually do that.
                       DR. BONACA:  Now this is an activity that
           takes place irrespective of whether or not you have
           indications from exposed piping that there may be some
           problem with that, right?
                       MR. BURTON:  That's correct.
                       DR. BONACA:  In case you do have
           indications, then you would have a more aggressive
           program, go after -- and there is provision under the
           program or is this separate provision, the one that
           says that should you have indication in structures
           that from exposed equipment that embedded equipment
           may be affected, I thought you had a specific program
           for that?
                       MR. BAKER:  I don't recall the detail of
           the Passive Component Inspection Program as to whether
           it has a scope expansion item in it.  We'll go look
           and get an answer for that.
                       DR. BONACA:  I appreciate it.  Thanks.
                       MR. GRIMES:  This is Chris Grimes.  To try
           and avoid some further confusion in the Generic Aging
           Lessons Learned, we referred to this as inaccessible
           components and there was a distinction between those
           things that are covered by the code, the structural
           elements under IWE were treated separately from
           inaccessible -- other inaccessible features that are
           covered by the code, and then of course, anything
           that's not covered by the code we treat it as
           inaccessible in a broader way.
                       DR. BONACA:  Okay.  Thank you.  
                       (Slide change.)
                       MR. ELLIOT:  I'm Barry Elliot, Materials
           and Chemical Engineering Branch of NRR.  I'm going to
           discuss the reactor and reactor coolant system.  The
           reactor and reactor coolant system is the reactor
           pressure vessel, the reactor vessel internals, the
           reactor recirculation loops, the reactor coolant
           system piping and valves which includes the main steam
           line, the safety relief valves, the main steam
           isolation feed water lines, feed water line check
           valves and instrumentation and control.
                       There are 15 Aging Management Programs
           associated with these components.  Two of them, the
           Boiling Water Reactor Vessel and Internals Program and
           the Reactor Pressure Vessel Monitoring Program
           reference the BWRVIP Programs.  There are 12 BWRVIP
           Program Reports that establish guidelines for
           inspection during the license renewal period.  The
           Reactor Vessel Report -- we have not completed review
           of the Reactor Vessel Report, however, we have
           reviewed it relative to Hatch and it's referenced in
           our safety evaluation how it affects Hatch and we're
           satisfied with what Hatch has provided to resolve the
           reactor vessels issues.
                       The other BWRVIP Report that is not
           complete for review is Core Shroud Report and the Core
           Shroud Report for inspection, the inspections during
           the current license term are being carried over into
           the license renewal period and that's found acceptable
           by the staff for Hatch.
                       And the last one that we haven't
           completed, but we really have completed, we just
           haven't put the SER on is the jet pump assembly and
           that takes care of all the ones that are as far as
           inspection is concerned.
                       As far as open items, I would like to say
           that BWRVIP did a wonderful job of looking at all of
           the current issues that projecting them out into the
           future.  However, we have two issues that we think
           they need to address.  First, is a loss of fracture
           toughness resulting from neutron irradiation for the
           CASS jet pump assemblies and the fuel supports.  The
           CASS stainless steel is composed of two phases, a
           ferritic phase and an austenitic phase and the
           ferritic is subject to thermal embrittlement and
           neutron irradiation embrittlement.  And I mention
           neutral irradiation embrittlement here because I think
           that thermal embrittlement is not going to be a
           problem here, in particular, because the BWRs operate
           at much lower temperatures and that should make the
           thermal embrittlement less of a problem.
                       The flip side of that is the lower the
           temperature, the more neutron embrittlement you get. 
           So this is why we're concerned about this.  And we
           think that this is an area where inspection -- if we
           don't see flaws, if we don't see cracks in the CASS
           stainless steel components, then we wouldn't be
           concerned about the loss of fracture toughness.  And
           this is a case where an inspection of the limiting
           component, CASS stainless steel components would be
                       DR. BONACA:  It's a one-time inspection
           you're asking for?
                       MR. ELLIOT:  Yes.
                       DR. SHACK:  Just on that very -- is the
           CASS part of that, has that ever been observed to have
           -- there's jet pump fatigue problems, but has it ever
           affected this CASS component?
                       MR. ELLIOT:  At the time we don't have a
           problem with CASS stainless steel components, but
           current inspections are of the welds and the adjacent
           material.  So we're going to ask that it be expanded
           a little bit.
                       DR. BONACA:  And you can see that the jet
           pump assembly components as the limiting component for
           CASS assembly?
                       MR. ELLIOT:  Yes.
                       DR. BONACA:  Okay.
                       MR. ELLIOT:  The second issue is cracking
           of the small-bore piping.  Our concern here is that we
           are giving a license for 60 years and in the first 40
           years we're not going to do any volumetric inspection
           of small-bore piping and so we think that it's
           necessary to do a one-time inspection to convince
           ourselves that cracking isn't occurring on these type
           of lines and a sampling of lines would be appropriate
           of the small bore piping.  We prefer -- the
           susceptibility here is to -- what we're worried about
           is stress corrosion cracking in and turbulent
           penetration and stratification, fatigue issues.  And
           if we can get the most susceptible components
           inspected, we'd be satisfied and again, a one-time
                       DR. BONACA:  And it would be just for a
           specific limiting components?
                       MR. ELLIOT:  Right.  If that can be
           judged.  If it can't be judged, then we would just
           take -- we would look at the consequences and maybe
           take the components with the most consequence and
           inspect those.
                       DR. BONACA:  Are these open items being
                       MR. BURTON:  No appeal on these.
                       DR. BONACA:  I have a question --
                       MR. PIERCE:  Let me -- there are some open
           items that we're still in the process of working out
           with the NRC and if we -- and at some later date we
           may take an open item into an appeals stage later,
           even though we're not appealing them tomorrow, they
           could come at a later time.
                       DR. BONACA:  I understand of the ones that
           you already are dealing with, I understand you have
           these options, sure.
                       MR. GRIMES:  Dr. Bonaca, this is Chris
           Grimes and I want to take this opportunity to point
           out this is another one of the GALL appeal issues that
           we discussed yesterday.
                       DR. BONACA:  Yes.
                       MR. GRIMES:  The industry has challenged
           the need for one time inspections on small-bore
                       DR. BONACA:  Yes.
                       MR. GRIMES:  On a generic basis.
                       DR. FORD:  I have a comment.  I agree with
           you that on the VIP reports relating to disposition of
           stress corrosion cracking of austenitic alloys,
           stainless steels, the nickle base alloys.  It seems as
           though the disposition curves are reasonably
           conservative.  I would have a bit concern, however,
           about the conservatism for the alloy steel stress
           corrosion cracking enunciated in I think VIP-60.  
                       It relates to -- if, in fact, those are
           not conservative curves for alloy steels, then we
           could have a safety issue for cracking at the H9 weld,
           for instance, or at the core penetrations and then the
           bottom head.
                       What assurance do we have that as more 
           -- if there is more data coming out, to show that
           those can't -- 60 disposition curves are not
           conservative, can we address those?
                       MR. ELLIOT:  Gene is coming to the
                       MR. CARPENTER:  Yes, Dr. Ford, just
           because of you, Dr. Ford, yes.  Gene Carpenter of
           EMCB.  As we discussed yesterday in the BWRVIP
           Program, the program is looking at the Aging
           Management Program consists of all the INE documents
           and those are supported by the crack growth and the
           various mitigation documents, including the BWRVIP 60
           documents just referenced.
                       If the staff finds or the industry brings
           to our attention that there are nonconservatisms that
           come along due to aging, we will revisit the programs. 
           At this time, to the best of our knowledge, this 60
           report appears to be accurate.
                       But if it does not continue to be so, we
           will come back and relook at it.
                       DR. FORD:  And following on from that,
           what programs shall we have in place for monitoring
           the cracking of those very thick section components,
           H9 and the bottom head.  How will we know if they're
           not cracking?
                       MR. CARPENTER:  And again, the inspection
           programs that are called out are the ones that will be
           doing those monitoring and as was pointed out
           yesterday, the industry provides to us on a semi-
           annual basis a listing of all the inspections that are
           done for every plant, so we would be able to see if
           there is any trending of cracking occurring.
                       MR. DYLE:  If I could, this is Robin Dyle
           for Southern Nuclear.  Peter, the other thing that
           maybe I didn't make clear yesterday, one of the
           documents that we credit in our application is VIP-38
           which is the document that requires the inspection of
           the H8 and H9 welds, so there are inspections being
                       Because of some overseas incidents of
           cracking, we're evaluating the impact of that. 
           Whether the document should be revised or not and will
           incorporate the appropriate results and we have on-
           going work with the staff.  They're aware of the
           situation, we are and we're working on it, but the
           inspections are being done at H9.
                       In accordance both with VIP-38 and it's
           currently required by Section 11 to be inspected also.
                       DR. FORD:  If there was cracking it would
           be a huge safety concern.  And that's why I bring it
                       MR. DYLE:  And there's quite a few
           evaluations that have been done to assess that.  It
           was done as part of the VIP-05 report which this
           committee has reviewed several times to look at the
           possibility of what happens if you have stress
           corrosion cracking that might propagate from clad into
           the reactor vessel.  But it's been thoroughly
                       MR. ELLIOT:  Your question had to do with
           the internals or was it to the vessel?
                       DR. FORD:  Vessel.
                       MR. ELLIOT:  I'm going to answer the
           vessel question.  That's my area.  And we don't think
           that stress corrosion cracking of the alloy steel is
           an aging effect we have to be concerned about.  Let me
           tell you why.  We've had a few cases where we have
           seen cracks go through the clad and they just don't
           propagate.  They go through the clad and they just --
           we inspect them year after year, not year after year,
           but every 10 years.  And they just don't go anywhere. 
           They just stop right there, they blunt.  The other
           case is a summer case, is whether the cracks went
           right through the Iconel 183, got to the carbon steel
           and stopped.  So that was primarily more due to stress
           corrosion cracking and so we've seen in our experience
           that stress corrosion cracking of low-alloy steel is
           not an issue that we're concerned about.
                       DR. FORD:  I would agree entirely with you
           for 99 percent of the cases and you're absolutely
           correct.  However, there have been at least one case
           as I know of, if not two where a crack has penetrated
           considerably into low-alloy steel underneath the
                       MR. ELLIOT:  And I would say this, when I
           say it's not -- we don't consider it an issue.  We
           looked at it as far as the BWR VIP-05 which was the --
           we talked about yesterday which was the
           circumferential welds and that -- in that analysis was
           done two ways.  We did it one way and the industry did
           it another.  The industry's way was a probability
           argument, a probability analysis.  In their analysis
           they looked at the probability of a stress corrosion
           crack based upon their experience penetrating and then
           they grew the initial crack based on those
           probabilities and was able to through the Monte Carlo
           simulation technique, determine the impact of stress
           corrosion cracking on fracture of the weld and it
           turned out from their method of evaluation that it was
           not significant and the failure probability on the
           circumferential welds were very, very low.
                       DR. FORD:  I agree with you in principle,
           yes, but given the severity of a problem I would
           question whether the data upon which such statistical
           analysis such as experimental data is up to the
           quality for this severe a problem, potential.
                       MR. ELLIOT:  And I agree, it's a potential
           problem.  What we're doing is we inspect the axial
           weld.  They're at higher stresses than the
           circumferential weld, so they are sort of like the
           limiting material and if we see stress corrosion
           cracking of the axial weld, then we could go to the
           circumferential weld.  I'm not saying we don't think
           it's significant.  It doesn't mean we're not
           interested in it.  We're interested in it and we have
           an inspection for it.  But we just don't think, based
           upon our experience that it's a significant issue.
                       DR. FORD:  I won't belabor the point any
                       DR. BONACA:  It's a well-taken point and
           I think -- I have a question just regarding the void
                       MR. ELLIOT:  The what?
                       DR. BONACA:  Void swelling.  The fact is
           of the problem.  Now I agree that it shouldn't be a
           problem because the plants are not running at the
           temperature that would justify that, just in the SER
           it's confusing because it says since BWR reactor
           vessel has relatively low nuclear neutron fluence and
           the applicant would perform inspections in accordance
           with the -- I mean is it an issue or is it not?
                       MR. ELLIOT:  We don't think it's an issue
           because it's at lower temperatures.  But even if it
           was an issue, even if it ever became an issue, they're
           doing inspections already of the critical areas of the
           core shroud.  It would show up as cracking or
                       DR. BONACA:  Yes.  Okay.  
                       DR. SHACK:  They have much more likely
           problems to occur if they do have a strike force.
                       DR. BONACA:  I understand.  I'm only
           saying that they're not specifically doing this
           inspection to look at swelling because swelling is a
           credible issue there.  I think that's -- all right. 
           I was trying to understand if it is will an issue and
           they're looking for it.
                       MR. ELLIOT:  No, they're not looking for
           it.  It's lower temperature and it's not an issue.
                       DR. BONACA:  You are saying if it was
           active then something would be a problem.  That's a
           different story.  Thank you.
                       MR. BURTON:  Okay, next we'll talk about
           the ESF systems, the auxiliary systems, steam and
           power conversion systems and Carolyn Lauron will do
                       (Slide change.)
                       MS. LAURON:  Okay, my name is Carolyn
           Lauron and today I'll be presenting the next three
           sections, the summary of the Aging Management Reviews
           for the Engineered Safety Feature Systems, the
           Auxiliary Systems and the Steam and Power Conversion
                       Let me preface my presentation with a
           statement that the concerns identified by the staff
           during their review has been addressed in a previous
           section, the Aging Management Program Section which
           was discussed earlier by Meena Khanna.
                       The ESF system consists of eight different
           systems and includes a wide range of materials and
           environments as noted on the slide.  The staff did not
           identify any open items.
                       The auxiliary system consists of 20
           systems and encompasses, once again, a wide range of
           materials and environments and the staff did not
           invite any open items.  
                       The steam and power conversion system
           consists of the electro-hydraulic control system and
           the main condenser system and once again, the staff
           did not invite any open items.
                       If there are any questions -- if there
           aren't any --
                       MR. GRIMES:  Wait, wait, wait.
                       MR. GRIMES:  This is Chris Grimes. 
           Carolyn scores extra credit for really moving right
           along on the schedule.
                       MS. LAURON:  Thank you.
                       MR. GRIMES:  I just wanted to make sure
           that the committee had ample opportunity.  There were
           a number of questions that you brought up in scoping
           the screening and Mr. Barton's questions about the
           crane hooks, the intake design, we've noted those and
           we'll work to get answers on those, but are there any
           other questions related to the Aging Management
           Programs associated with --
                       MR. BARTON:  I didn't have any in that
           area, Chris.
                       MR. GRIMES:  Okay.
                       MR. BARTON:  I don't know if the rest of
           the committee did.
                       (Slide change.)
                       MR. ASHAR:  I am Hans Ashar, Mechanical
           and Civil Engineering Branch and I'm going to talk
           about SER Section 3.6, Structures and Structural
           Components.  Thirteen structures/structural components
           are included in this area.  Originally, I believe we
           had 46 open items in August of last year.  The problem
           more was navigation and where is what kind of a thing
           more than anything else.  I think we are left with
           three open items now and out of three, I think two of
           them we have closed them after you received your SER
           copies and I am going to talk about those two and the
           third open item is still open and it is one of the
           appeal items.
                       Let me first talk about the items which
           have been closed since you saw the SER.  First item is
           torus corrosion in which we requested applicant to
           tell us as to where the torus penetrations are being
           addressed and how the torus penetrations are being
           managed as far as the aging is concerned.  Again,
           partly integrational and partly informational
           provided.  There is enough Aging Management Programs
           to cover the torus corrosion as well as the
           penetrations within the torus corrosion and they
           provided us with -- it's been a very nice drawing
           which saved 10,000 words more or less saying that
           which area is called by what Aging Management Program
           below water, above water, so it was very descriptive
           and that item was closed.
                       MR. LEITCH:  Is the torus at Hatch, is it
           coated?  Does it have a zinc --
                       MR. ASHAR:  The torus is coated, yes.
                       MR. LEITCH:  And the inspection of that
           coating is --
                       MR. ASHAR:  It's part of the Coating
           Management Program, yes.
                       MR. LEITCH:  Okay.
                       MR. ASHAR:  The second open item which we
           closed was related to the gears, latches and linkages
           which were mainly related to the access openings.  Our
           concern -- now this was also in parallel with a GALL
           item and let me go into that.  In GALL, we have the
           same items being recommended as part of the GALL
           evaluation.  However, the basic reason why the
           industry complained that hey, it is an active item and
           they're going to be monitoring during the opening and
           closing of the doors and latches.  The concern that we
           had was because the outages, you know, during
           operation of the plant, when anything can happen and
           if they don't properly close and they go to aging,
           what would happen to them?  And I'm right now
           referring to GALL and then we'll come back to Hatch
                       In GALL, we resolved this item when the
           safety reviewed a number of programs, particularly IS,
           due to IWE, IS program and then Appendix J testing
           during the time when they opened any equipment access
           opening and they inspect them and they close it.  They
           go to 5B testing.  So -- this particular answer is
           that there are enough things there, so what we did
           identify these three items such as IWE, IS, Appendix
           J and but in the evaluation we said no, so far as the
           programs is in effect.  So on the same basis, we
           closed the open item in Hatch.
                       Now the third item, this is still an open
           item --
                       MR. LEITCH:  Excuse me, there's a term
           used in that discussion Nelson frames.
                       MR. ASHAR:  Yes.
                       MR. LEITCH:  I'm not -- it's a term I
           don't understand.  What is Nelson frames?
                       MR. ASHAR:  Nelson frames are -- you want
           to expand on that?
                       MR. BAKER:  The reactor building
           penetrations for electrical conductors essentially
           consist of a large structural frame with then inserts
           that are used for the cables to penetrate through. 
           That entire assembly is commonly called a Nelson
                       MR. LEITCH:  Okay, thank you.
                       MR. ASHAR:  The third open item still is
           open and it is related to the reactor building
           controlled leakage characteristics.  The applicant
           argues that we got a very in-depth instruments
           inspection requirements, structural monitoring and
           looking at all the access doors and we are going to
           make sure that on a periodic basis that the aging
           management is being conducted.
                       However, the staff -- the secondary
           containment building including the SGT, the standby
           gas treatment system requires certain amount of vacuum
           in the building in order to make sure that the SGT
           will work or during an accident.  And for that the
           staff is insisting that there has to be some kind of
           an Aging Management Program to make sure that the
           characteristics of the reactor building for secondary
           containment is maintained, the way it is in the
           current license.  
                       MR. GRIMES:  This is an appeal issue.
                       MR. ASHAR:  I would like have some
           thoughts from you too because it's going to be an
           appealed and I would like some help or words from you
                       MR. BARTON:  What, do you want a vote?
                       MR. ASHAR:  No vote, but just your
                       DR. BONACA:  Well, clearly, we will be
           looking at these things, but just because there is an
           appeal, it seems to me that it's important we reflect
           on that before we decide on one perspective or the
           other.  I think we need to see how the members feel.
                       MR. GRIMES:  This is Chris Grimes.  I'm
           sure that you'll give us a reaction when we tell you
           how we've disposed of the appeal issue.
                       DR. BONACA:  That's right.
                       MR. LEITCH:   I had a couple of questions
           in that section.  Yard structures, on page 3-180.  I
           wonder if that goes as far as the switchyard.  I'm
           thinking particularly about a transformer, tanks,
           circuit breaker tanks.  Did the review go out into the
           switchyard and were those types of tanks considered as
           passive structures?
                       MR. ASHAR:  I would defer to David Jeng. 
           Maybe he can -- he was the main coordinator in that
           entire area.
                       MR. JENG:  I am David Jeng.  To answer
           your question, I think the yard structures in our
           section particularly covers the pad that anchors and
           the structure support elements.  As to the components,
           the transformers, I think they should be covered
           within the system.  So we did not review the component
           as I say, but we review the supporting anchors in the
           frames and so on and make sure they are properly
           married to aging effects.
                       MR. LEITCH:  Okay, so the transformer
           pads, so to speak --
                       MR. JENG:  Anchor bolts.
                       MR. LEITCH:  Anchor bolts.
                       MR. JENG:  And supporting frames.  These
           are the things we talk about.
                       MR. LEITCH:  Well, then is there someone
           that can address the issue of transformer tanks and
           circuit breaker tanks?
                       MR. GRIMES:  I would suggest the applicant
                       MR. BAKER:  The scope of the electrical
           part of the plant is at the 4160 volt level as it
           comes into the plant from the supply from off-site. 
           As a result, the electrical switchyard that you're
           referring to, none of the items in that electrical
           switchyard are in scope at Plant Hatch.
                       Now the entire diesel generator building
           and this includes the ability to supply the alternate
           sources of AC, from there in is all in scope.
                       MR. LEITCH:  Now is the switchyard not in
           scope by definition or it's not in scope because it
           doesn't meet the criteria?
                       MR. BAKER:  We evaluated against the
           criteria and it did not meet the criteria.
                       MR. LEITCH:  Okay.  I understand.  And I
           guess I have a similar question on the end of the
           plant regarding the intake structures.  Did any of
           that thought go out into the river, I'm thinking of
           silting that may occur over long periods of time or
           changes in the characteristics of river flow, river
           soundings and so forth.
                       MR. BAKER:  As I recall, we addressed
           siltation at the intake structure as a part of the
                       MR. LEITCH:  And there is a program then
           to sound that area periodically or how did that --
                       MR. BAKER:  We send divers down.
                       MR. LEITCH:  Okay.
                       MR. BARTON:  Although the switchyard isn't
           a scope, who owns the switchyard?  Does the plant own
           it or does something else in Southern Company own it? 
           The maintenance programs in the switchyard are
           performed by who under what process, under what
           program, under what procedures?
                       MR. PIERCE:  I can check on that during
           lunch, but I am reasonably certain that currently
           today, the switchyard is being maintained by Georgia
           Power Company.
                       MR. BARTON:  Not the plant.
                       MR. PIERCE:  Right.
                       MR. BARTON:  And it's under Georgia Power
           Company's procedures, processes, programs and not the
                       MR. PIERCE:  There are some elements of it
           that I think the plant gets involved with, but I'll
           have to check on that.
                       MR. BARTON:  I'd like to know what the
           plant's involvement is.
                       MR. BAKER:  Just to follow up on that,
           this is an area that was discussed somewhat in the
           environmental review part of the discussions as to who
           performed the routine procedures for the switchyard
           and for the transmission lines.  So we have that.
                       DR. BONACA:  I have a question regarding
           the unit.  Does the plant have a program to monitor
           building settlement, if any?  And at what point do you
           feel that during the life of this plant settlement may
           affect somehow structures or impingement on piping and
                       MR. BAKER:  In the original licensing of
           the plant, building settlement and differential
           settlement between structure and soil was considered. 
           There were technical specification requirements to
           monitor that.  That monitoring showed that the
           consolidation settlement was essentially complete by
           the time construction was finished.  There were some
           concerns at one time regarding a possibility of
           differential settlement between structure and soil at
           the intake structure.  There was some remedial actions
           that were taken there.  Subsequent to that there's
           been no indication of any additional settlement
                       MR. JENG:  This is David Jeng.  I'd like
           to supplement this answer.  Settlement is a general
           issue.  If the structures are in the scope in the
           design CP, OL review has been reviewed and accepted to
           determine to be adequate, there's no concern.  In the
           license renewal, we did not come across any special
           concern from the standpoint of RAI.
                       DR. BONACA:  Okay.  I was more curious
           than anything else.  The other thing I would like to
           do, by the way, we're close to the end of the Section
           3 presentation.  I would appreciate at some point if
           the applicant could give us a very brief summary of
           operating experience.  If you look at the application
           and then the SER, there is substantial information
           provided in different sections regarding particularly
           the operating experience for crackings and so on and
           so forth, but it would be good for us to have a
           feeling about what are the major issues that the
           applicant is tracking right now that they consider,
           they focus on mostly.  So just for our benefit.
                       (Slide change.)
                       MR. BURTON:  Just briefly, the next
           section was 3.7, again electrical components.  We
           looked at 14 systems and again, we found that the
           Aging Management Review and the Aging Management
           Programs seemed to be appropriate to manage the aging
           effects associated with this.  The only issue which we
           had already talked about before was the additional
           Aging Management Program that came into play for the
           non-EQ cables.  That's it.
                       MR. BARTON:  Butch, I know yesterday in
           the discussion in the electrical area, that electrical
           cabinets were in scope, but switch gear was excluded
           from aging management.  Is there a logic for that? 
           What in switch gear is not -- is excluded from the
                       MR. BURTON:  Okay, this was part of
           yesterday's discussion?
                       MR. BARTON:  Yes, I believe so.
                       MR. BURTON:  I probably need to call in
           our electrical person.  Paul?  Paul Shemanski.
                       MR. SHEMANSKI:  Paul Shemanski, Electrical
           Branch.  Basically, switch gear are excluded by the
                       MR. BARTON:  Okay.
                       MR. SHEMANSKI:  And the basis is that they
           contain for the most part active components which are
                       MR. BARTON:  How about the cabinets
                       MR. SHEMANSKI:  Well, the cabinets would
           be in scope because they're the -- they would be in
           from a structural standpoint.
                       MR. BARTON:  That's why I'm confused.  You
           talk about electrical cabinets in scope and switch
           gear not in scope.  When you talk about electrical
           cabinet, how about a 4160 switch gear room that's
           contained within a cabinet and you've got breakers and
           dials and indicators and meters.  Is the cabinet
           itself an electrical cabinet that's in scope or not?
                       MR. SHEMANSKI:  My understanding is that
           the structural --
                       MR. BARTON:  The cabinet that's bolted to
           the concrete.
                       MR. SHEMANSKI:  That would be in scope and
           that would evaluated for aging effects such as
           corrosion, whatever else, but the internal components
                       MR. BARTON:  I understand internal
           components.  They all move in something.  I thought
           the definition that was given, the description that
           was given talked about breakers and switches,
           etcetera, as not being in scope and I can understand
           they're active components, but then it said switch
           gear.  I'll have to find it.  It was in yesterday's --
           it said switch gears excluded.  I was trying to
           determine what they meant by switch gear.  Was that
           the cabinet itself and there's also electrical
           cabinets are in scope.  What's electrical cabinets? 
           Is that all motor control centers and switch gear, the
           outer envelope, the housing so to speak or is it more
           than that?
                       MR. SHEMANSKI:  Basically the housing, the
           structural cabinet would be in scope, the metal, okay,
           the enclosure itself would be in scope, again, the
           internals are out of scope because --
                       MR. BARTON:  I can understand the
           internal.  I understand that.
                       MR. SHEMANSKI:  But electrical cabinet,
           panel, enclosure, that would be in scope and would be
           evaluated for aging effects of corrosion, rust, that
           type of thing.
                       MR. BARTON:  Okay, thank you.
                       MR. BURTON:  Okay, that's pretty much it
           for section -- I'm sorry.  That's pretty much it for
           Section 3.  Comments, questions?
                       DR. FORD:  I have a much more general
           question.  A lot of your argument for the aging
           managing, especially for environmental degradation
           problems, based on the VIP documents which are
           primarily deterministic based on data and you come up
           with a deterministic upper bound, admittedly
           disposition curves.  I haven't seen anywhere and I'm
           talking from lack of knowledge because this is the
           first time I've been on this committee, I've seen
           very, very little reference to use of extreme value
           statistics, bearing in mind that we're really
           concerned about the first event.  That's what's going
           to kill us.  So has this a place in all of these
                       When will a first event occur which is
           going to kill us all?  
                       MR. GRIMES:  Somehow I have a feeling that
           question is in my job description.
                       And I would emphasize that if you look
           very carefully at the statements of consideration of
           the license renewal rule, I think the industry
           originally argued that -- we don't need to do anything
           for license renewal by virtue of we've got regulatory
           processes and look at operating experience and when
           stuff breaks, we fix it and we've been doing that fine
           for 25 years and let us have another 20 years.
                       The Commission concluded that while we've
           got maintenance rule and we do have confidence in
           active components because they break a lot and we've
           got a large data base from which we can draw
           reliability information.  And it's that data base that
           led us into the maintenance rule and its requirements
           in order to monitor very carefully the information
           that's used to derive reliability and failure rates
           and core damage frequencies and other information
           that's used to try and be informed about risk.  But
           for passive things like the fracture toughness of the
           vessel or sprawling -- did I say that correctly? 
           Spalling.  Sprawling was probably Freudian in terms of
           my vision of structural inspections.
                       But the Commission concluded that because
           these are rare events, we do not have large -- we
           don't have a large data base to draw on for the
           failure rates of tanks and pump casings and structural
           elements and they do not get challenged in the way
           that they will be challenged if an accident occurs. 
           And for that reason we will look to ensure that there
           are Aging Management Programs that are going to
           monitor the condition that are going to identify when
           applicable aging effects appear to the extent that
           they jeopardize the intended safety functions.
                       So the entire focus of this review is
           almost the inverse of your question and that is
           because there is a lack of data and reliability values
           associated with these functions, we concentrate on the
           inspection and maintenance practices that are relied
           on in the current term and to what extent do they need
           to be modified, adjusted or augmented for an extended
           period of operation so that as new failures occur in
           the future that there's a process in place that's
           going to account for new information and adjust
           according to aging effects in such a way as to
           continue to maintain the condition of the system
           structures and components so that we have reasonable
           assurance that they'll perform their intended
           functions for the period of extended operation.
                       Did that answer your question?
                       DR. FORD:  Yes.  You've been proactive, to
           a certain extent proactive.
                       MR. GRIMES:  Right.
                       DR. FORD:  You're going to hope to see it
           before it becomes --
                       MR. GRIMES:  We're going to hope to see it
           and if we haven't seen it we've got a process in place
           that by through the corrective action process it will
           reveal an aging effect that was not considered in this
           revised licensing basis and then we would expect a
           corrective action process to say we don't have a
           procedure to manage this aging effect.  Now we need
                       And I think that the issue is more clearly
           illustrated in some of the industry comments on
           Generic Aging Lessons Learned where you see these one
           time inspections.  They're aging effects that the
           industry believes don't warrant an aging management
           program, but at the same time they're not so out of
           the question that we could simply dismiss them as not
           applicable and in those cases, we've insisted on a
           one-time inspection in order to provide a benchmark in
           time that says is there any evidence that it's
           occurring.  if there is any evidence, then the process
           will account for that.
                       DR. BONACA:   Okay.  Before we take a
           recess for lunch, it will be interesting to us to hear
           just a brief summary of the operating experience and
           all you had, for example, cracked sparger.  It wasn't
           clear to me that you had both at Unit 1 and Unit 2. 
           You also had indication of -- so just a summary of
           operating history and what is -- which is focusing
           mostly on inspections  right now?
                       MR. PIERCE:  Yes, I think Robin could
           probably answer some of the discussions on some of the
           internals in operating experience.  At a broader
           level, we do have an individual that is calling down
           at the plant to make sure that we give you the right
           information.  So it might be better to do that right
           after lunch and just go through the whole thing,
           including what Robin has, if that's okay with you.
                       DR. BONACA:  Okay, sure.  No problem.  And
           again, remember I'm asking you for just a summary in
           the application, interspersed in so many locations
           operating experiences.  At times you lose a little bit
           sight of what are the major issues that right now we
           are facing or you are concerned with.  Some of them
           seem to be disposition, once and for all, so that kind
           of information.
                       MR. PIERCE:  Right, and that's why we
           wanted to go down to the plant and make sure that we
           had a good understanding of they viewed the major
           issues were for operating experience.
                       DR. BONACA:  Okay, with that I think we'll
           take a recess for lunch and I would like to start the
           meeting at 1 o'clock.  We don't need an hour.  I have
           to catch a plane pretty early, so why don't we just
           start the meting again at 10 of 1.  Okay?
                       (Whereupon, at 11:57 a.m., the meeting was
           recessed, to reconvene at 12:50 p.m., Wednesday, March
           28, 2001.)
           .                     A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                   (12:50 p.m.)
                       DR. BONACA:  Okay, we're going to resume
           the meeting now and first of all, we will ask the
           licensee if they have received the information to give
           us a brief update.  We don't need a lengthy one, just
           a summary.
                       MR. PIERCE:  Okay, I think during lunch we
           worked on basically two questions.  One was on Mr.
           Barton's issue on the switch yards and secondly the
           operating experiences.
                       Regarding the operating experience, I'm
           going to let Robin start and then turn it over here to
           Wayne Lunceford to continue with some of the switch
           yard discussion, I'm sorry, the operating experiences
           discussion.  On the switch yards, I'm going to let Jim
           Mulvehill speak briefly to that.
                       MR. DYLE:  This is Robin Dyle.  You did
           mention the sparger and I guess the first thing that
           popped into mind which sparger.
                       So instead of going that path, I'll just
           discuss both of them.  The core spray spargers, there
           has been an occurrence in Unit 1 years ago where there
           was IGSCC detected, a mechanical clamp has been put in
           place and that is inspected as part of initially the
           IEB 8013 inspections that were required and then when
           we implemented VIP-18, VIP-18 replaced those
           inspections.  So we continue to do that.
                       Also, and I do not remember exactly when,
           three to five years ago, there was actually a full-
           flow functional test performed on core spray where
           they injected through the sparger and looked at that
           clamp before and after and looked at the general
           conditions.  So that's been evaluated.
                       In regard to -- Unit 1.  Excuse me.  In
           regard to feedwater spargers and the feedwater nozzle
           issue, we've been performing inspections in accordance
           with NUREG-0619 for years.  It had to do with the
           thermal fatigue initiation of a flaw in the inner
           radius and the propagation of that.  Unit 1 was
           originally a slip fit sparger.  That was replaced with
           the triple sleeve double piston sparger.  Unit 2, as
           the problem had been detected was still in
           construction and it was replaced in the field with a
           welded in-place sparger with a single thermal sleeve.
                       So those are the issue on the two
           spargers.  Since we've done the replacements and
           implemented the NUREG-0619 program, we've had no
           problems, nor has any other BWR in the industry, so we
           believe that's been handled generically and that's
           addressed in some of the VIP documentation.
                       MR. BARTON:  You said no other plant has
           had a problem since when?
                       MR. DYLE:  Since -- there was a series of
           changes that were made as part of the NUREG-0619
           process.  Not only were spargers changed out, but in
           some cases, spargers weren't changed, but operating
           procedures were changed to minimize the effect of the
           on-off flow of the cold feedwater, so you eliminated
           the thermal cycling and the initiation mechanism at
           the inner radius.
                       So there was a generic report that was
           published.  The staff has reviewed that and that's the
           new position that all the BWRs use for inspection that
           has shown that there has been no cracking throughout
           the feedwater nozzles in 15 plus years.
                       In regard to other internals, we've
           inspected the jet pumps.  We've replaced the jet pump
           beams and put in the newer heat treat versions so
           we've got the newer generation jet pumps.  We do the
           inspections per the VIP.  We have done inspections at
           the top guide.  We've seen no evidence of cracking. 
           As I mentioned yesterday, the only plant that has has
           been Oyster Creek.  
                       We did do a preemptive repair to the
           shroud as I've briefly mentioned.  And that was an
           economic decision where we knew the repair replaced
           all the cirumferential welds so instead of spending
           the money to do that, we preferentially, from a
           financial standpoint just installed the repair and now
           inspect that on a routine basis consistent with the SE
           that the staff provided.
                       We replaced access hole covers.  There was
           indications detected several years.  We were not sure
           they were IGSCC and the reason is you couldn't
           actually track the indication to the water surface,
           but plant management conservatively decided to remove
           those and they've been replaced with mechanical
           devices and we inspect those at a regular period also. 
           And I believe that's everything as far as the
           internals and the vessel goes.
                       The mention was made of the open item, the
           Integrated Surveillance Program.  We're lucky there
           because if the VIP Integrated Surveillance Program is
           not implemented, Hatch 1 and 2 or 2 of the 7 plants
           that were in the program, so we have capsules
           available that we can withdraw.  So we have a backup
           available for that.
                       MR. LUNCEFORD:  Wayne Lunceford, Southern
           Nuclear.  All I'm going to do is describe to you some
           of the general issues that the Plant Hatch is dealing
           with right now regarding components that are in the
           scope of license renewal.
                       The first one would be CRD cap screws or
           control rod drive housings.  Those are -- Hatch has
           detected corrosion and stress corrosion cracking on
           some of those cap screws.  GE issued a SIL subsequent
           to that.  I don't recall the date or the number
           suggesting an improved design, upgraded material, a
           different washer design that doesn't college fluid
           leakage so it tends to mitigate that type of
           corrosion.  Plant Hatch currently is replacing any CRD
           cap screws with any sort of noted damage as they pull
           out CRD drive housing at the replacement process, it's
           in progress right now.
                       Second item, and probably the most
           significant that the plant's dealing with is corrosion
           and reduction of flow in plant service water piping. 
           Currently, this phenomena is restricted to small bore
           piping.  The failures we've seen are in 4-inch and
           under lines.  We have replaced some lines with 304 or
           304L stainless steel an upgrade from the carbon steel
           that was originally installed.
                       There have also been failures in plant
           service water minimum flow lines, discharge lines due
           to corrosion and we've replaced some of those lines
           with 304.
                       The failures in plant service water had
           been in both safety-related areas of the plant and
           nonsafety-related.  I believe that's all I'll say
           about that.
                       MR. BARTON:  They were flow erosion
                       MR. LUNCEFORD:  We have had both erosion
           problems on the minimum flow lines off the plant
           service water pump and discharge lines and we have had
           corrosion problems in areas of low flow where under
           deposit corrosion occurred and we have also had flow
           blockage in drain lines.
                       DR. SHACK:  This is erosion is essentially
           a room temperature line?
                       MR. LUNCEFORD:  Right.  There is no -- it
           is not FAC-related.  It is simply an elbow, high
           energy line flow rate going through a relatively small
           line and it just tends to wear away the carbon steel. 
           We replaced those with stainless steel to mitigate
           that problem.
                       It's happened in more than one of the
           minimum flow lines.
                       DR. SHACK:  How fast is this going?
                       MR. LUNCEFORD:  I don't know right off
           hand.  All I know is they had problems and replaced
                       MR. BARTON:  What was your question, Bill?
                       DR. SHACK:  Just how fast was the flow
           rate?  I was zipping through?
                       MR. LUNCEFORD:  It was obviously
           significant enough to erode the carbon steel.
                       The next item for license renewal, a FAC
           item would be a failure we've had in a HPCI, an RCIC
           drain line downstream of the drain pipe.  Steam supply
           to the turbine, you've got a drain pipe.  You've got
           that line that's just going to the condenser.  It's --
           they have noted some FAC in that area and the response
           was to include portions of RCIC and HPCI in the FAC
                       It was originally excluded from the FAC
           program based on low usage.  Less than 2 percent usage
           under normal operating circumstances.  But we've
           included that in.  They don't model it, but they will
           periodically go out and look at those areas that will
           be most susceptible to FAC.
                       Torus corrosion.  The inner shell of the
           torus, there have been instances of minor corrosion
           pitting on that surface where the originally installed
           inorganic zinc primer and coating has broken down.  We
           have an aggressive coatings program that currently not
           only trends and tracks certain areas we've mapped out
           on the torus shell to see the rates of pit depth
           growth, the rates of corrosion, but we've also got an
           aggressive program to desludge the torus, to recoat. 
           They're using an underwater epoxy coating right now
           for repairs and are considering in the future what
           they may have to do to ensure the long-term viability
           of that coating.
                       MR. BARTON:  Do you inspect that coating
           every outage to your knowledge?
                       MR. LUNCEFORD:  They inspect, I forget
           which unit is which but currently, one unit is
           inspected every outage with divers.   The other unit,
           due to reduced corrosion rates, that we observed, is
           inspected only every other outage.  
                       MR. BARTON:  Why is the corrosion rate
           different there?  Is it different coating?
                       MR. LUNCEFORD:  I believe that the Unit 2
           is holding it better and it may be due to improved
           water chemistry controls implemented.  I don't know
           that they've established exactly why that coating is
           performing somewhat better.
                       Also noted, this was an issue that came up
           in a recent inspection for Aging Management Programs
           at Plant Hatch was general corrosion in exposed areas
           of the plant such as the intake structure, valve pits
           for service water, the EDG building roof area where
           the inspectors noted excessive rust on components,
           supports, etcetera and the plant has made that an
           issue to improve their identification and corrective
           actions in those areas.
                       One other item I'll mention is
           particulates in our diesel fuel tanks.  There have
           been instances of high particulates above the 10
           milligram per liter limit required by tech specs and
           those were all properly corrected by filtration or
           draining, cleaning the tanks and the plant is pursuing
           what methods they need to ensure that reduced
           occurrences of high particulate in those tanks.
                       I believe that is all the current items
                       MR. BARTON:  Back to service water or
           erosion problem you had.
                       MR. LUNCEFORD:  Yes sir.
                       MR. BARTON:  Did your erosion/corrosion
           program pick it up or was it a failure that led you to
           discover it?
                       MR. LUNCEFORD:  Service water, the service
           water line, if you're talking of the FAC program.
                       MR. BARTON:  Whatever you use for
           erosion/corrosion program.  Is that pick it up or did
           you have a piping failure, an actual leak and then you
           found out you had a problem?
                       MR. LUNCEFORD:  It is not an
           erosion/corrosion problem per se.  It's simply an
           erosion problem.  If you look at it from FAC --
                       MR. BARTON:  But don't you have a program
           in place that looks for that kind of stuff and picks
           out susceptible areas or potential areas that you
           could have this problem?  Don't you have a program
           like that?
                       MR. LUNCEFORD:  Correct, that's our plant
           service water piping inspection program.  I do not
           believe they identified all of those failures prior to
                       MR. BARTON:  Prior to, okay.
                       MR. LUNCEFORD:  Once they --
                       MR. BARTON:  What makes you have
           confidence that the program is effective?  What
           confidence do you have in your erosion program that
           it's effective?  If you're finding failures --
                       MR. LUNCEFORD:  The service water
           inspection program, one line was identified, they
           implement inspections of the other lines, trended
           those corrosion rates and the engineer at the site who
           is responsible for that, actively goes out and tries
           to identify.  If they do identify a failure, he will
           review other areas of the plant where similar
           materials, environments could exist and we include
           those in routine inspections.
                       DR. SHACK:  But that's not included in
           what you call your FAC program?
                       MR. LUNCEFORD:  That is correct.  It's
           covered by the plant service water inspection program.
                       DR. SHACK:  In other words, they really
           didn't expect it.
                       MR. BARTON:  I gotcha.
                       MR. LUNCEFORD:  It's not FAC is the point.
                       DR. SHACK:  A rose by any other name --
                       MR. BAKER:  I think the point we're
           making, the distinction is, there's an industry 
           program that might get confused with that in terms of
           the scope.
                       MR. LUNCEFORD:  That's all I have unless
           there's any other questions.
                       DR. UHRIG:  Question.
                       MR. LUNCEFORD:  Yes sir.
                       DR. UHRIG:  Are the two plants identical,
           even though they're several years difference?
                       MR. LUNCEFORD:  No.
                       DR. UHRIG:  What are the substantial
                       MR. LUNCEFORD:  I'll let Ray address that.
                       MR. BAKER:  Unit 2 has a hydrogen
           recombiner associated with containment.  Unit 1 does
           not rely on hydrogen recombiner.  That's one
                       DR. UHRIG:  Well, of course, those kinds
           of things, but in general, the types of systems are
           very similar.
                       The same power level.
                       MR. BAKER:  Yes.
                       DR. UHRIG:  Are you involved in this large
           PWR upgrade program?
                       MR. BAKER:  We have done the extended
           power upgrade on both units.
                       DR. UHRIG:  You've already done that?
                       MR. BAKER:  Yes.  Thank you.
                       MR. MULVEHILL:  Jeff Mulvehill, Southern
           Nuclear.  Changing the subject to switchyard and
           maintenance.  The plant is involved with monitoring
           and minor maintenance of switchyard components inside
           the protected area fence.  Any large item of
           maintenance such as replacement of a transformer would
           be a joint effort between Georgia Power Company and
           the plant people.
                       Inside the protected area fence, changes
           to the switchyard are controlled by the design change
           process there so and once you get beyond that fence
           into the transmission line area coming in and so
           forth, that's pretty much all Georgia Power.
                       MR. BARTON:  What control do you have over
           the work they do in the switchyard?
                       MR. MULVEHILL:  If they're working under
           a PCR, a design change request, they would have to
           follow the procedures that the --
                       MR. BARTON:  Station procedures?
                       MR. MULVEHILL:  Right.  
                       DR. BONACA:  Thank you.  All right, then
           let's move on now to the Time-Limited Aging Analysis.
                       MR. BURTON:  This is Butch Burton again. 
           I'm going to turn it over to John Fair from the staff
           to discuss the TLAAs.
                       (Slide change.)
                       MR. FAIR:  Good afternoon.  I'm going to
           go over the areas that were identified as 
           Time-Limited Aging Analyses at Plant Hatch and I'm
           going to discuss the open items that we have in the
           draft SER.
                       The first section is in the identification
           of TLAAs and we have two open items.  The first open
           item involves the fatigue analysis of components.  In
           the application, the applicant identified TLAAs for
           the reactor vessel and for the reactor coolant lube
           piping, but did not identify other major reactor
           coolant system components as TLAAs and did not
           identify the reactor vessel internals as a TLAA.
                       The staff reviewed the Hatch FSAR,
           identified that the reactor vessel internals had been
           discussed and a fatigue evaluation of the internals
           was identified in the FSAR so that we ask a question
           as to why this was not identified as Time-Limited
           Aging Analysis.
                       The response to our question was that the
           criteria of the vessel internals program, VIP-74 were
           used to identify items that are TLAAs.  We really
           didn't understand what that meant in terms of
           response, so we held this as an open item and maybe
           some misunderstanding in the terminology, but since
           there isn't an identified fatigue evaluation of at
           least the internals, we want to know how that was
                       And the second item there was really just
           a catch all, in case there's some other component that
           there was a fatigue evaluation.  We don't know from
           review of the FSAR whether there are.  But we'd like
           the applicant to identify if there's any other
           components they did fatigue evaluations on and how
           they dispositioned those.
                       The second open item in the identification
           TLAAs is one of the items of contention and that's the
           high-energy line break postulation based on fatigue
           cumulative usage factor.  Again, the staff believes
           this meets the definition of a TLAA per the 54.3
           criterion and the licensee's response was that they
           just used this criterion to select break locations and
           they really didn't consider it a Time-Limited Aging
                       This particular item was identified as a
           potential Time-Limited Aging Analysis, this high
           energy line break postulation based on cumulative
           usage factor.  In the statement of considerations of
           the rule, it's in the draft SRP as an item where
           there's a potential TLAA and I believe there was even
           an industry comment in the fatigue section of the SRP
           that this item should be identified as a potential
           TLAA.  So we're still holding this open as TLAA and
           want to have a discussion on how we're going to
           resolve the issue with the licensee.
                       DR. BONACA:  Are these under appeal?
                       MR. FAIR:  This is an item that's under
                       DR. BONACA:  Not the second one?
                       (Slide change.)
                       MR. FAIR:  Yes, the second one.  The
           second item is under the fatigue analysis issue and
           really the heading in the license renewal application
           is pipe stresses, the way the applicant has labeled
           this.  And the open item really is the resolution of
           environmental fatigue issue or the GSI-190 issue.
                       In response to the staff concern on this
           item, the licensee has referred to generic EPRI
           studies that were performed previously to try to
           address this generically for BWRs.  The open item that
           we have is really the applicability of these
           particular generic studies to specific locations at
           Hatch and we have on-going discussions, I believe, we
           anticipate with them to try to resolve this issue.
                       MR. DYLE:  If I could, John, just one
           thing to add to that.  This is Robin Dyle.  Not only
           are we working that between Hatch and the staff, this
           is also a generic issue that we're trying to work this
           particular resolution of environmental assisted
           fatigue with the MRP, so we're trying to develop not
           only the Hatch specific, but also a generic position,
           that others could use and this is on-going dialogue.
                       (Slide change.)
                       MR. FAIR:  The next ones are just -- I'll
           go over the items that were in the license renewal
           application, briefly, but there were no open items
           identified.  The first one was a corrosion allowance. 
           There were some specific piping systems that they had
           evaluated for corrosion and they went back and
           dispositioned those.
                       Environmental qualification, again, they
           dispositioned those.  We had no open items.  And they
           did have a calculation on containment pressurization
           cycles, a fatigue evaluation which they went back and
                       (Slide change.)
                       MR. FAIR:  The next area was the reactor
           vessel and really there were a number of subitems
           under this, but the issue is the effect of neutron and
           irradiation embrittlement and one of the various items
           listed under this.  And there were no open items again
           identified under this.
                       (Slide change.)
                       MR. FAIR:  The last item was an
           interesting item.  This is main steam isolation valve
           operating cycles.  This was originally identified as
           a TLAA by the applicant because they had specified in
           the FSAR a number of cycles.  They went back and
                       They had put this number in a design
           specification, but did not have the actual basis of
           why it needed to meet this number of cycles, so they
           decided this really doesn't constitute a TLAA and that
           they do have on-going programs to refurbish these
           valves and restore them.  So we accepted that
           resolution and there's no open item on this.
                       MR. BARTON:  Is this handled through the
           LLRT program and overhaul is needed?
                       MR. PIERCE:  That's one of the programs,
           that's correct.
                       MR. BARTON:  What's the other one?
                       MR. PIERCE:  There is a number of
           individual activities that are done on the MSIVs that
           I'd have to go back and refresh my memory on, but
           everything to tech spec., routine tech spec.
           surveillance, in terms of operating, testing, testing
           the valves for closure time and so forth are part of
           it as well.
                       MR. BARTON:  Okay.  I understand.  
                       MR. FAIR:  And that was the extent of the
           time-limited aging analyses done by the applicant.
                       DR. BONACA:  Are there specific questions
           from the members?
                       What I'd like to do is to ask Mr. Grimes
           to give us a summary of the five issues that will be
           appealed tomorrow?
                       MR. GRIMES:  I think it's four.
                       DR. BONACA:  I thought it was five.
                       MR. GRIMES:  I'll go back and enumerate
           the issues that are on the agenda for the meeting that
           we're going to hold tomorrow.
                       DR. BONACA:  Okay.
                       MR. GRIMES:  But rather than summarize
           them which I think is the purpose of the meeting that
           we're going to have tomorrow, I would suggest that
           we'll be able to better articulate what the nature of
           the dispute is after we've had an opportunity to sit
           down with the applicant and compare notes.  And just
           going through the agenda for -- the reactor building
           leakage, the use of the drawdown tests.
                       DR. SHACK:  Chris, on that one, they have
           a tech spec., right, so they have to test for that?
                       MR. GRIMES:  Yes.
                       DR. SHACK:  And you want an Aging
           Management Program as well as the inspection program
           and the test?
                       MR. GRIMES:  No.  The issue, as best as I
           can characterize it, without prejudice to my position
           as judge and jury tomorrow, the applicant conducts
           inspections of the secondary containment and they go
           around and they check the condition of the
           penetrations.  They have access controls to make sure
           that doors are closed when they're supposed to be
           closed.  They check all of the individual parts of the
           building in order to make sure that the building is
           standing up properly.
                       But they also perform a tech spec required
           draw-down test to demonstrate the leakage integrity of
           the secondary containment as a secondary containment. 
           The staff wants the leakage test to be included as an
           element of the aging management program and the
           applicant argues that's an unnecessary regulatory
           burden because the inspection of the individual
           component should be sufficient for the purpose of the
           aging management purposes.  I think I've fairly
           characterized the nature of the issue.  Details to be
           explored tomorrow.
                       The second issue is seismic II/I and that
           gets to the design basis for nonsafety stuff that
           could fall and prevent safety-related functions.  The
           applicant has designed seismic supports for the
           nonseismic piping and the staff has said that the
           piping could fail so the piping needs to be included
           in the scope as well as the supports.  And so we'll
           need to explore the extent of that scoping issue.
                       Pipe break criteria is a time-limited
           aging analysis.  There are -- the piping has a fatigue
           design and there's a fatigue analysis that's
           identified as the Time-Limited Aging Analysis, but
           there are also analyses that are performed to look at
           crack growths rates as it relates to where you
           postulate pipe breaks and so the pipe break criteria
           as a separate Time-Limited Aging Analysis is going to
           be discussed.  
                       And then, of course, the general question
           about housings as separate passive functions of active
           components.  And that generally applies to all HVAC
                       So those are the four issues that are in
           dispute that are going to be discussed in an appeal,
           but as John Fair pointed out, the rest of the open
           items we think that there's a course of resolution and
           we understand what information needs to be exchanged,
           but that still needs to be verified.  Our ability to
           be able to close all the open items and prepare a
           final safety evaluation in accordance with the
           schedule that Butch showed you earlier will still be
           monitored very carefully.
                       MR. BARTON:  The housing issues on HVAC
           systems plus standby gas treatment, right?
                       MR. GRIMES:  Yes sir.
                       DR. BONACA:  Thank you.  
                       MR. GRIMES:  I would point out and I'm not
           sure that we can promise that the results of
           tomorrow's meeting will be a sufficient basis for us
           to be able to tell you what the answer is by the time
           that we get to the full committee.  And so we'll need
           some guidance from the subcommittee in terms of what
           material you want presented for the full committee
           meeting on April 5th.
                       DR. BONACA:  Well, what I would like to
           ask you to do is to by some means to gather --
           depending on how the meeting goes tomorrow, and what
           the closure on the items are, probably no closure, but
           progress and clarification and making available to the
           members say by Friday, if you could.
                       And then I would like to have the members
           review these issues, what happens tomorrow and give me
           by e-mail to pass out to me during the weekend your
           thoughts.  I would appreciate that because I think
           I'll try to put together these comments and then bring
           them back next week for our use so we can discuss
           them, look at our perspectives and then be ready then
           for the presentations we receive from the staff and
           the licensee next week.
                       Okay, we may decide not to express an
           opinion or we may have an opinion at that point that
           we can express, but certainly that becomes an issue of
           agenda next week and you bring a position on the
           staff.  We will consider commenting on those.  So that
           would be helpful for me as a member to send me their
           perspectives on these issues, once we get the
           information from the staff.
                       With that, I believe we have completed the
           presentations.  I'm just asking now if there are any
           other comments or questions.  I see none.  
                       So what I would like to do now is to go
           around the table and see if any one of the members has
           any comment at this stage regarding what we have seen.
                       We have reviewed the application.  We
           heard the support provided by the BWRVIP program to
           this application and so I would like to gather your
           thoughts, if you have any this stage.
                       Bill, we'll go in this direction.
                       DR. SHACK:  No.  You know I don't see any
           major stumbling blocks here.  There are a number of
           open issues to be resolved.  I would say that I found
           their approach to putting together the report to be
           more confusing, for example, than the last example we
           saw at ANO 1.  The information may be there, but it
           just was more difficult to access.  I really did sort
           of miss the Appendix B compilation which I thought was
           a very nice feature of the ANO 1 license renewal.  If
           I see license renewals again I sort of hope they look
           like that.
                       DR. BONACA:  Okay.  Graham?
                       MR. LEITCH:  No, I don't really have
           anything to add except to echo Bill's comment that I
           did find I guess the word we're using is the
           navigation a little difficult, but I think now that I
           understand a little more clearly the layout of the
           report, I think it's quite understandable.  It was
           just somewhat confusing to me without some of the sort
           of tutorial we've had today.
                       DR. BONACA:  John.
                       MR. BARTON:  Well, I don't see any show
           stoppers, but I've got some concerns.  I think I'm not
           going to be at the full committee meeting, but I think
           the committee ought to hear the results of the staff's
           looking into some of the questions that we raised and
           the committee ought to be satisfied that those
           components are, in fact, covered by the Aging
           Management Program or not and also I think we ought to
           weigh in on where we stand on the issues that are up
           for appeal, whether we've got a strong position one
           way or another on that.
                       But as far as overall the application, I
           think, the committee gets satisfied with those and the
           answers that the staff will provide the full committee
           meeting.  I don't see a problem overall.
                       I think it was a harder process to review. 
           Took a lot more time to review it because you try to
           figure out where were things that you had seen before
           or located in this application and from a technical
           standpoint, it's not detrimental.  It's just from an
           administrative standpoint it was harder.
                       DR. SHACK:  We'll charge them for it.
                       MR. GRIMES:  I wish you'd be careful with
           that.  There is a fees issues on this plant as well.
                       MR. BARTON:  Oh yeah?
                       DR. FORD:  My main concern as I said
           earlier on was the whole question of the conservatism
           or otherwise, the disposition curve, and the process
           was compliant enough to take into account new data, if
           and when it becomes available.
                       I'm satisfied that that compliance is
                       DR. BONACA:  Tom?
                       DR. KRESS:  I agree with the comments on
           navigating through the documents and I agree with John
           Barton that we need to express our opinion, whatever
           it turns out to be on these appeal issues.  I'm
           particularly interested in two of those, the reactor
           building leakage issue and the question of what
           constitutes passive versus active in terms of
           housings.  I think there may be a need for some
           clarification of that and this may be a chance for the
           staff to clarify what the passive component really is.
                       I didn't see any major show stoppers and
           I also found that BWRVIP documents provide a pretty
           good basis for referencing and I thought those were
           pretty good documents, at least the ones we've
                       So that's about all I had.
                       DR. BONACA:  I could pretty much echo the
           same comments.  On the issue of navigation,
           navigating, that's why yesterday also, when we were
           talking about a generic approach, I felt that the
           earlier applications where you had scoping system and
           then the screening doggedly going to the outcome.  It
           was really helpful in the review process and helping
           people to understand on their own without searching.
                       So what I would consider the scrutability
           of the documentation that allows for the public as I
           said yesterday, we are the public in many ways, to
           feel the confidence that we know this stuff has
           reached a position if the audits hadn't taken place
           and you found that in fact the methodology was
           implemented as stated.
                       So I do believe that not specifically on
           the Hatch application, but maybe on the others, we may
           express some preference in that sense or direction in
           that the next applications have the opportunity to be
           clear or less clear.
                       I also have some -- I feel we need to
           express an opinion on these open issues because those
           are issues we have reviewed for other plants. I mean
           clearly, we looked at II/I.  I thought we had looked
           at those at casing components.  You're right.  We
           would not have looked at them.  I assume that they
           were being treated just like equipment on skids.  But
           there's a need for clarification on that particular
           issue.  In the context, I still feel, that's personal
           opinion that the rule specifically talks about passive
           components and active components and not inactive
           systems.  But --
                       DR. SHACK:  It looks a lot like an
           electrical cabinet to me.  
                       DR. BONACA:  Yes.  So I think we should be
           open about resolution that there will be reached on
           this.  I think we should look at them positively also
           because they're going to bring resolution to some
           issues on a generic basis and they're going to help
           finalizing the guidance documents that we have and
           making it easier for the industry.
                       And certainly we will look for answers to
           the questions that John raised and for which we have
           no answer.  They were good questions.  Good questions
           particularly because they give us some feeling about
           the scoping issue for which we have various questions.
                       I would like to just briefly now ask the
           members about what we should ask the staff to present
           next week.  There is a limited amount of time there.
                       MR. BARTON:  Bob wasn't here when you
           asked the question.
                       DR. BONACA:  Yes.
                       MR. BARTON:  How much time is on the
                       DR. BONACA:  Oh, I didn't see a question. 
           We skipped you.
                       DR. UHRIG:  I was out.
                       DR. BONACA:  Okay.
                       DR. UHRIG:  I don't have anything of major
           concern.  I spent most of my time concentrating on the
           electrical components and I see those resolved,
           essentially the same as the previous plants have been
           and it's satisfactory.
                       DR. BONACA:  Right.  Yes.  
                       MR. DURAISWAMY:  Did somebody ask a
           question of how much time we've got?  We've got two
           hours, scheduled for the agenda.
                       But that's for both the staff and --
                       MR. BARTON:  And the applicant.
                       DR. BONACA:  And the BWRVIPs.  We have to
           be parsimonious about how we spend the time.
                       DR. KRESS:  That includes the BWRVIPs,
           that two hours?
                       DR. BONACA:  Well, we're not going to have
           a specific view of those.  We're simply going to
           discuss the part of how they support particularly the
           internals and the vessels, some of the TLAAs and the
           other inspections.
                       MR. DURAISWAMY:  I don't think we're going
           to spend too much time on that thing, Tom.  I think
           primarily we're going to spend most of the time, I
           think I split them between the applicant and the
           staff.  So now we've got to get on about the agenda.
                       DR. SHACK:  You'd better let Gene
           Carpenter know that.
                       MR. DURAISWAMY:  Gene knows that.  We told
           him yesterday, unless he was sleeping.
                       MR. GRIMES:  Actually, this is Chris
           Grimes.  In Gene's defense, we were hoping to convince
           you to let Robin do 25 of the 30 minutes allotted for
           VIP and Gene could have the last 5.
                       You mentioned yesterday about half an
           hour's worth of VIP.  I would also suggest that you
           look at the way that you treated the BWR topical
           reports for the Oconee review as a model of what the
           desired outcome looks like.
                       DR. UHRIG:  Ar you going to spend time on
           the results of the appeals?
                       DR. BONACA:  Yes.  It seems to me that the
           first thing we need to talk about, the scoping and
           screening because this has been probably one of the
           places where we had some difficulty in reviewing, not
           because there is anything wrong with that
           fundamentally, but because we had some trouble with
           that issue.  Then, I think we need to understand the
           open issues as a summary with specific focus on those
           which have been appealed right now, understanding that
           others may be appealed in the future.  That doesn't
           preclude that.
                       But right now those are the ones on the
           table.  So and then I think we need to, as we talk
           about TLAA or even management programs to see how the
           BWRVIPs fit.  That will be the half hour dedicated to
           that.  It will be interesting to have again the
           perspective on how one-time inspections and the new
           problems have gone from application to application.
                       MR. BARTON:  You need the mike.
                       DR. BONACA:  Sorry, how they have gone
           from application to application, so we have an
           understanding of how that is evolving as we come
           closer to final documentation of GALL.
                       MR. GRIMES:  Dr. Bonaca, if I could
           suggest, we've committed to provide you with the cross
           cut of one-time inspections for the following session
           on improved renewal guidance.
                       DR. BONACA:  Okay.
                       MR. GRIMES:  So I would suggest for the
           purpose of the full committee meeting on the Hatch
           application, that if we could have the applicant
           simply decide on how they want to account for what's
           existing, what's modified, what's new in a very broad
                       DR. BONACA:  Exactly, and only as it
           fairly relates to Hatch.
                       MR. GRIMES:  Correct.
                       MR. GRIMES:  Okay, good.  I think that if
           you include all those items you pretty much will run
           out of time, so my suggestion is to stay with that and
           with whatever else you feel you want to communicate to
           us at that point and that goes for both the staff and
           the applicant.
                       MR. LEITCH:  Maybe you mentioned this,
           Mario, but I think Butch's slide that's labeled
           overview, the four important distinctions, first BWR,
           first use of the BWRVIP program, functional approach
           versus systems approach, that slide, I think --
                       DR. BONACA:  It's a good introduction.
                       MR. LEITCH:  That's a good introduction,
                       DR. BONACA:  One thing that I suggest is
           if the applicant finds a way to fit it in, the brief
           communication he gave us on the experience of the
           plants I think was very important because I mean it
           told us a pretty good story about the plants and the
           recent history of travel and the plants and a good
           history and so -- I think also that slide we saw
           yesterday where the capacity factor has improved so
           significantly through the years, I think is a
           demonstration that the initiatives of the BWRVIPs have
           been effective.
                       The other point we have noted yesterday in
           the presentation was that this is not only one plant
           operating and gathering information, but is three
           plants, before including maybe including foreign
                       So therefore, there is substantial
           experience being gathered of every year that is really
           applicable to every plant out there, so that gives a
           lot of additional confidence in the BWRVIP.  I would
           probably present that point as part of the BWRVIP
           element to the presentation.
                       Any other thoughts?  So if I remember now
           next week is going to be practically the whole morning
           first of all on Hatch and then --
                       MR. DURAISWAMY:  First two hours, 8:35 to
           10:30 on Hatch and then go the license --
                       DR. BONACA:  Okay.  Any other comments or
           questions for the members?  Comments or questions from
           the public?
                       None, the meeting is adjourned.
                       (Whereupon, at 1:37 p.m., the meeting was

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