Plant License Renewal (Turkey Point 3 & 4) - September 25, 2001


                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               Plant License Renewal Subcommittee
                               Turkey Point Units 3 and 4 Application

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Tuesday, September 25, 2001

Work Order No.: NRC-031                               Pages 1-272

                   NEAL R. GROSS AND CO., INC.
                 Court Reporters and Transcribers
                  1323 Rhode Island Avenue, N.W.
                     Washington, D.C.  20005
                          (202) 234-4433                         UNITED STATES OF AMERICA
                                 + + + + +
                                 + + + + +
                                 + + + + +
                            SEPTEMBER 25, 2001
                                 + + + + +
                            ROCKVILLE, MARYLAND
                                 + + + + +
                       The Subcommittee Meeting was called to
           order at the Nuclear Regulatory Commission, Two White
           Flint North, Room 2B3, 11545 Rockville Pike, at 8:31
           a.m., Dr. Mario V. Bonaca, Chairman, presiding.
                       DR. MARIO V. BONACA, Chairman
                       DR. STEPHEN L. ROSEN, Member
                       DR. WILLIAM J. SHACK, Member
                       DR. F. PETER FORD, Member
                       DR. NOEL F. DUDLEY, ACRS Staff Engineer
                                                        I N D E X
                        AGENDA ITEM                        PAGE
           Opening Remarks by Subcommittee Chairman . . . . . 4
           Florida Power and Light Presentation . . . . . . . 5
                 by Elizabeth Thompson and Steve Hale
           Introduction and Overview of SER Related . . . . .74
                 to Turkey Point License Renewal Application
           Presentation by R. Auluck, NRR . . . . . . . . . .74
           Presentation by G. Galletti, NRR . . . . . . . . .95
           Presentation by B. Thomas, NRR . . . . . . . . . 102
           Presentation by M. Khanna, NRR . . . . . . . . . 115
           Presentation by J. Davis, NRR. . . . . . . . . . 136
           Presentation by C. Munson, NRR . . . . . . . . . 139
           Presentation by P. Shemanski, NRR. . . . . . . . 143
           Presentation by A. Keim, NRR . . . . . . . . . . 149
           Presentation by B. Elliot, NRR . . . . . . . . . 152
                                                    (8:31 a.m.)
                       CHAIRMAN BONACA:  Good morning.   The
           meeting will now come to order.  This is a meeting of
           the ACRS Subcommittee on Plant License Renewal.  I am
           Mario Bonaca, Chairman of the Subcommittee.
                       ACRS Members and consultants in attendance
           are Peter Ford, William Shack, and Stephen Rosen.
                       The purpose of this meeting is to discuss
           the staff's safety evaluation report, with open items,
           related to the application for the renewal of the
           operating licenses for Units 3 and 4 of the Turkey
           Point Nuclear Plant, and associated Westinghouse
           Topical Reports.
                       The Subcommittee will gather information,
           analyze relevant issues and facts, and formulate the
           proposed positions and actions, as appropriate, for
           deliberation by the full committee.  Noel Dudley is
           the Cognizant ACRS Staff engineer for this meeting.
                       The rules for participation in today's
           meeting have been announced as part of the notice of
           this meeting previously published in the Federal
           Register on September 11th, 2001.
                       A transcript of the meeting is being kept
           and will be made available as stated in the Federal
           Register Notice.  It is requested that speakers first
           identify themselves and speak with sufficient clarity
           and volume so that they can be readily heard.
                       We have received no written comments or
           requests for time to make oral statements from members
           of the public regarding today's meeting.
                       We will now proceed with the meeting --
           well, before we do that actually, I would like to make
           just a couple of brief announcements.  One is that you
           all know that one of our members, Graham, had a heart
           attack, and he had a second one, I believe, on Friday. 
                       He is in good shape, but certainly could
           not join us here.  So I gave him our best, and I think
           we hope to have him back for the Hatch application. 
           So, that is one issue.
                       The second one is John Barton could not
           make it.  He had some problems with transportation and
           things of that kind.  He sent us a number of good
           comments, and if the applicant and the NRC will be
           patient with us, we will try to do justice to his
                       And as we walk through the presentations,
           we will go through them and where they seem to be
           significant, we will talk about them.  That may force
           me to break the flow of the presentation and go back
           to his comments, but I think that is the only way we
           can do justice to them.
                       So with that we will now proceed with the
           meeting, and I call upon the Florida Power and Light
           Company to begin.
                       MS. THOMPSON:  Good morning.  My name is
           Liz Thompson, and I am the project manager for Florida
           Power and Light.  With me here today is Steve Hale,
           and he is the licensing and design basis leader for
           FPL as well.
                       We have prepared a presentation to go
           through the process that we used for generating the
           application, the IPE portion, or excuse me, the IPA
           and the TLAA portions, and Steve is going to lead us
           through that using the overhead projector.
                       MR. HALE:  Good morning.  Like Liz said,
           I am Steve Hale, and I am the licensing lead for FPL's
           nuclear plants and terms of license renewal.  I will
           try to keep this as interesting as I can.
                       The topics identified by the ACRS
           Subcommittee that they were interested were to go
           through a background, and go through our scoping and
           screening process, go into how we performed our aging
           management reviews, and then talk about our time
           limited aging analyses.
                       In terms of background, FPL began
           strategic planning for license renewal of our nuclear
           plants around the 1992 time frame.  This followed
           issue of the original version of the license renewal
                       We have been active in the license renewal
           industry groups, like the Westinghouse Owners Group,
           the license renewal group, and the NEI task force and
           working groups since about 1993.
                       We began in earnest our IPA and TLAA
           efforts in 1999, and we submitted the application in
           September of 2000.  The safety review requirements and
           guidance that we had available to us at that time were
           the 10 CFR Part 54, the revised version that was issue
           in the mid-1990s.
                       We had a draft standard review plan for
           license renewal, but that has changed drastically.  We
           tried to keep up with the GALL report.  We had
           technical reps on the groups at NEI that reviewed the
           mechanical, civil structure and electrical sections of
           GALL as it was going along.
                       We had a draft version of the Reg guide,
           and we also had available to us NRC position letters
           on certain particular issues like consumables and that
           sort of thing.
                       We were active participants on the
           development and issue of NEI 95-10, and we 
                       also had as part of the Westinghouse
           Owners' Group effort developed some guidelines on how
           to do an IPA, as well as review your TLAAs.
                       In terms of our work process itself, and
           namely that scoping, screening, aging management
           reviews, and TLAA identification and evaluation, we
           piloted our initial procedures in 1996.
                       And by piloting we actually tried to
           produce sample products and that sort of thing, and
           then factored in improvements that we could see.  We
           tried to structure them around the design basis tools
           that we had available to us.
                       We have a controlled electronic database,
           and we have design basis documents that were developed
           in the late '80s and early '90s, and those were very
           useful in performing this process.
                       We made a number of information trips to
           various applicants that were very active in license
           renewal at the time.
                       And then we went back to the one that we
           felt more compared -- you know, fairly well with, to
           the tools that we had available to us, and we spent a
           lot of time reviewing your detailed technical
                       Some of the other things that we did was
           that we tried as best we could, because it was kind of
           a moving target, to factor in lessons learned from a
           review of previous applications, looking at REIs, and
           REI responses, and looking at resolution of generic
                       And we tried to factor those into our
           procedures and output documents as best we could.  We
           did perform all the work in support of our license
           renewal application in accordance with our quality
           assurance program, and we also chose to have
           independent peer review groups, both internal, as well
           as external peer review groups, come in and look at
           our products and our procedures.
                       And these were folks from various
           applicants, as well as some technical experts in the
                       DR. SHACK:  I was just curious about that. 
           One of the more contentious issues that always seems
           to come up on a license renewal is how you handle the
           effect of the environment on fatigue life.  And
           through the REI resolution, you seem to have come up
           with a good solution to that problem.
                       But I was a little curious as to why you
           didn't anticipate that question was going to come up. 
           It has come up in every license renewal so far, and I
           am sort of waiting to see it built into the
           application, rather than coming out of an REI.
                       Well, I think one of the reasons is
           because we were the first B-31(1) plant, and we didn't
           really know what the issues would be.  Now, we did try
           to address concerns relative to NEUREG 62-60, which we
           did include in our application.
                       And we tried to address the concerns as we
           saw them, and we factored in, in fact, the commitments
           regarding the surge line consistent with what ANO had
           committed to.
                       But there was a lot of questions that came
           out regarding the pressurizer, which had not been
           asked previously, and the GTR, the Westinghouse GTR
           that was submitted as a stand alone document for all
           Westinghouse plants, had flagged some high fatigue
           areas in the pressurizer.
                       DR. SHACK:  That was one of the more
           curious things in the thing.  They had it flagged, and
           for you it was a "no, never mind" thing.
                       MR. HALE:  Right, but we went back and
           looked at the pressurizer specifically for Turkey
           Point.  And I think that is probably where a lot of
           those REIs were based on.  Whereas, you didn't really
           see a lot of that in the previous applicant.
                       CHAIRMAN BONACA:  I have a question that
           is more general to the same.  Clearly, your
           application is somewhat one of a kind again, because
           you didn't have final documents, like NEI finalized
           documents, or the SRP, or the GALL report.
                       How different do you think it would be,
           this application today, if you had had started from
                       MR. HALE:  I think that probably we would
           have figured in GALL as much as we could.  It is
           interesting that you ask that, because we are in the
           process of developing the application for St. Lucie
           right now, and we are facing that.
                       We want to try and use the approach that
           we took at Turkey Point, but at the same time
           integrate what we have available to us in GALL.  And
           we are doing things like including GALL references in
           the component commodity listings.
                       And where our programs fit within the
           bounds of the GALL programs, we are simply going to
           say that we are consistent with GALL.  So, we are
           doing that.
                       CHAIRMAN BONACA:  Okay.
                       MR. HALE:  We see the GALL as the main
           area where we can benefit from what is out there. 
           With regards to scoping, we kind of walk through a
           two-stage process.  When you go to look at the plant,
           our plants define the terms of systems and structures.
                       So the first step that we wanted to take
           is to identify which systems and structures had
           portions that were safety related, and we said that
           the whole thing was safety related.
                       And then the next step is that we looked
           at the various components that make up that system,
           and determine which ones support the functions and
           which ones don't.
                       So we started first in the system and
           structure level, and when I say system, we are at the
           cooling system, and safety injection system, and our
           HR system, and structures, containment and this sort
           of thing.
                       And you can see those results which are
           presented, and I believe it is in Section 2.2 of the
           application.  The purpose of scoping is to identify
           systems and structures which are either safety
           related, non-safety, which can affect safety related.
                       And then the five regulations regarding
           fire protection, environment qualification, PTS, ATWS,
           and station blackout.  More safety related, when you
           compare the safety related definitions in Part 54,
           they are consistent with what we call safety related
           in our quality instructions, and consistent with how
           we classified safety related components in our plant.
                       The sources of information that we used in
           defining what was safety related -- and again, even if
           only a portion of the system was credited, in terms of
           -- or had components that were safety related, the
           whole thing was considered safety related for future
           component scoping.
                       We used the UFSAR, and we used the tech
           specs.  We used our license correspondence database. 
           We have all of our licensing correspondence, both to
           and from the FPL and the NRC electronically.
                       Our design basis documents, and our
           component database, and our control design drawings. 
           And again we reviewed all systems and structures to
           determine if there were any safety related components
           within them.
                       For non-safety which can affect safety,
           this is probably one of the more challenging portions
           of scoping, especially for an older plant, where you
           are looking at non-safety related systems which could
           potentially affect safety related systems.
                       Again, we looked at the UFSAR tech specs,
           our licensing correspondence files, our DBDs.  We have
           a section of our design basis documents that walks you
           through all the assumptions like for pipe break,
           seismic criteria, and that sort of thing that we
           source when we are looking at interactions.
                       Our design drawings, as well as pipe
           stress analysis, because you have to go and look at
           what portions where you have a boundary, and you
           credit an additional piece of pipe in support of that,
           and we had to include that pipe in the scope of
           license renewal.
                       We saw two categories.  You have a
           category of non-safety related system, which actually
           performs a function that supports the safety related
           system.  An example would be a NVAC system on a long
           term basis that needs to run to support a safety
           related function.  And then we had interactions.
                       MR. ROSEN:  Hold on for a minute.
                       MR. HALE:  Yes.
                       MR. ROSEN:  Why wouldn't a system that is
           needed to provide functional support for a safety
           related system also be safety related?
                       MR. HALE:  The design of Turkey Point
           originally in the late '60s and early '70s didn't
           classify HVAC systems similar to what you would
           classify them today.
                       Now, control room HVAC is safety related,
           but you had some of those heating or cooling
           functions, or ventilation functions, that weren't as
           clear, in terms of criteria, when Turkey Point was
           originally licensed.
                       We carry a special augmented quality for
           those ventilation systems, but they aren't classified
           safety related.
                       MR. ROSEN:  They would be classified
           safety related, for instance, at St. Lucie, a later
                       MR. HALE:  Yes.  Yes, they are.
                       MR. ROSEN:  Okay.  Thank you.
                       MR. HALE:  But when you look at the older
           plants HVAC, it is a little different than what you
           would see in a newer plant.  In terms of license
           renewal, they are all in the license renewal.
                       And the other was in the area of
           interactions, where you have a safety related or non-
           safety related systems based on assumed failures could
           impact the safety related system.  So those two
           categories are what we looked at.
                       With regards to the regulated events, we
           have a lot of design tools at our disposal, in terms
           of determining what is in the scope and what isn't. 
           Again, we used our UFSAR and tech specs, and licensing
           correspondence, DBDS, our component data base, and
           design drawings.
                       But in addition to that, we have a safe
           shutdown analysis and a central equipment list with
           regard to Appendix R.  We have the EQ list as
           integrated into our component database.
                       And for station blackout, we have load
           lists, in terms of what is required post-station
           blackout in order to support the plant.
                       Okay.  Now that we have identified what
           systems and structures are in the scope of license
           renewal, we proceed to screening, the purpose of which
           is to identify structures and components which require
           an aging management review.
                       We step through this by first looking at
           all the components or structural components that make
           up the system or structure, and determine whether that
           component or structural component supports the
           functions of the system or structure.
                       And then we look at the screening
           criteria.  Is it passive as defined in the
           regulations.  You know, performing the intended
           function without moving parts or change the
           configuration or properties.
                       And is it subject to replacement based on
           qualified life.  And we decided in screening that it
           made sense to us to segregate the three major
           disciplines; mechanical, which is more system oriented
           in the structural area, and had very similar
           components in each one of the buildings.
                       And then in the electrical area, based on
           the types of components that you have in the
           electrical 9C systems, and it was best to take a
           different approach there.
                       So for mechanical systems, we established
           valuation boundaries and interfaces, in terms of where
           the systems were, and this is that system, and this is
           this system.  And we made sure that we had everything
           picked up.
                       And then we identified or actually mapped
           functions of the system, the license renewal system
           intended functions, on to the drawings to establish
           what pieces support the various functions.
                       And then we identified the various
           components in that system that support those
           functions.  After we got that, we have a list of
           components that support the system intended functions,
           and this is all three scoping criteria.
                       And then we identified whether they were
           passive or not, which is fairly extensive information
           in the NEI and standard review plan regarding how you
           do that.
                       And then long lived.  We looked to see if
           these things were procedurally replaced on a regular
           basis, in terms of qualified life.  And then after
           that, we identified individual component functions.
                       You know, like pressure boundary, heat
           transfer or whatever it might be for that particular
           function, or for that particular component.
                       CHAIRMAN BONACA:  I don't know if this is
           the right time to ask questions.
                       MR. HALE:  Sure.
                       CHAIRMAN BONACA:  But in the plant level
           scoping results, you know, you have tables in the
           back, Table 2.2.1., where you do have an
           identification of systems or components, and then
           structures, but the structures are later.
                       And we have a number of questions about
           the number of systems that were excluded, and I would
           like to ask you, first of all, penetration cooling
           that was excluded from scope.
                       MR. HALE:  Yes, there is a particular
           analysis that was performed at Turkey Point.  Our hot
           penetrations go to the outside.  I mean, we don't have
           a building around where the main steam and feed water
           blowdown penetrations come out.
                       And it was an actual analysis, and it is
           in the UFSAR, in the structural section, that says
           that even without cooling, temperatures will not
           exceed 150 degrees.
                       CHAIRMAN BONACA:  Okay.
                       MR. HALE:  And so all of our peer reviews
           -- well, that is a good question.
                       MR. ROSEN:  What do you mean by hot
           penetrations that don't exceed 150 degrees?
                       MR. HALE:  Well, the area around -- the
           concrete around.  You know, you have a flute head
           inside containment on the steel side, and you have a
           main steam pipe that comes out.
                       So you have an air space around the
           penetration, the actual containment penetration proper
           in the pipe that comes out.  That goes to the outside. 
           So that space right there is exposed to an outdoor
                       MR. ROSEN:  What do you mean by high
                       MR. HALE:  Penetrations that are hotter
           than 150 degrees.
                       MS. THOMPSON:  Classically -- this is Liz
           Thompson speaking.  Classically, you would talk about
           those as being, for instance, lines that you look at
           for high energy evaluations.
                       MR. HALE:  Yes, typically they are your
           main steam, feed water, and a blow down lines for a
                       CHAIRMAN BONACA:  The next question I had
           was -- and actually this came from John Barton, and is
           regarding RAD waste building ventilation, and why that
           was excluded.
                       MR. HALE:  We have a document basis in the
           application regarding RAD waste systems in general. 
           We basically looked -- our RAD waste building is an
           independent building.
                       The consequences of radioactive, both
           liquid and gastrious releases, are so small that we
           looked at the scoping criterion under Part 54, and it
           is a small fraction of Part 100 limits for all of our
           radioactive waste accidents.  So we excluded RAD waste
           system on that basis.
                       CHAIRMAN BONACA:  And some of this, you
           know, I looked at myself, and I could not find a
           discussion, however, in the application.  I mean, the
           results is here in the table, but --
                       MS. THOMPSON:  On the other side of the
           table, there is a copy of the application, Steve.
                       CHAIRMAN BONACA:  So there is a
           discussion.  You don't have to give me -- well, you do
           have a discussion.
                       MR. HALE:  I will give you a reference
           after we are done.
                       CHAIRMAN BONACA:  Okay.
                       MR. HALE:  We did cover it, I believe, in
           the methodology section.
                       DR. FORD:  Could I come back to Steve's
           earlier comment about the classification of non-safety
           related items, which would affect a safety rating, and
           which are not included in your proposal because of the
           age of your plant, and which would be included, for
           instance, in St. Lucie.
                       I can understand that maybe there is a
           regulation reasoning for this, but is there a physical
                       MR. HALE:  We just said that they weren't
           classified safety related.  We have included the HVAC
           system in the scope of license renewal, regardless of
                       DR. FORD:  Okay.  So it is not just a
           question of putting the rules because of the age of
           the plant in one era, and changing them for --
                       MR. HALE:  And there are various
           classifications.  Typically what we find is that, for
           example, we credit the exhaust building exhaust fans. 
           They are not safety related, but they are credited for
           fire protection, and they are credited for station
                       And they also carry an augmented quality. 
           It doesn't go to the full extent, but they do -- but
           they are treated special, and they are controlled
           under our QA program.
                       MR. ROSEN:  Can you identify what the
           differences are?  For example, if today you declared
           them safety related.  What additional controls and
           processes would be applied to those components that
           are not now applied?
                       MR. HALE:  Really none, because I think
           probably -- because even in new plants the only tech
           specs you have are typically associated with charcoal
           filter systems.
                       Well, I take that back.  Well, control on
           the air-conditioning is one.  But in terms of material
           control, quality assurance, we maintain a similar
           level to safety related for our HVAC systems at Turkey
                       So I think it was more of an evolution of
           the industry, you know, when you look at the old
           plants versus the newer plants.  I think the important
           thing those is that we have included them all in the
           scope, and they have got an aging management review,
           and they were determined to be in the scope for the
           maintenance rule as well.
                       CHAIRMAN BONACA:  All right.
                       MR. HALE:  
                 So they are already under observation inspection
           and being managed.
                       CHAIRMAN BONACA:  The next question is
           that it says on screen wash.  Why are screen wash not
           in the scope?
                       MR. HALE:  Our screens are, but our screen
           wash isn't.  And the reason there is that when you
           look at the flow rate for intake cooling water, it is
           very small as compared to circ water.  
                       We need screen wash for circulating water,
           but under accident conditions, our circ water pumps
           are not running.  So you are looking at a very small
           percentage.  So we included the screens to preclude
           any small debris, and that sort of thing which may be
           in the intake.
                       But we didn't credit the fact that the
           screens have to run and you need to rinse this stuff
           off of it.  And we still have our strainers that are
           downstream of that, and which are cleaned periodically
           as well.
                       CHAIRMAN BONACA:  So you do have in any
           event programs to clean them and to inspect them?
                       MR. HALE:  Oh, yes, but we just didn't
           need to credit them for license renewal.
                       MR. ROSEN:  I understand your comment as
           to safety related water flows through those screens.
                       MR. HALE:  Yes.
                       MR. ROSEN:  And even after the main pumps
                       MR. HALE:  Right.  But it is such a small
           amount that it wouldn't -- that you wouldn't get a
           backup to where you would actually block flow in water
                       MR. ROSEN:  So the service water system
           takes suction from the same bays as the main
           circulating water system?
                       MR. HALE:  Right.  Right.
                       MS. THOMPSON:  And for clarification, the
           safety related service water system at Turkey Point is
           called the intake cooling water system.  The service
           water system at Turkey Point is actually a non-safety
           related, like potable, water type of a system just for
                       MR. ROSEN:  Thank you again.
                       CHAIRMAN BONACA:  And that is one thing,
           that when you read through, you are left with the
           question of how come this is not, and then you think
           about it and you say, well, I am sure that they have
           some programs ongoing now that are not described, even
           among existing programs and that are being used to
           monitor the systems and this was one.
                       MR. HALE:  Right.
                       CHAIRMAN BONACA:  But to some degree -- I
           mean, I guess it is the format of the applications
           that we received that it just doesn't provide that
           information.  It leaves the reader with the impression
           that things are not being done.
                       One question, for example, that was raised
           by John Barton that comes later, but I can raise it
           now, is that I believe on the fire protection, the
           sprinkling systems.
                       There is a one time test, I believe,
           during the last 10 years of the license life -- and
           maybe we have to wait until we get there, but is the
           testing of wet pipe sprinkler systems starting in the
           50th year of operation.
                       And it leaves us with the question of is
           this system never tested before?
                       MR. HALE:  Oh, no.  If you look at the
           fire protection program description, we have extensive
           testing that we do on the fire protection system.  The
           issue that was raised there was that there was a
           particular criteria in NFPA 25 regarding sprinkler
           head inspections at year 50.
                       And so as a result of the staff review,
           they had asked us to include that in our commitments,
           which we did.
                       CHAIRMAN BONACA:  Yes, and this I think
           came up in previous applications.
                       MR. HALE:  Right.  Right.
                       CHAIRMAN BONACA:  Okay.  I remember now. 
           Okay.  I understand.  It is just the impression that
           one is left with, is this question, you know.  And in
           many cases, we know that there is a lot of going on.
                       But since you are referencing existing
           programs, one would expect some mention of that and at
           times we don't see it.  So --
                       MR. HALE:  The NRC regional inspections --
           and I can tell you this much right off.  They did a
           very detailed review of the programs, and Hibo Wang,
           who was the civil rep, can tell you about that.
                       But they sept a lot of time looking at our
           programs, in terms of -- and comparing them against
           our AMRs to ensure that our programs are managing the
           effects that need to be managed.
                       CHAIRMAN BONACA:  Yes, and if you can be
           patient with me, I will go through this list so that
           we can get through them under the plant scoping.
                       MR. HALE:  No problem.  No problem.  There
           were three electrical systems.  One is a C-Bus
           electrical switch gear and closure, the main auxiliary
           transformers, and the start-up transformers.  And that
           was not clear to me why they were excluded from the
                       MR. HALE:  The C-bus was a bus that we had
           installed that was powered from the switch yard, and
           it powers non-safety related loads.  It was basically
           to -- you know, like a feed pump, main feed pumps.
                       It was really to take some of the load off
           the existing plant buses.  The auxiliary and start-up
           transformer, our assumption was that you have your
           diesels, in terms of on-site power supply from a
           safety related standpoint.
                       And you don't need your aux and start-up
           transformers for safety, and non-safety, which can
           affect safety, and certainly not station blackout.
                       CHAIRMAN BONACA:  But the basic
           assumptions in the accident analysis is that you have
           also no low power in some cases, right?  You would
           depend on that.  I mean, it is not only that the --
                       MR. HALE:  We don't rely on it, you know,
           in terms of our accident analysis, or in any of the
           regulated events.  And fire protection, the assumption
           is that you have to demonstrate that you can handle it
           with some loss of off-site power.
                       CHAIRMAN BONACA:  Okay.  So you don't
           consider them because of that?
                       MR. HALE:  There are components, certain
           terms of plant availability.  You know, you want your
           aux transformer and that sort of thing.
                       CHAIRMAN BONACA:  And then the other thing
           that we had on the list here from John Barton is the
           off-site communications tower is not in scope, and --
                       MR. HALE:  Well, we have on-site
           communications.  In fact, after Hurricane Andrew, we
           developed 3 or 4 different alternatives on-site.  So
           it is not required.
                       CHAIRMAN BONACA:  No, this would be off-
                       MR. HALE:  Right, but the off-site one is
           not required, in terms of communications.
                       CHAIRMAN BONACA:  Okay.  It is not
                       MR. HALE:  No.
                       CHAIRMAN BONACA:  For an emergency plan or
                       MR. HALE:  Right.
                       CHAIRMAN BONACA:  And finally the switch
           yard relay inclosure and the condenser.
                       MR. HALE:  We don't credit the condenser
           for any of the scoping criteria, 54.4, nor the switch
                       CHAIRMAN BONACA:  Okay.
                       DR. SHACK:  Just to continue on the
           scoping a little bit.  One of the things that we sort
           of looked at and suggested in other reviews is do
           people look at EOPs, because again this is sort of
           discussing equipment that people are relying on.
                       And just making sure that that equipment
           is somehow checked in license renewal, but I noticed
           that it is not one of the documents that you look at
           here for your scoping study.  Are you confident that
           everything that you need in your EOPs is somehow
           covered here?
                       MR. HALE:  Yes.  Yes, we are.  One of the
           things that we did do was compare our scoping results
           against maintenance real scoping results for
           consistency, and one of the items under the
           maintenance rule is the EOPs.
                       So we felt confident by doing that
           comparison that we could -- that we would capture any
           differences that there may be.  So that was the main
           thing.  We found that we didn't really need to go into
           the EOPs themselves.
                       MR. ROSEN:  I am taking your answer as you
           relied on the maintenance rule scoping for the EOPs.
                       MR. HALE:  Well, we don't -- the EOPs is
           not a scoping criteria for license renewal.  And we
           don't have to check the maintenance rule files as part
           of our license renewal scoping.  There are differences
           between license rules and maintenance rules.
                       But we did go compare against the
           maintenance rule for consistency.  It still is not a
           criteria under license renewal to do that.
                       CHAIRMAN BONACA:  Okay.  I have another
           question which probably will go to the staff more than
           you, but I think it is about the spent fuel pool.  And
           I noticed that you included the spent fuel pool
           cooling in scope.
                       MR. HALE:  Yes.
                       CHAIRMAN BONACA:  In fact, you identified
           for the spent fuel pool system three intended
           functions.  One is the pressure bundle integrity, and
           two is heat transfer, and three is culling.
                       And so you have a number of components in
           scoping, including the cooling of the pumps and so
           forth.  Now, you do have an emergency makeup system to
           that pool outside of the cooling system. Is it tied to
           the high pressure injection system or something?
                       MR. HALE:  I am not sure.  Do you know,
                       MS. THOMPSON:  Well, yes, there are makeup
           systems.  I am not sure if it is tied to high pressure
           injection, but we certainly have that capability.
                       MR. HALE:  We had to upgrade after our
           second rerack, and we upgraded our system to a seismic
           category one safety related system.  We felt that we
           were managing the system.
                       CHAIRMAN BONACA:  Well, actually, I feel
           that you went beyond the normal scope that we saw
           before.  I mean, for other plants that we have
           reviewed before, the only function identified was
           pressure bundling integrity, and then the steel liner
           was the only component in scope because there was an
           emergency makeup water coming from high pressure
                       And I am just questioning why there is
           this variability in different applications.  Is it
           tied to just the design basis?  I mean, how come you
           have such differences in functions being identified,
           and I guess that is a question for the staff.
                       MR. HALE:  Well, I can tell you from my
           own experience looking at our two sites that the
           original design, for example, at Turkey Point was an
           emergency makeup.
                       But as a result of fuel consolidation in
           the spent fuel pits,  you go through a upgrade as you
           license that.  For example, at Turkey Point, we
           upgraded the cooling system to seismic category one,
           and we replaced the liner with a quarter-inch
           stainless steel liner plate which was not there
                       Redundancy.  I go look at Unit 2, and you
           have got a totally redundant system at St. Lucie Unit
           2.  At Turkey Point, we didn't originally, but it was
           upgraded.  So I think that has something to do with
           it, is based on where various plants are regarding
           upgrades that might have taken place through time.
                       CHAIRMAN BONACA:  But I still -- I mean,
           I feel at some point, for example, the GALL report
           will have to have some base line acceptance of both
           functions which are credited for license renewal for
           that system, and therefore, the specific components
           that come through that scoping and screening process
           that identifies those functions.
                       I mean, I am just uncomfortable about the
           difference in scope, particularly the one that has to
           do with the inclusion of the cooling system that was
           excluded from the previous applications.
                       MR. KOENICK:  This is Steve Koenick with
           the staff.  You have to look at the licensing basis.
           A lot of these other plants, they were required to be
           safety related.  They did have the boiling and makeup
           as a design basis.
                       So there will be variability like Steve
           was saying between the vintage of plants and what they
           were designed and licensed to.
                       CHAIRMAN BONACA:  I understand that, but
           I certainly wasn't very happy with the exclusion of
           the cooling system from scoping and screening in the
           previous applications.
                       But I understood the logic of that.  Now
           I see an application coming and it goes beyond the
           requirements we saw applied before, whatever the
           reason may have been.
                       And I am left with the question in my mind
           not regarding this application or the previous one of
           why those components should be excluded to start with.
                       I mean, is there something regarding the
           license renewal rule that allows you maybe not to
           include things that should be there?  You see, that is
           really the question, and this is a significant
           discrepancy here.
                       MR. KOENICK:  Well, as Steve was saying on
           Turkey Point, in order to rerack their pool, I don't
           know all the details, but they essentially needed to
           upgrade to become safety related.
                       And other plants, if you look at the
           scoping criteria, today they are not safety related
           cooling systems.  It's not that they are not being
           maintained and that there is not programs and
                       But when you look at what the criteria for
           license renewal are, these systems on some of the
           other plants that you have looked at don't meet that
           criteria, and that is the way that they are operating
                       CHAIRMAN BONACA:  But do you feel
           comfortable that those systems then are going to be
           effective for the next additional 20 years of
                       MR. HALE:  Yes.
                       MR. KOENICK:  Yes.  You know, license
           renewal is only looking at select systems that are
           based on the scoping criteria that are safety related
           or that can in effect fail safety related.
                       The licensees have programs and
           maintenance procedures for all the other systems, too. 
           It's just that we are taking a particular look at
           certain ones for renewal to ensure that the plants
           will continue to have the safety margins that they
                       CHAIRMAN BONACA:  Okay.  Anyway, I don't
           have a problem with your application.  I mean, you
           went beyond what we have seen before.
                       MR. HALE:  We are very happy.
                       CHAIRMAN BONACA:  And I think you have
           certainly recognized the intended functions that I
           always thought had to be there.  So, that's good.  I
           have one more question.
                       MR. HALE:  Okay.
                       CHAIRMAN BONACA:  Your Table 2.2.1 is a
           list of all of the component mechanical systems, and
           then when I got to Table 2.3.2, I find that there is
           a very effective, I think, resolution of the renewal
           applicant action items coming from the supporting
           Westinghouse documentary report.
                       MR. HALE:  Okay.
                       CHAIRMAN BONACA:  And although you did not
           reference it in the application; however, you do have
           significant discussion into the application and also
           in the SER.  I could not find the one for the
                       MR. HALE:  Well, at the time that we
           submitted the application, we had two draft SERS.  We
           had piping and we had supports.  So, when we
           submitted, we did not have that available to us for
           the pressurizer or for the internals.  Now, what
           happened --
                       CHAIRMAN BONACA:  But you must have used
           it, because the SER, all the pressurizers specially
           identifies four renewal applicant action items, and
           then discusses the reason why or whatever you are
           proposing is acceptable.
                       MR. HALE:  As part of our REI process, and
           the staff I'm sure will describe this to you, and
           maybe this afternoon, but we got REIs relative to the
           open items on the pressurizer.
                       They reviewed our application and in those
           cases where the applicant action items weren't
           addressed, they asked us in the REI and we responded
           to it.
                       In the case of the internals, they asked
           us all 11 of the applicant action items as an REI.  So
           what you will find is our responses to those in our
           REI responses, and it might have been in the reactor
           coolant system REI response.
                       I am not sure about that, and so it was a
           combination of considering where they were with the
           WCAPs at the time.
                       CHAIRMAN BONACA:  Okay.  I understand.
                       MR. HALE:  They all have SERs now, and we
           have also done a check where we stand against them,
           and we took them either through our application or in
           the REI responses.
                       CHAIRMAN BONACA:  Well, I bring it up
           because I thought it was an excellent way of
           documenting resolutions in an open fashion so that you
           understand the true linkage between the supporting
           topical reports, and the way they had been used in the
                       And I liked it so much that when I went to
           the pressurizer, I said where is it, and so I
           understand now.
                       MR. HALE:  That's good feedback.  Thank
                       CHAIRMAN BONACA:  Okay.
                       MR. HALE:  With regards to civil
           structural screening, we took a very similar approach
           to what we had done in the mechanical area to each
           structure.  We identified the various structural
           components that make up each structure.
                       One point that we wanted to make is that
           the non-current carrying electrical 9-C components,
           these are enclosure supports for conduit, and conduit
           cable trays were included in the civil structural
           area, because they are really structural components.
                       We looked at the various structural
           components that support each of the structure intended
           functions, and then we went through the passive, long-
           lived checks in the regulations with regard to
                       Of course, most of the civil structural
           items are passive, and typically they are not replaced
           on a regular basis.  So most of the stuff comes
           through in terms of requiring an aging management
                       And then we identified the individual
           functions of the structural components.  In the
           electrical 9-C area, for efficiency, it makes a lot
           more sense to walk through this in a little different
                       For example, if I do a download in our
           database of electrical components associated with a
           480 volt load system, I may get 18,000 components, and
           to go through that one when a majority of them are
           active, it makes more sense to -- you know, let's look
           at the active stuff, and get it out first, and then
           look at what we have left.
                       So we identified all the component
           commodity groups, and we identified the functions as
           being very similar to approaches taken by previous
           applicants.  And then we identify the component
           commodity groups that were passive.
                       One point that I wanted to make was that
           if it was in the EQ program, we said that it is
           subject to replacement based on qualified life, and I
           think that's it.  Yes, that's it.  I'm sorry, I
           thought I had another slide on there.
                       Well, that pretty much takes us through
           screening.  Did you have any questions regarding
                       CHAIRMAN BONACA:  Well, actually again I
           thought that your tables laid out, 3.2.1., are quite
           effective, because you are summarizing in those tables
           the function, and the material environment, and
           therefore you are going to the scoping and screening,
           and it comes through.  That's very good.
                       MR. HALE:  And six column tables were
           lessons learned from the Oconee.  In fact, it came
           from our Duke Brothers that indicated that if you had
           it all in one table -- and in fact we are thinking of
           carrying that forward long term, in terms of
           configuration control and management.
                       CHAIRMAN BONACA:  Yes.
                       MR. HALE:  I think that is a good way to
           reflect the entire IPA.
                       CHAIRMAN BONACA:  Yes, that's good.
                       MR. HALE:  Now to the aging management
           reviews.  This is really the purpose as defined in the
           regulation for each structural component or component
           requiring an aging management review.  You demonstrate
           the effects of the aging will be adequately managed.
                       So the intended function would be
           maintained consistent with the current license basis
           for the extended period of operation.  Now, that is a
           long definition.
                       I thought that the best way to go through
           this was to talk about the inputs that we utilized for
           doing our aging management reviews.  I am going to
           touch on the technical resources, and talk about the
           operating experience reviews that we performed, and
           also mention peer reviews that we had done on our
           aging management reviews.
                       CHAIRMAN BONACA:  Before you start with
           that, I would like to ask you a question.
                       MR. HALE:  Yes.
                       CHAIRMAN BONACA:  Of course, through the
           application there is a description of the exposure
           that you have to salt air.  You do have a pretty
           peculiar auxiliary building, right?  I mean, you have
           no walls there.  It is all open.
                       MR. HALE:  The turbine building.  The
           auxiliary building is enclosed, with the exception of
           the CCW area, which has walls, but steel grating for
           a roof.
                       CHAIRMAN BONACA:  For those components
           which are not enclosed -- I mean, what is the
           experience of the past?  It is more curiosity than
           anything else.
                       MR. HALE:  It is actually pretty good. 
           What we found is a large bore stainless piping, thin
           wall, in the heat affected zones.  We have had some
           experience with St. Lucie, which in terms of external
           stress corrosion cracking, and this is piping in
                       But overall it has been very good.  As
           part of our aging management review, we walk down all
           our systems that were outdoor.  I mean, we walked them
           all indoor as well, but outdoor we specifically were
           looking for certain aging effects, like pitting.  You
           know, cracking.
                       We have had 30 years of experience at
           Turkey Point, in terms of SSC and that sort of thing,
           and so we know where the problems area would be.  But
           actually it has been pretty good.
                       There is a couple of isolated areas which
           have challenged us, and we have talked about them in
           the application.
                       CHAIRMAN BONACA:  Yes.
                       MR. HALE:  Our previous heat traced line
           in the CDCS system, where you had insulation, and you
           get some leakage or something and it holds it on to
           the pipe, we actually had some experience with it. 
           But overall the performance has been very good.
                       MR. ROSEN:  Let's come back to the
           stainless steel piping that was found to have external
           stress corrosion cracking.  Was that piping that was
           wetted continuously or underwater because it was in
                       Were the trenches filled with water, or
           was that cracking, do you think, experienced just
           because the piping was exposed to salt there?
                       MR. HALE:  No, there was some wetting
           involved, and Liz, maybe you can speak a little better
           to this.  We have not really experienced this at
           Turkey Point yet.  We experienced it at St. Lucie, but
           we made it an assumption for Turkey Point.
                       MS. THOMPSON:  Well, in a trench,
           sometimes in a subtropical climate like we have, we
           get rains, very hard rains, all at once.  And
           sometimes you will get some wetting.  If nothing else,
           you are getting a very moist environment, with some
           salt present there from the ocean and the canal water
           at the two different sites.
                       And both are salt water environments, and
           what you don't see -- and what is different about
           trenches -- is because it has a cover, you don't get
           the rinsing effect basically of the rainwater, which
           basically in a trench, you know, you would tend to
           expect that you may see a little bit higher chloride
                       And you don't get the rinsing and then the
           sun drying from afternoon thunderstorms and stuff like
           that that you get in most other areas.
                       And as Steve mentioned, Turkey Point --
           you know, we are dealing with about 30 years of
           experience, and at St. Lucie, about 25 years of
           experience.  And so far that has been all that has
           really come up.  The rest seems to be a pretty stable
           environment for outdoor areas.
                       MR. HALE:  And it was very specific to the
           heat affected zone on that thin wall pipe where they
           welded it.
                       MS. THOMPSON:  But the stresses of the
           heat affected zone, you know, plus a thinner wall,
           would tend to cause higher stress and complications. 
           So it took the combination of all of that before we
           have seen anything, and of course those have been
           addressed through our correction action program under
           our quality assurance program.
                       MR. ROSEN:  How severe was the cracking?
                       MS. THOMPSON:  We had just seen minor
           boric acid indications.  I mean, nothing from a
           leakage perspective or whatever.  Early detection, of
           course, is what we deal with everywhere.
                       But we have found it in more than just one
           location.  So once we found it in one location, then
           the next step is to look for applicability, and
           expanding out until you confirm that you have really
           got your arms around the full scope of the issue.
           And so we did see it in more than one location.
                       MR. ROSEN:  And this was at St. Lucie and
           not Turkey Point.
                       MS. THOMPSON:  It was at St. Lucie.  We
           took that experience and applied it to Turkey Point. 
           We do have a few lines that are somewhat comparable,
           although we have not seen the conditions at Turkey
                       MR. ROSEN:  And can you tell me what
           systems at St. Lucie it was experienced in?
                       MS. THOMPSON:  They were ECCS section line
           systems.  Basically, they are section line to the
           piping systems, and we had to work through one train
           at a time making repairs, and replacements, and so
           forth to address those.  So they were definitely
           systems of great interest to us.
                       MR. ROSEN:  Thank you.
                       DR. FORD:  On this full page, fairly
           recent Mr. Lochbaum, a concerned scientist, sent a
           note to Mr. Grimes pointing out that in the last year
           in several, in quite a few, in over 10, incidents
           where reactors have been shut down prematurely,
           unplanned, and probably because of a failure of aging
           management programs.
                       How good do you feel about this programs,
           in terms of their ability to see or to detect a
           problem before it occurs?
                       MR. HALE:  We are very confident in our
           programs.  In fact, I think the inspection that was
           recently performed upholds that.  We look at those and
           we factor in any of those failures in consideration of
           our own instances.
                       For example, the V.C. Summer, we looked at
           the applicability there to Turkey Point.  You know,
           they had penetrations, and that's identified as an
           open item in the application.
                       DR. FORD:  But these are really all
                       MR. HALE:  Well, that penetration issue,
           I think there was some recent information that came
           out regarding the failure mode that had not been
           originally, but we all had plans for reactor vessel
           head penetration inspections as part of 97.01.
                       You know, it's just that -- I think there
           was some -- the new information that came out
           available, but it is not as if we were ignoring it,
           you know.  I think that -- well, my perspective on it
           is that I have been at FPL for over 30 years.
                       And I have been at both of these plants,
           and I think you pretty much see most everything, or
           have seen most everything based on the long term
           operations at length.
                       DR. FORD:  Yes.  Unfortunately, you always
           see something the next day which you didn't predict
           the day before.  I guess my frustration to a certain
           extent about this whole procedure is that I keep
           seeing -- for instance, the frequency of inspections,
           and the depth of inspections.
                       It is dependent on how good your
           disposition algorithms are, and we keep seeing in all
           of these license renewal aging management programs
           reference to ASME 11 procedures.
                       And yet the data upon which those curves,
           those disposition curves, are not always good quality,
           and they are always being revised.  And unfortunately
           when you find that we need to revise them after we
           have had a fairly catastrophic event.
                       And maybe this will come out this
           afternoon as we are discussing from the NRR
           perspective, but do you have any feeling as to where
           we are at risk?  For instance, baffle bolts right now. 
           Could you predict when the baffle bolt cracking
           occurrence would in fact take place, and what would
           the impact be on, for instance, delta-LOCA, or LRF?
                       MR. HALE:  I feel very confident about the
           baffle bolt area because we have had an extensive
           probing program going on right now as part of the WOG
           to address that specifically.
                       And including safety evaluations
           regarding, you know, failures.  We were doing -- and
           Roger Newton is back there, and he can tell you,
           because they pulled theirs at Point Beach and
           inspected them.
                       And George Roble was also there for GANE,
           who has done the same.  So I feel in terms of the WOG
           that we have a good feel for the baffle bolt issue. 
           With regard to Section 11, where we credited Section
           11, at least the mechanical systems, was for Class One
                       Now, we are moving to a risk informed in-
           service inspection at Turkey Point.  We factored in
           things like risk, fatigue, into what we are going to
           be looking at.
                       For example, we are going to look at every
           weld in the surge line in the next 10 year interval,
           because that is the critical location to Turkey Point.
                       DR. FORD:  Well, that's great.  What is
           the area of your greatest risk right now?
                       MR. HALE:  Greatest risk?
                       DR. FORD:  Well, you have about 7 or 8
           programs that I see listed in your application, but no
           details in there about them.  How good do you feel
           about their worth, and which ones would you want to
           upgrade from a risk point of view?
                       MR. HALE:  I feel -- well, what we
           described in the application, behind every one of
           those on site is what we call our program basis
                       DR. FORD:  Okay.
                       MR. HALE:  And details specifically how
           the plant specific procedures that implement those, as
           well as specific enhancements to procedures, in terms
           of what we feel that we need to do.
                       If you look at what is happening in
           industry over the last few years, you know that
           inconel is an issue.  I mean, that seems to be one of
           the underlying things behind a lot of these issues
           that have been raised.
                       At St. Lucie, we have a number of inconel
           instrument penetrations, and we have had leakage there
           before.  So we have been following the inconel issue
           for some time, and what I have seen through the years
           is they started saying, well, it is a bad heat.
                       And then, oh, here is another one, and
           here is another one.  But certainly inconel poses a
           challenge for all of us, and to me I think that's
           where the risk is.
                       But I think we are learning a whole lot
           more over the last couple of years, because the V.C.
           Summer event was related to an inconel safe end, I
           believe.  You know, certainly the penetrations on the
           inconel head are all centered inconel.
                       DR. FORD:  I bring it up now because the
           information for making those decisions come out of
           those three sub-bulleted items there.
                       MS. THOMPSON:  I think an important thing
           to note is that the aging management reviews
           -- and Steve will get into this a little bit, and
           factor in operating experience, both at our plants and
           at other plants.
                       And that is part of an ongoing process
           that we always do.  Operation of our plants is based
           in a defense-in-depth, you know, multiple barriers
           type of a concept.
                       And we have to recognize that those
           multiple barriers really are what provide the ultimate
           level of safety from redundancy, between systems.  You
           know, systems backing up other systems.
                       And the fact that we have and have
           included in our aging management program are most of
           our early detection processes that we have in place
           now under the current term.
                       And in a couple of cases we have suggested
           enhancing those to further cover a broader scope
           basically for the renewal term.  Those are the
           processes that put us in a position where that
           operating experience is identified early, and then we
           as an individual operator of the plants, as well as an
           industry, share that.
                       And that's where I think we really have
           the strength and the safety performance of this
           industry.  We don't what to let problems get us to the
           point where they force us undue shutdowns, unplanned
                       And we know that we have to take the right
           actions to address those based on not just our own
           specific planned experience, but also what we find as
           we move forward basically in this industry and
           managing these plants.
                       And a lot of our early detection programs,
           from the systems and structures monitoring program,
           and to our boric acid programs, are the types of
           things -- just to name a couple of examples, that
           really put us in that early indication type of a
           process that allows us that additional layer of
           defense really to ensure our plants are safe.
                       CHAIRMAN BONACA:  And on the other hand,
           you might reference to the V.C. Summer issue.  They
           are more -- and I am not as much troubled by the fact
           that you have an inconel problem, and you have some
           cracks developing, than about the fact that the
           programs which were in place there did not detect
           those cracks.
                       In fact, they didn't see any when the
           inspections were performed.  And then we had to wait
           until the crystals were out, and that's really what is
           our concern the most.  I mean, these programs are
           great in many ways.
                       I look at it and there is a full life
           cycle management here being laid out, and developed in
           front of us.  You know, the concern is always about
           how able are we to detect in the inspections, because
           the inspections are many and thorough.
                       DR. FORD:  These are more general
           comments, and not specific, as those will come out
           this afternoon.  But it just concerns me that as an
           industry that we tend to go by industry experience,
           and by implication is the mean of the experience.
                       And what we are really interested in is
           the first occurrence.  For instance, before V.C.
           Summer, the day before, we didn't know it was going to
           occur.  And when it did occur, it was, "oh, shit," and
           what are we going to do about it.
                       And time and time again throughout our
           history we have done exactly that, that in large pipes
           and BWRs, they are never going to crack, but for
           whatever reasons yet they did.
                       And this is why I have got great suspicion
           of these aging management programs which can't see
                       CHAIRMAN BONACA:  We left behind an issue
           on scoping that I would like to get back to, because
           I think it is important, and that has to do with the
           October 1 issue of known break location line piping. 
           I guess support by known break location line supports,
           seismic.  Why are they not in scope?
                       MR. HALE:  The supports are in the scope.
                       CHAIRMAN BONACA:  I understand that.  Why
           are the segments not in the scope?
                       MR. HALE:  In looking at our licensing
           basis regarding high energy line break and flooding,
           we felt that we had already accommodated pipe failure
                       Now we are working with the staff right
           now and understand the concern they have raised, and
           we are in the midst of responding to their open item.
                       Our feeling is that our current licensing
           basis is acceptable based on approved flooding
           evaluation and our high energy line item, but we
           understand the staff's concern.  So we are taking an
           additional step, and looking at our plant regarding
           the assumptions that are being proposed.
                       And essentially the assumption is that
           aging would change the assumed break locations and
           this sort of think for systems containing fluid and
           steam.  So we are evaluating that.
                       The supports have always been in the
           scope, and another point that I need to raise is that
           we have got a number of non-safety related systems
           already in the scope, including the piping.
                       The Turkey Point fire protection brings in
           numerous systems in the Aux building that are non-
           safety related.  So the pipes wouldn't even scope
                       So we are walking or we are in the midst,
           and in fact we are going to work with the staff,
           understanding their concerns.  And we will probably
           identify some additional lines that we will include in
           the scope.
                       CHAIRMAN BONACA:  And I am sure that you
           will agree that if you had a segment between supports
           that is likely to corrode, or whatever, and then fail,
           and then fall over into other systems, that would not
           be acceptable.  You don't disagree with that do you?
                       We are trying to understand the logic. 
           This is the second application that we have seen in
           which there is this issue.  The first one I think had
           different connotations there, because they, I believe,
           had seismic qualified supports.
                       And then they were looking more at zones
           and you are not here.  But try to understand why this
           issue is there, and whether or not -- and we will
           understand that this afternoon that there will have to
           be specific items on the part of the staff for
           licensees in this particular area.
                       MR. HALE:  A lot of it has to do with your
           current licensing basis.  You know, when do you assume
           the seismic occurrence.  You know, we all went to the
           older plants when they went through A-46, and you just
           had to show that you had shut down the plant with a
           seismic -- a given seismic occurrence.
                       If you jus say that failure can impact
           safety related equipment, period, well, that is a
           difference basis behind -- you know, that is saying,
           okay, I have got the seismic occurrence, and I have
           got the LOCA.
                       And so if you take the definition,
           "affects safely related period," you have to go back
           and look at your licensing basis as to what your
           assumptions are.  Typically most of us don't assume an
           earthquake with design basis events.
                       MR. ROSEN:  Notwithstanding all of that,
           and going back and looking at the license basis, and
           all of that, where we end up on this issue I think is
           that we have an unsafety related piping out to a non-
           safety related support, where we have the support in
           the aging management program, and the aging management
           review.  But the piping itself, which is the load
           carrying member out to that support, is not.
                       MR. HALE:  Well, let me correct that.  We
           did include piping segments that provide structural
           support in the scope for that very reason, because it
           is an extension of the support.
                       What we are talking about here is a non-
           safety related line that sits above a safety related
           piece of equipment.
                       MR. ROSEN:  Where the non-safety related
           line does not provide any kind of structural support.
                       MR. HALE:  Right.  We did include the pipe
           segments.  Remember when I was talking about screening
           and stress analysis?  We actually took whatever
           portion of the piping was credited downstream of the
           boundary, as in the scope of licensing.  That pipe is
           in the scope of licensing.
                       MS. THOMPSON:  I would also like to add
           that in addition to what Steve described, which was
           the piping segment that is connected to the safety
           related portion being considered in the scope, the
           support is being considered in the scope.
                       We also considered protective features,
           such as sump pumps and actual protective features for
           leakage considerations in the scope as well.  So our
           difference between the staff's open item and what we
           have already considered in our application is actually
           very small.
                       We feel like we understand that, and we
           would like to -- you know, we have asked our project
           manager if we could actually go through our resolution
           on that next week.  So we feel like we can move
           forward on that.
                       And for Turkey Point, as I think you all
           mentioned earlier, a number of the areas are outdoor
           as well, and so the things that are underneath, those
           safety related pieces of equipment, are actually
           designed for wetted environments.
                       MR. HALE:  Outdoor service.
                       MS. THOMPSON:  Outdoor service.  So our
           scope tends to be quite small in this area.  but we
           feel like we can move forward on that.  So our delta
           is actually a relatively small delta.
                       And we understand the staff's position,
           and we will work forward on that.  I think our
           difference has been consideration of what we consider
           our current licensing basis.
                       But I think aside from that, we understand
           the staff, and we will work forward to resolution.
                       CHAIRMAN BONACA:  Okay.
                       MR. HALE:  Okay.  Any other questions?  If
           not, I would like to go through these three points. 
           With regards to the AMR technical resources we had
           available to us, although only five generic technical
           supports were submitted to the NRC for review, the
           Westinghouse Owners Group, we generated over 15 of
           these generic technical documents.
                       And it incorporated basically the history
           of all of the Westinghouse plants.  So we have that
           integrated in it, and it pretty much covered every
           component that you would have in the power plant.
                       And certainly in the early '90s, NUMARC,
           with EPRI, had the industry reports, which were
           submitted to the NRC for review.  The B&W tools, I'm
           sure you have heard this, all of the owners' groups
           have bought those tools that look at the evaluation of
           aging effects for non-Class One mechanical systems and
           civil structures.
                       You have to tailor it to your plant.  You
           know, we did an evaluation which took the tools, and
           applied to to Turkey Point.  We looked at the Aging
           Management Reviews performed by a particular
           applicant, and that we felt did a fairly detailed
           review of.
                       We looked at submitted applications in
           certain cases, and if you have some unique materials,
           you actually get into materials handbooks.  We also
           have a materials group and a materials lab, and so we
           also had at our disposal laboratory results of
           analyses that have been formed through the years in
           support of corrective actions.
                       And we are very active in the industry
           groups, and so those were the technical resources that
           we had at our disposal.
                       And with regards to operating experience
           review -- and I feel that this is one of the strengths
           of the aging management reviews that we performed.
                       Not only did we look at the industry stuff
           that was out there, both in the INPO and the NRC, and
           how we responded to that, but we also looked at all
           the non-conformance reports and condition reports in
           our database.
                       We looked at our event response team
           reports.  These were teams that are formed after a
           major event.  License event reports.  We looked at all
           the FDL metallurgical laboratory reports that we had.
                       And then we actually -- we were on site,
           and so we spent a lot of time with the system and
           component engineers in going over our aging management
           review results as to what they are actually seeing out
           in the field.
                       We used this as input for identification
           of our aging effects, but another positive though is
           that it also shows that we are managing aging.  If you
           are identifying items requiring corrective action, it
           says that you are out in the field and you are out
           there and actually managing aging of these systems.
                       So we draw on a fairly extensive database,
           in terms of input into our operating experience.
                       CHAIRMAN BONACA:  Did you look at the GALL
           report that was being developed at that time?
                       MR. HALE:  Yes.  In fact, we were very
           active.  You know, the industry established technical
           review groups -- mechanical, civil structural, and
           electrical -- and we have representatives on all three
           of those.
                       In fact, our mechanical lead, he is
           probably one of the most knowledgeable of the
           mechanical folks in the group.  In fact, he is
           providing most of the input to upgrades to the B&W
           tools right now.
                       And in addition to all of that, we felt
           that it was worthwhile to have independent eyes come
           in and look at the results.  And not only the results,
           but out of procedures, and the way we approached this.
                       We had license renewal staff members that
           actually gone through the process with the NRC review
           it.  We actually had some ex-NRC and other consultants
           come in and look at the way that we had done our aging
           management reviews.
                       We felt that because Framatome had
           submitted generic reports, and gone and gotten SERs,
           that we wanted to have the technical experts from
           Framatome review all of our Class One AMRs.
                       CHAIRMAN BONACA:  Which components were
           manufactured by B&W?
                       MR. HALE:  Our reactor vessel, but in
           terms of just what are the aging issues associated
           with rack cooling components, they had gone through
           quite an extensive review of the generic reports for
           the B&W plants.
                       So we felt that the type of aging issues
           and that sort of thing were worthwhile to have him
           come in and actually review in detail the results and
           conclusions we had reached.
                       And then in the electric/I&C areas, we
           actually had our corporate electrical chief, who is
           also -- I guess, Liz. that he is an IEEE chair,
           actually review our electrical/I&C aging management
           review results.
                       CHAIRMAN BONACA:  I had a question, and I
           don't know if it fits here, but what is the -- well,
           material-wise, what is the basic difference between
           Class I piping and non-Class I piping?
                       MR. HALE:  It is essentially the
           definition consistent with what we call Quality Group
           A, reactor pressure boundary up to the second normally
           closed valve.
                       It's just that you have orifices sometimes
           breaking the boundary between Class I and non-Class I. 
           For example, attached to the reactor coolant system,
           and that's why you will see a section in the RCS on
           non-Class I.
                       Well, what I was looking at was the aging
           -- the facts to be managed.  There were some
           differences there.  For example, you know, Class I
           piping not subject to wear.
                       And then non-Class I piping subjected to
           loss of material by a different means or several
           means.  And I was just asking in general the
           difference in materials.
                       DR. SHACK:  Well, a lot of it is stainless
           steel versus carbon steel.  So one is essentially
           immune to erosion, and the other is going to be
           susceptible to erosion.
                       CHAIRMAN BONACA:  But non-Class I piping
           has no cladding of any type?
                       MR. HALE:  The Westinghouse plants, the
           piping is stainless.
                       CHAIRMAN BONACA:  For non-Class I.
                       MR. HALE:  No.  Well, it depends. 
           Typically systems that are exposed to boric acid are
           stainless steel.
                       CHAIRMAN BONACA:  Well, boric acid wastage
           -- I mean, you have those for Class I, and need for
           chemical control, and starts corrosion and cracking
                       So there was just such a difference in the
           application between the issue of where, and where
           simply there is no monitoring for wear of Class I
           components, and were identified by several means on
           non-Class I.  But I understand, and that is really the
           difference in the material.
                       DR. FORD:  Could I ask again a very
           generic question.  If you look at this slide and the
           two previous ones, can you -- and everything is great,
           great words.
                       Can you give an example -- for instance,
           for the specific situation of baffle bolt cracking,
           there is a physical phenomena.  How do you use these
           technical tools, the technical resources, the AMR, the
           operating experience and the peer reviews, to solve
           that particular problem?
                       And I realize that I am asking you a half-
           an-hour talk, but if you could just kind of bulletize
           things.  What information did you get from these
           various resources to come up with a better inspection
           program and correction actions for baffle bolts.
                       MR. HALE:  For baffle bolts, the WOG
           report, we utilized that.
                       DR. FORD:  Yes, I have got this thing
           here, but there is no data shown in this.
                       MR. HALE:  Oh, I understand.  You will see
           some data that we have presented in our REI responses,
           where we have provided more data as they are analyzing
           and looking at these various baffle bolts.
                       But we identified radiation system and
           stress corrosion and cracking, stress relaxation.  All
           these aging effects for the baffle bolts, and this is
           based on the experience that we have seen, and also on
           expected experience in the future.
                       So we have established for those bolts
           -- that is part of our -- the rack vessel internals
           inspection program over and above Section 11.  I
           believe we are planning to do one early in the renewal
           period on Unit 3.
                       DR. FORD:  And inspection process?
                       MR. HALE:  Well, the inspection process
           will follow very closely what has been done at the
           previous Westinghouse plants, where they have actually
           done ultrasonic examinations of the bolting material. 
           I believe you also -- and, Roger, correct me if I am
           wrong, but you actually pulled all the bolts; is that
           right, or just the ones that had indications?
                       MR. NEWTON:  At Point Beach?
                       MR. HALE:  Yes.
                       MR. NEWTON:  At Point Beach, we had a
           removal program, where we were taking the bolts out
           and replacing them with new material, and a --
                       CHAIRMAN BONACA:  Could you come up to a
           microphone, please?
                       MR. NEWTON:  Yes.  I am Roger Newton, and
           I am or was the Chairman of the Westinghouse Owners'
           Group on the baffle bolt program.  I am also from
           Point Beach Nuclear Plant, an older plant, and we did
           participate as part of the Westinghouse and EPRI
           baffle bolt program.
                       And as part of that program, we were
           looking for actual experience of bolts in nuclear
           plants, and Point Beach is one of the older plants. So
           we volunteered to do a bolt inspection and replacement
           program to add information to the industry.
                       We have 347 stainless steel bolt material,
           and older plants have that, and newer plants have 316
           stainless steel bolt material.  So there are two
           different categories of plants in the Westinghouse
           family.  I think Turkey Point has 347 don't you?
                       MR. HALE:  I believe so.  I would have to
           check it out.
                       MR. NEWTON:  You are old enough to have
           347.  WE did this just to provide information to the
           industry on what aging was looking at in this
           particular area and to answer questions for the NRC,
           and provide a benchmark that at this age and time what
           are we seeing.
                       And as part of the program, we inspected
           all of the bolts, and for those bolts that had
           indications, we said, well, let's see if we can
           replace the pattern, plus the additional bolts that
           had indications.
                       So we ended up replacing -- well, I knew
           those numbers by memory at one time, but about 170
           some bolts throughout the internals.  Most of them did
           not have indications because they were in the pattern
           that we wanted to replace to.
                       But we did replace about 50 that had
           indications.  We found that of those 50 that 9 did
           have cracks.  We tested almost all of the bolts that
           were removed by structurally, and put them in a took
           and breaking them to indeed see what their
           characteristics were.
                       All of this information was put together
           in a very extensive report and provided to EPRI, which
           was also provided to all of the Westinghouse Owners'
           Group members.  So that's part of the operating
           experience for 347.
                       Similarly, an older plant that had 3/16ths
           stainless steel replaced their bolts as well.  They
           found that for that aged plant that there were no
           indications and no failures.
                       So we have a mark in time with respect to
           the bolt behavior in a Westinghouse plant.  So that is
           part of the operating experience that the industry is
           now relying upon.
                       The MRP program of EPRI is continuing to
           pursue the bolting issue, and looking at longer term
           effects of aging, and looking at whether voids play a
           role in it.
                       There was an integrated program that will
           support all of us out into the future and that pretty
           much all of us will take credit for as part of the
           Aging Management Program, and deciding what the next
           steps are.  And so that is somewhat of the operating
                       DR. FORD:  So your aging management
           program for Turkey Point is sort of a living document?
                       MR. HALE:  Yes.
                       DR. FORD:  And tomorrow it will change?
                       MR. HALE:  Yes.  If you look at the --
           right, and because I am a member of the Westinghouse
           Owners' Group, we have all this information available
           to us either in the WOG technical reports, or
           information as brought forward.
                       So in answer to your question, in terms of
           where, the participation in the Westinghouse Owners'
           Group is the primary source of information relative to
           baffle bolts.
                       But, yes, if you look at our application,
           as well as our response to REIs, you will see that --
           and in fact the staff has asked us to submit our
           inspection plan, detailed inspection plan, in advance
           of performing the inspection.
                       DR. FORD:  And the fact that the distance
           rate tends to go on logarithmically with fluence, your
           response time to these changes frequency will
           increase, or your response frequency will increase?
                       MR. HALE:  Yes.
                       MR. ROSEN:  The response time will go
                       DR. FORD:  Will go down, yes.
                       MS. THOMPSON:  I think that you have to
           look at all of these as living programs, and I think
           the most current example is the Alloy 600 program,
           where when we submitted the application, it was prior
           to any of the discoveries that happened at Oconee and
           so forth.
                       And now you look at it, and we are
           shutting down one of the units for a scheduled
           refueling outage next week, and we have an inspection
           that the reactor had planned.
                       And that will be factored in, and that is
           one of the open items.  We have responded to the
           bulletin.  It is going to be a living program.  We are
           going to incorporate that in, and I think that
           particular open item really just becomes a matter of,
           yes, this is a living process.
                       And we just happened to be in the middle
           of our licensing process here for renewal, but you
           would expect this type of change as items come up. 
           And we will do the right thing and update our programs
                       MR. HALE:  I think the one thing -- and
           this has been a good learning process for us all, in
           terms of -- well, because the aging effects evaluation
           that we have performed, it not only looks at what
           experience has happened, but what we would expect to
           happen, in terms of aging effects.
                       So I think that we have improved our
           knowledge level, in terms of trying to get at the
           issue that you are raising in terms of avoiding the
           failure before it occurs.  I know that I know a whole
           lot more about aging of the plant.
                       DR. FORD:  Thank you very much.
                       MR. HALE:  And one of the things that we
           did that I mentioned previously was the development of
           our program basis documents.  For each program that
           you see in the application, we have what we call a
           program basis document.
                       The program basis document provides a
           detailed evaluation of the 10 attributes, the summary
           of which you see in the application, and we felt early
           on that we needed to do this, because if you show the
           program to someone, and they say, well, show me the
           program, and it may be as many as 10 to 20 procedures
           that are being implemented, but you don't have this
           umbrella that says this is what defines what the
           program is.
                       And in some cases, you do, but in other
           cases, especially some of these non-regulated
           programs, it is not as clearly defined.  So we felt
           that it would be a good idea to have a basis document
           which bridges the program described in the application
           with actual implementation in the field.
                       This basis document identifies specific
           plant procedures which will implement the inspections,
           the walkdowns, or whatever may be involved, and it
           also is a place to capture all of our specific program
                       I think as a result of going through this
           process, we identified about 80 program commitments,
           and it is down at the procedural level as to when we
           will do the inspection, and what changes to programs,
           and what specific procedures need to be made.
                       And this was also one of the topics that
           the inspection team came down and looked at when they
           did the aging management review inspection.
                       MR. ROSEN:  When this kind of a program
           requires you to change a procedure, does the procedure
           reference back to that this change was as a result of
           the aging management review done on the license
                       MR. HALE:  Yes, we are going to put a
           statement on every procedure that implements that
           program that this is a commitment for license renewal,
           and we will identify -- because some of the procedures
           may be broader than the specific scope related to
           license renewal.
                       And we will highlight the specific steps,
           and the specific components that are covered in that
           particular procedure for license renewal.  So any
           change that occurs in the future is going to have to
           go through a review process to ensure that it
           addresses license renewal.
                       MR. ROSEN:  This is to preserve the
           license renewal commitments for the extended period of
                       MR. HALE:  Yes, because where the rubber
           hits the road is in the procedures at the site.  With
           regards to TLAAs, you have got six criteria that are
           specified in 10 CFR 54.3.
                       We did a fairly extensive review of all of
           our current licensing basis documents, and our
           licensing correspondence is tech searchable.  We
           looked at tech specs, and the USFAR, as well as the
                       We identified potential candidates for
           TLAAs, and then we reviewed them against the six
           criteria.  The methodology is prescribed in NEI 95-10,
           and we were consistent with that methodology.
                       As part of that process, we also looked to
           see if there were any exemptions involving TLAAs, and
           we did not find any.  The TLAAs for Turkey Point  as
           described in the application, a reactor vessel
           irradiation embrittlement, Class I and non-Class I
           fatigue, EQ, containment tendon relaxation, and
           containment liner fatigue.
                       And then we had a case of wear/erosion,
           where there was a TLAA associated with -- a couple of
           cases where there was wear/erosion associated with our
           current licensing basis, and then crane fatigue in
           some of the major cranes.
                       With regard to our conclusions, the aging
           management programs at Turkey Point we feel are
           adequately managing aging effects so that the intended
           functions will be maintained consistent with our CLB
           for the period of extended operation.
                       And, secondly, all our TLAAs from Turkey
           Point were identified and evaluated, and shown to be
           acceptable for the extended period of operation.  That
           concludes our presentation.  Are there any more
                       CHAIRMAN BONACA:  I have a number of
           questions.  However, our component are systems
           specific, and so we will go through when we go through
           the SER.  I am sure that you are going to be here for
           the rest of the day.
                       MR. HALE:  Yes.  Yes, I will be here.
                       CHAIRMAN BONACA:  And so we can ask you to
           provide information at that time, and that will be the
           best way to do it.
                       MR. HALE:  Okay.
                       CHAIRMAN BONACA:  Thank you.  And with
           that, I think we should take a break now, and we will
           resume the meeting at 20 after 10:00.
                       (Whereupon, the meeting was recessed at
           10:03 a.m., and was resumed at 10:21 a.m.)
                       CHAIRMAN BONACA:  All right.  Let's resume
           the meeting, and we have now a presentation by NRR of
           the Safety Evaluation Report by Mr. Raj Auluck.
                       DR. AULUCK:  Good morning.  My name is Raj
           Auluck, and I am the project manager for the Turkey
           Point license renewal effort, and the purpose of
           today's meeting is to brief the subcommittee on the
           staff's SER related to the Turkey Point license
           renewal application, and to respond to the questions
           that the committee members may have.
                       I will provide an overview of the safety
           evaluation report, followed by other staff members
           summarizing their research of the review.  As the
           slide shows, we have a number of staff members
           scheduled to speak.
                       We do not have that many open items, but
           for discussion purposes, we have tried to make the
           slides complete so that when the appropriate time
           comes, you can ask your questions, and we can respond
           to your questions.
                       And most of these staff members have
           participated in the NCR, and at this time, I would
           also recognize Mr. Steve Koenick, and he is my backup
           project manager, and helped prepare the SER also, and
           he is getting ready to take on any other future
                       As you can see, this is an application
           submitted on September 8th, 2000, and this is a little
           over a year.  It is a three loop Westinghouse,
           Pressurized Water Reactor, and a two unit site, and
           each is designed for 2300 Megawatts.
                       Now, the site is shared by two gas and oil
           generating units.  The plant is located about 25 miles
           from Miami in Florida City, the same distance from the
           Keys, Key Largo.
                       The license expires on July 19th of 2012
           for Unit 3, and April 24th for Unit 4 -- well, for
           Unit 4, April 10, 2013.  And they are requesting a 20
           year extension to these dates.
                       DR. ROSEN:  So those are typos on the
           slide that is Unit 3 and 4?
                       MR. AULUCK:  Yes, correct.  It should be
           Unit 3 and 4.  And for the different applications, we
           performed an acceptance review and sent a letter to
           the applicant in October, and attached to the letter
           was this targeted schedule.
                       As you can see, we have met most of the
           milestones.  The next important milestone other than
           ACRS meetings is for the applicant to respond to the
           open items in the SER.
                       Now, this schedule is based on our
           standard 30 months schedule.  Since there is no
           hearing -- the hearing proceeding has been closed --
           and so this will be changed to 25 months, and we are
           in discussion with the applicant, and we will see
           where we are.
                       They have requested with respect to this
           schedule an earlier date, and so we are in the process
           of discussing that with them and with our staff how to
           support any new date.
                       The SER format follows pretty much the
           application for.  The difference is that we have in
           Chapter 3 all the AMRs and AMPs that are in the
           application contain that information in Appendix B and
           Appendix C.
                       And Chapter 1 is the introduction and
           general discussion; and Chapter 2 is the structures
           and components; and Chapter 3 is the AMRs as I
           mentioned; and Chapter 4 is the TLAAs.
                       As was mentioned by Steve a little
           earlier, this is the first PWR and FPL participated in
           many industrial groups, and they were an active
           participant in the Westinghouse Owners Group.
                       CHAIRMAN BONACA:  It is the First
           Westinghouse PWR.
                       MR. AULUCK:  Westinghouse PWR.  And the
           four Westinghouse Generic Reports were submitted to
           the staff for a staff review, and as mentioned
           earlier, the reports were not finalized.  So the
           applicant did not incorporate those Westinghouse
           reports by reference.
                       They addressed all the issues there, and
           for the other reports we had several REIs, and all the
           applicant items, the action items, were in the report. 
           But the safety evaluation of these Westinghouse
           reports were stand alone documents, which were not
           completed at the time of the application.
                       As far as the staff review, the staff
           identified open items,a nd the list is quite short. 
           The first one is the scoping of seismic II over I
           piping systems, which was already discussed earlier,
           and we will go over it in more detail in the following
           presentations this morning.
                       There was an open item at Plant Hatch, and
           we especially asked the applicant to wait until the
           resolution on Hatch is reached, and the staff's
           position is clarified, which has been done now.
                       So now we are in the process of discussing
           further the applicant's position on Turkey Point.  The
           staff's position will be given later on, but it is
           very clear that all II over I piping should be within
           the scope of license renewal, and we will go from
                       CHAIRMAN BONACA:  What kind of additional
           burden does this inclusion of all II over I piping --
           for example, for Hatch.  I understand this morning
           from the presentation that it is not much of a burden
           for Turkey Point.  It doesn't have much piping.
                       MR. AULUCK:  Well, Hatch probably did some
           several walkdowns and they did have to include some
           systems which were not previously included.
                       CHAIRMAN BONACA:  No, what I am trying to
           understand here is the logic of the applicant, because
           this issue is a current issue, and clearly there must
           be a significant difference in scope to justify this,
           and so we will try to understand the logic.
                       MR. AULUCK:  I think we will have that
           later, and it depends on how each plant briefs and
           identifies those systems.  In the case of Turkey
           Point, they went with area approach, and what is
           contained there.
                       If I remember there were 7 or 8 areas only
           where they have this potential interaction.  So, the
           staff is prepared to discuss that this morning.
                       A second open item is the reactor vessel
           head alloy 600 penetration inspection program. 
           Leaking from the vessel head penetration nozzles has
           been identified recently at some plants, and so the
           staff is working with them to resolve this issue.
                       And so our expectation is that whatever
           resolution is reached with industry that Turkey Point
           will follow that, and we will have a presentation on
           this issue also.
                       CHAIRMAN BONACA:  So this is not an open
           issue because there is a difference of opinions
           between the staff and the licensee, and there is an
           emerging event issue that you just are expecting ot
           have some commitment from Turkey Point?
                       MR. AULUCK:  I think whatever resolution
           is reached between the staff and industry, and Turkey
           Point is part of that -- and since we do not know the
           resolution of that is, we consider it an open issue.
                       MS. THOMPSON:  I would consider this an
           emerging issue, and we have responded to the bulletin,
           but of course that just happened very recently. 
           Whereas, our application and the REI process happened
           before the Oconee discovery.
                       CHAIRMAN BONACA:  Yes.  I am trying to
           understand what the closure means.  It will be quite
           a while before there is a full resolution of the
           technical issues.  What is necessary to close this
           issue from the perspective of the license renewal?
           It seems to me just a commitment to --
                       MS. THOMPSON:  Right.  Right.
                       MR. AULUCK:  And so we don't perceive any
           problems here, but at this time we are not in a
           position --
                       CHAIRMAN BONACA:  No, I understand.
                       DR. SHACK:  Just out of curiosity.  You
           have an outage coming up.  How inspectable is your
           plant from a visual point of view?  Do you have
           insulation on the head?
                       MS. THOMPSON:  Yes.  The insulation issue
           tends to be more of an issue for the combustion
           engineering plants.  So Turkey Point being a
           Westinghouse plant, there is insulation present, but
           we feel like we can perform the inspection.
                       We are feverishly planning this activity. 
           Obviously it is something that has just come up
           recently and the timing of it, and to try and take
           action this quickly truly is a challenge for us to do
           at the station.
                       We have taken one of our main managers off
           to the side basically, and he is focusing all of his
           attention on trying to get this activity planned to be
           ready to go really next week.
                       So for those plants, just for your
           understanding of the type of impact this is, it is not
           easy to plan something that is done in a such a high
           dose area.  Plus, it is relatively costly.
                       So it is something that we really are very
           focused on right now to try to accomplish it at ALARA,
           and also in a cost effective manner to be able to get
           it done in this period of time.
                       CHAIRMAN BONACA:  This inspection that you
           are planning, is it imminent?
                       MR. AULUCK:  In October, I think.
                       CHAIRMAN BONACA:  In October?  All right. 
           I didn't understand that from the SER.  I thought that
           you advanced your inspection based on the NEI schedule
           as shown here, but I didn't realize that you had one
           so soon.
                       MS. THOMPSON:  Yes, that is the advanced
           schedule.  Our refueling outage was scheduled to start
           this coming Monday.  So we are basically within a week
           now of when we would start, and when the head is
           removed from the reactor is really our start time for
           performing the inspections.  So that is the first week
           of the outage.
                       CHAIRMAN BONACA:  Okay.
                       MR. AULUCK:  The third item is reactor
           vessel underclad cracking.  In their application the
           applicant indicates that the generic evaluation of
           underclad cracks have been extended to 60 years using
           fracture mechanics evaluation space on a
           representative set of design transients with
           occurrences extrapolated over 60 years.
                       And they also mention that the number of
           design cycles and transients are presumed to encompass
           the WCAPS 15338 analysis, and this WCAP was submitted
           for staff review in March of this year.
                       So it is undergoing a review, and the
           review has been completed, but the SER has not been
           issued.  The current schedule that the staff
           evaluation will be issued by the middle of next month.
                       CHAIRMAN BONACA:  Now, the reactor vessel
           was designed and constructed by B&W.
                       MR. AULUCK:  Yes, to Westinghouse
                       CHAIRMAN BONACA:  All right.  So this
           evaluation is being done by Westinghouse, but -- well,
           I am trying to understand why wouldn't it be
           -- that you would have an B&W evaluation on that.
                       MR. HALE:  Well, B&W fabricated the
           vessel, but it was built -- the vessel was built with
           Westinghouse specifications.
                       CHAIRMAN BONACA:  Okay.
                       DR. SHACK:  There was a question that I
           meant to ask before.  Your fatigue management program,
           I take it that wasn't a new program for license
           renewal.  What was the driving force for instituting
           that?  What problems were you addressing when you
           instituted that?
                       MS. THOMPSON:  I think you are referring
           to the fatigue or what we call the fatigue monitoring
           program.  Basically it is a confirmatory program, and
           whether you look at the current term or the renewal
           term, we are confirming that we are not exceeding the
           number of cycles that were assumed for operation.
                       DR. SHACK:  But you had some locations
           though that were approaching usage factors of one?
                       MS. THOMPSON:  No, not necessarily.  We
           had some that were higher as I think all plants do. 
           Some of the surge lines and so forth that have been
           evaluated in some plants you will find some of the
           nozzles and spray lines, and so forth, just depending
           on the particular plant.
                       But I think that has been a confirmatory
           program to make sure that we are staying within our
           design analysis regardless, and to keep track of that.
                       MR. AULUCK:  Okay.  The next item is an
           open item and is acceptance criteria for field erected
           tanks internal inspection.  We will have a discussion
           on this item later on in the presentation, but this is
           a new program used to manage in part aging and effects
           of loss of material due to corrosion of the tanks
           within the scope of the program.
                       And this chemistry control program will --
           two of these programs will manage corrosion inside the
           tanks.  At this time, at the time of the staff's
           evaluation, the applicant had not developed a program
           with acceptance criteria and limiting procedures.
                       So that is one of the reasons that is an
           open item.  So as soon as we receive the information,
           we will review it and take the next step.
                       CHAIRMAN BONACA:  And this includes all
           the other RWST and --
                       MR. AULUCK:  Yes.
                       CHAIRMAN BONACA:  And on the third item
           that you had, that is the Westinghouse topical report
           being reviewed for the reactor vessel underclad
           cracking.  When do you expect to have that review
                       MR. AULUCK:  The middle of October.  It is
           pretty close.  The staff is completing the process of
           management review.
                       CHAIRMAN BONACA:  So it seems to me that
           the potential for closure of this open item is in the
           very short term.  What is the understanding that you
           have of that?
                       MR. AULUCK:  As I understand, right how
           the current scheduled date for a response to the open
           items is December 17th.  The applicant is targeting
           for the end of October or the first week of November. 
           Around that time.  So at least six weeks.
                       CHAIRMAN BONACA:  Okay.  Thank you.
                       MR. AULUCK:  And this is a slide on
           inspection activities.  So far we have performed two
           inspections.  The first was for a week in may for
           scoping, and a two week inspection on the AMRs, split
           into one week segments.
                       This is in addition to the staff audit
           done on the scoping in November of last year.  I think
           that besides --
                       CHAIRMAN BONACA:  So in total you had four
                       MR. AULUCK:  Yes, we had four site visits
           in four weeks, yes.  Once we were there, we discovered
           that all the projects developed for license renewal
           were under the plant's QA program, as I understand
           there were no QA procedures for license renewal.
                       So they overlooked procedures or
           instructions on quality instructions, numbering 5.2
           5.3, 5.4, and 5.5.  And each of these documents
           provide guidance to their engineers and staff members
           how to scope the document, and how to scope the
           systems, and how to screen the system, and how to
           review the AMR.
                       This is more like a step-by-step, and so
           we looked at the application here things were not as
           clear and there was a lot of questions from the staff,
           and which were answered by redirecting elsewhere in
           their applications.
                       But once we went to the site and looked at
           some of those quality instruction procedures, and
           taking it step-by-step, it was really helpful.  And
           then in addition to that there was backup
           documentation as Steve mentioned for each program
           basis documents.  And descriptions for procedures and
                       And they were easily accessible.  So these
           inspections did not find any major findings, but there
           were several minor discrepancies and the drawings were
           not consistent with each other, or with different
           documents there were some discrepancies.
                       And then once we told them, they were
           reported to the appropriate programs and followed up
           on, or they were addressed elsewhere.  And the team
           did review several documents for the new programs, and
           for the existing programs.
                       With that, if you have no questions that
           I can answer, we will then move to the next
                       CHAIRMAN BONACA:  We as a committee have
           expressed interest in the form and clarify of the
           documentation, because it is a complex evaluation, and
           it is important to have documents that will be
                       Some of the members of the subcommittee
           had an impression that this was a good application
           insofar as clarity of the form.  What is the
           perspective that you have?
                       MR. AULUCK:  I think it is -- I mean, this
           is my first -- and I have been involved in project
           management of plants, and licensing, and operating for
           a long time.  But this is my first experience with
           license renewal.
                       And I had worked at Turkey Point maybe 10
           years back as the operating director.  So I knew a
           little bit more about the plant.  But they have a good
           staff and that might have helped.
                       The application contents were not as good
           as you would expect.  An example, when we first
           received the application, and it was assigned to
           different staff members, and started talking and had
           requests for additional information.
                       So we received more than 300 REI requests
           -- and approximately 325 -- and when we started
           reviewing them and found that several of them were
           simple, then we had several conference calls, and we
           found that the information is already available in the
           application elsewhere and in different documents.
                       And as a result of those few meetings and
           telephone interactions, we reduced the number without
           any new information from 325 down to 215.  So once we
           go to the site and we see those additional
           documentation, and which verifies the application.
                       And I am sure the next applicant will look
           at Turkey Point's REIs and their process procedures,
           and follow it and improve on it.
                       DR. ROSEN:  Would you say that the hundred
           or so REIs that were really answered in the document,
           but the staff didn't find them, that was the result of
           the staff's inexperience, or the documents being so
                       MR. AULUCK:  I think it was not the
           staff's experience, but it was a navigational problem
           within the application.  The information was not
           readily available in the sections that the staff was
           looking at.
                       And it was rational for the applicant to
           include that information elsewhere, and sometimes
           there is a time factor and only a short time to review
           the whole thing, and come up with requests for
           additional REIs.
                       DR. ROSEN:  We are always searching for
           more ways to be more efficient.
                       MR. AULUCK:  Exactly.  And do we have
           lessons learned from the different applications?  We
           are preparing lessons learned for internal use so that
           it gives us more time up front to review the
           application, and then we will have fewer REIs, and
           will improve the process.
                       DR. ROSEN:  Yes, to improve the process,
           and no search for blame.
                       CHAIRMAN BONACA:  Now there is a standard
           form that pretty much is being proposed between NEI
           and the staff, and so on, and so forth.  So that is
           why we are asking this question.  I think we want to
           monitor as a committee how this is taking place, and
           in-part I think also that when you do review the
           application that you have different reviewers, to
           which you assign individual chapters, right?
                       MR. AULUCK:  Right.
                       CHAIRMAN BONACA:  And that's why probably
           the issues with various problems.  There isn't one
           person that reads it all and says this is there or
                       MR. AULUCK:  Well, yes, and that's part of
           the process.
                       DR. FORD:  I have another question.  These
           things that we have been talking about have been
           navigational and procedural as technical people.  When
           you look at the application, there is a whole lot of
           technical questions that will come up.
                       Some of them might be minutia and some of
           them will be major impacts.  How does your staff go
           through deciding what they should be really looking at
           technically, as opposed to the minutia?  And how do
           they evaluate that, and how do they get the
           information necessary to have an informed review, a
           technical review of the application?
                       MR. AULUCK:  Well, I think as a technical
           person, they want to feel fully comfortable with what
           they are preparing in the safety evaluation, and
           whether it is minor or major, they put it in writing.
                       And if they don't put it in writing, they
           will call the project manager or their immediate
           supervisor, and say, hey, you know --
                       DR. FORD:  But that does not answer the
           question of how do they prioritize what is important
           and what is not.  For instance, boric acid wastage may
           or may not be of higher importance than, for instance,
           baffle board cracking, or the other way around.
                       How do you decide?  Is it based on the
           formality of a risk-informed analytical approach or
                       MR. AULUCK:  I think there is no priority
           basis.  I think it is because the information is not
           sufficient in the application, and the application is
           not sufficient.  There is no priority of REIs that
           should go first than the other.
                       MR. KOENICK:  For all structures and
           components  that are within scope, they have to have
           full confidence that they can make the findings.  So
           they have to address that to their satisfaction, and
           that's where you get the capabilities of your
           reviewers and their supervisors to ensure that they
           have done a thorough review and can make the findings
           that they need to for every structure and component
           that is within the scope.
                       DR. FORD:  I just keep coming back to this
           concern I have.  We might find a crack in the pressure
           vessel and which was not perceived yesterday, and it
           was not predicted yesterday, but that would be a major
                       In your process of when you are looking
           through these applications does it go through your
           mind how are they managing the program proactively to
           decide whether they are going to have a major event
                       MR. AULUCK:  That will be under the part
           of the current license.
                       MR. KOENICK:  You have to go back to what
           the fundamental principle of the Commission when they
           developed the rule; that you rely on the regulatory
           process, and the regulatory process is continuing.
                       DR. FORD:  I guess I am questioning the
           approach.  I am questioning the technical completeness
           of the regulatory process that was developed years ago
           and before we had some experience.
                       MR. ELLIOT:  Barry Elliot, Materials and
           Chemical Engineering Branch.  He is describing the
           regulatory process.  The best example is the one that
           we just finished talking about, which was the reactor
           vessel head penetration cracking.
                       When we originally did the review it was
           fine.  It met all the requirements that we had
           established at that time.  That's why it became an
           open issue, because it was a new thing.
                       So the answer to your question is if we
           find a new issue, and it is at the time that we are
           reviewing the application, it becomes an open issue. 
           If we have already finished the review, then it is
           handled as part of the regular licensing process.
                       That is our procedure, and you are seeing
           it right here on Turkey Point.  We are putting it into
                       CHAIRMAN BONACA:  For example, you may
           question why we did not inspect the heads before
           because we didn't see any cracks.  That is really a
           question regarding the current licensing approach to
           it, and not really the elements of license renewal,
           which is the assurance that the program that you
           believe is correct or adequate will be carried over
           the period of the license renewal.
                       And the basis for which you believe it is
           going to be effective from 40 to 60 years.  So the --
                       DR. FORD:  I can understand the replies,
           but I keep coming back to we approved Oconee, and then
           we had the embarrassing situation two months later to
           have the vessel head penetration cracking, which to
           the technical community was no surprise.
                       CHAIRMAN BONACA:  I don't think there is
           any expectation that we would not have new events
           taking place that would were never seen before.  I
           mean, there is no doubt in my mind about that.
                       DR. FORD:  I am just questioning the
                       MR. ELLIOT:  We had a vessel head
           penetration program before Oconee, and we could argue
           all day long how effective it was.  But we had it, and
           all we are doing now is trying to figure out do we
           have to revise it.  How much do we have to revise it.
                       We've had a program, and the issue now is
           what do we need to do to revise it, and whatever
           answer we come up with will affect Turkey Point, and
           will be part of the resolution of the open issue.
                       DR. FORD:  I guess I am on a crusade.
                       CHAIRMAN BONACA:  But I think it is a
           significant question that you are asking, and it is a
           legitimate question, because it goes to the heart of
           how long are you going to run these plants, and we
           don't have an answer to that, except that we feel
           comfortable evidently with the current process to go
           from 40 to 60 years.
                       But there is no doubt that for components
           that there will be surprises coming through, because
           they age, and that's why the focus is on long-lived
           passive components.
                       So I think it is a good question that you
           have.  Unfortunately, I don't think we will be able to
           predict all that is going to happen.
                       MR. AULUCK:  Okay.  Our next presentation
           will be by Greg Galletti, on the scoping and screening
                       MR. GALLETTI:  Good morning.  My name is
           Greg Galletti, and I am with the Division of
           Inspection Performance Management Branch of NRR.  I am
           responsible for the scoping and screening methodology
                       What I would like to do is briefly go over
           the scoping and screening method with you that we have
           performed, and then discuss the one open item on
           seismic two over one that we still have currently.
                       Initially let me start off by saying that
           when we do the scoping and screening methodology
           review that we really have three goals in mind.
                       The first goal is primarily to ensure that
           the program that is described by the applicant is
           comprehensive and detailed enough to ensure that the
           requirements of 55.4 are completely covered.
                       The second goal that we have is to go and
           review design documentation and supporting information
           that the licensee has developed to ensure that they
           have done a comprehensive review to ensure that the
           current licensing basis has been considered for the
           purposes of the review.
                       And the third main goal that we come into
           this review with is to go and review the implementing
           guidance that is provided by the licensee for their
           own personnel to try to get an understanding of how
           they have implemented the requirements, ensure that
           the implementation is consistent across their
           engineering staff, to ensure that they have done a
           comprehensive and detailed review of the guidance and
           the requirements for the performance of the review.
                       And in doing this three goal tiered
           approach, the staff usually uses a two-tiered
           approach.  This is the approach that we have taken in
           the past.
                       We initially start off with a desktop
           review, which is done in-house, where we review the
           application in detail, and we also review some of the
           background documentation that is provided, such as the
           updated safety FSAR.
                       We would look at any other design
           documentation that we would have on the docket that
           may be pertinent.  The question that had come up
           earlier this morning about looking at the EOPs, while
           we don't specifically look at the EOPs, we did in fact
           look at the Westinghouse ERG, emergency response
           guidelines, the parent documentation for the
           development of the procedures.
                       And just to get a better fundamental
           understanding of the design of the plant, the
           application of mitigation strategies that the licensee
           has used, and just to get a better general
           understanding of how the plant was designed and is to
           be operated.  The second --
                       DR. ROSEN:  With respect to that, with the
           EOPs and the ERGs, earlier this morning we heard that
           it was not a criterion under the license renewal rule
           to review equipment used in EOP for aging management.
                       MR. GALLETTI:  That's correct.  If you
           look at the guidance in NEI 95-10, for example, source
           documentation that could be used to support the
           scoping and screening methodology, there is a litany
           of information that is available to a licensee to use
           for that purpose.
                       It is really left up to the applicant as
           to which of those documents best serves them for that
           purpose.  They may or may not choose to use the ERGs
           or the EOPs because there may be some other design
           documentation like the maintenance rule scoping, and
           there are equipment lists, and which provides the same
           level of information, and gives them a reasonable
           source for coming up with the conclusions as to what
           should be scoped and screened in accordance with 54.4.
                       So while it is not a firm requirement that
           they look at those documents, for the purpose of the
           staff's review and getting a fundamental understanding
           of the plant, the staff had that information available
           to it, and felt that it was appropriate to use that
                       DR. ROSEN:  Well, let's cut to the chase
           on this one.  What I am concerned about is did the
           staff or does the staff have an adequate basis to
           conclude that the equipment that operators would use
           throughout the extended period of operation for
           responding to not normal events, or accidents, would
           in fact function and not be degraded by some aging
           effect that we have not identified yet?
                       MR. GALLETTI:  Yes.  I think that is clear
           that the basis for the entire approach as to how we
           perform these reviews, and how the application was put
           together in the first place.
                       It is really fundamentally if you look at
           the requirements of 54.4, those criterion in the 54.4
           must be addressed by the applicant.  They must ensure
           that the safety equipment is in scope.
                       They must ensure that non-safety that
           could affect the function of that safety is in scope. 
           By doing so, we ensure that all that equipment that is
           necessary for vent mitigation is in fact covered, and
           perhaps subject to an aging management review.
                       And the second tier of the approach that
           the staff has used is to actually do an on-site audit
           of the documentation and the process implemented by
           the applicant.
                       The on-site audit is typically about a
           week long, and generally we have 3 to 5 people on the
           staff on the team for the audit.  We go through a
           detailed review of the design basis documentation that
           the applicants have used for the purposes of their
           review, and to ensure that the current licensing basis
           has been captured.
                       We go through in very strong detail the
           implementing guidance that they have provided to the
           staff, and we go through and we use certain samples. 
           We will sample a couple of systems in detail to ensure
           that the implementing guidance as written was actually
           performed, and those systems were scrutinized
           consistent with that guidance.
                       And based on the two-tiered approach, the
           desktop, as well as the on-site audit, the staff, for
           the purposes of the Turkey Point review have concluded
           that in general the approach that was taken by the
           applicant was consistent with the scoping and
           screening methodology that they have described.
                       It is consistent with the requirements of
           54.4, and we believe it is robust and comprehensive
           that we had a positive safety finding.
           We did have one issue that was brought up that I would
           like to discuss in a little bit more detail on the
           seismic two over one.
                       DR. ROSEN:  Let me interrupt you again. 
           Pardon me for making one point, and ask the question
           that you said that in your on-site audit that you
           looked at the instructions and guidance with the
           staff, and found them to be reasonable and
                       MR. GALLETTI:  Right.
                       DR. ROSEN:  But the other piece of getting
           a process done correctly is the qualifications of the
           people using that guidance, and the training of the
           people using that guidance.  Did you look at either of
           those things?
                       MR. GALLETTI:  The way we captured the
           training of the people that were involved in the
           review was generally on the on-site inspection, we
           will go through as I said certain systems, and we will
           go through those systems with the cognizant staff that
           was responsible for the review.
                       So in doing so, we will question them to
           understand how they applied the implementing guidance
           to ensure that it was consistently applied.  We
           discussed specifically the training aspects, and how
           did you train your people on these implementing
                       And in fact the responses have been
           generally that the guidance is a quality document.  It
           is reviewed by each of the staff.  There were certain
           internal meetings if you will during the development
           of this implementing guidance to ensure that the
           guidelines were specific and did in fact reflect the
           approach that the applicant wanted to take.
                       So basically through a dialogue with the
           staff, the applicant's staff that is, we had a
           reasonable assurance that they were well trained.
                       DR. ROSEN:  Did you look into whether this
           guidance was included in the engineering support
           personnel training programs?
                       MR. GALLETTI:  Not as such, no.
                       CHAIRMAN BONACA:  I think that this is a
           good question and it also goes to the NRC stuff.  I
           mean, how do you -- are the same individuals assigned
           to the same areas of different license renewal
           applications so that there is experience being built
           there, and the learning curve is high?
                       MR. THOMAS:  Maybe I should answer that. 
           My name is Brian Thomas, and I am in the Division of
           Systems Safety Analysis, Plant Systems Branch.  And
           that division is responsible for the scoping and the
           screening of the SSEs that are within the scope of
           license renewal.
                       To the extent that we can, we are forming
           a license renewal review team if you will.  To the
           extent that they are within the resource limitations
           and so forth, people are pretty much are assigned to
           the same areas.
                       So we have folks that have expertise in
           structures, structural engineering, for example, that
           would review the scoping of the SSEs that pertain,
           let's say, to the structures, the yard structures, the
           containment structures.  And similarly we take a
           similar approach with the systems.
                       CHAIRMAN BONACA:  Okay.  Thank you.
                       MS. THOMPSON:  To address the FTL Turkey
           Point specific training, the engineers that
           participated in generating the actual license renewal
           documents that yielded the application, all received
           specific training on the procedures -- they were
           called quality instructions as what we refer to them
           as -- as part of their job orientation.
                       And there was a specific group of people
           that developed those documents, and then more of an
           overview and understanding of the concepts and bases,
           and how those would be applied in a long term basis
           from a commitment management perspective, as well as
           a configuration control perspective, the engineering
           technical personnel training program also included
           sections that were specifically dealing with license
                       And we have done that a couple of times
           already, and plan to continue to do that, particularly
           upon issuance of a renewed license favorable decision
                       DR. ROSEN:  Well, thank you.  That's
           helpful.  Now, I understand what you said is that you
           have included the license renewal process, as well as
           those things that come out of the process that will
           have to be carried forward for the life of the -- for
           the extended life of the plant in the engineering
           support training program, so that it gets built into
           the infrastructure of the engineering organization as
           an ongoing matter.
                       MR. GALLETTI:  Absolutely.  That's
                       MR. GALLETTI:  If there is no other
           questions on the scope and screening review itself, I
           did want to discuss specifically the seismic two over
           one issue.
                       CHAIRMAN BONACA:  And then after that I
           have questions regarding 2 or 3 systems, and why they
           were not included, and I will ask those questions
           after you.
                       MR. GALLETTI:  Sure.  I think that Brian
           will cover that as part of the scoping results
           section.  As was brought up earlier today, the one
           open issue that we do currently have is characterized
           as seismic two over one.
                       And really for the purposes of the review
           the staff is looking at this in terms of a little bit
           broader.  It is really the application of the 54.482
           requirement for inclusion of non-safety related SSCs
           whose failure could in fact impact a safety related
           SSC from performing its function.
                       As you know the genesis of this issue
           really came out of the Hatch review, where some
           questions were asked on some auxiliary systems, and
           whether or not certain segments of piping were in
           scope or not scoped.
                       As a result of that staff review and
           working with the licensee, several key issues came
           out.  Generally for the application of 54.482, the
           staff would consider any non-safety SSC whose failure
           could impact a safety SSC as potentially within the
                       What a licensee or applicant would have to
           do is really first of all identify what are their
           safety related SSCs, and then take in essence a
           spacious approach to determine what other components
           and systems structures within that vicinity could in
           fact impact those SSCs.
                       Once that is determined, then they would
           have to do a credible job of reviewing what sorts of
           failures could these non-safety related SSCs have that
           could potentially impact those safety related SSCs.
                       With that fundamentally laid out the staff
           really came up with two options for applicants.  In
           doing this review, they have the ability to either
           take credit for certain mitigative features if they
           could show through analysis that those features in
           fact would mitigate the effects of the failures of the
           non-safety SSEs that they are trying to credit.
                       A good example would be if a non-safety
           related pipe were to break and leak, or spill fluid on
           a safety related component, if there was some sort of
           shielding or mitigative feature that they could show
           could in fact ensure the safe function of that
           component, then we would consider that mitigative
           feature could be brought into scope.
                       And not necessarily requiring inclusion of
           the piping segment.  The other alternative if they
           cannot show that that mitigative feature is sufficient
           to protect that safety related function, the actual
           segment itself would be brought into scope.
                       I think that is consistent with the staff
           policy as we have developed it, and now it is a matter
           of going to each of the applicants and making sure
           they understand that general approach is the approach
           that the staff is trying to provide people.
                       CHAIRMAN BONACA:  But this is an approach
           as you said has been standing for a while.
                       MR. GALLETTI:  Yes, certainly since the
           Hatch review.
                       CHAIRMAN BONACA:  And you have in some
           specific cases where you have in fact mitigated
           protection of the component that you are concerned
                       DR. SHACK:  This didn't seem to arise in
           three of the applications that you have approved
           already.  Is that because of differences in their
           licensing basis or just the way that they have
           interpreted it?  Have they interpreted it closer to
           what you have interpreted it?
                       MR. GALLETTI:  I think it is probably a
           combination of those two things really.  It's how
           certain systems in the plant are credited in their
           design basis as to whether or not they are performing
           a safety related function or not.
                       But then once that is actually determined,
           reviewing the non-safety equipment that could impact
           that needs to be done by those applicants as well.
                       Now, in the past, I think what we found is
           that in certain cases it was clear that this was a
           question raised by the staff and then in response
           those applicants did something.
                       In other cases, they were more proactive,
           and as part of the application that level of detail
           was provided.  But it is something as a result of the
           Hatch review that we are actually going back and
           revisiting some dialogue with those previous
           applicants to understand and clarify that.
                       CHAIRMAN BONACA:  Now, for Hatch, the
           supports were seismic highly qualified are?
                       MR. GALLETTI:  Yes, sir.
                       CHAIRMAN BONACA:  And for Turkey Point,
           are they seismic highly qualified?
                       MR. GALLETTI:  I don't think so, but could
           you answer that.
                       MR. HALE:  They are non-safety related,
           but we are a fairly low seismic area, and we have
           demonstrated that the supports can hold up the
           structural components under seismic loading.
                       MR. GALLETTI:  I think the key issue here
           is for the supports themselves.  The applicant may be
           able to credit those supports for mitigating a seismic
           event.  But there are other mechanisms in play here
           that may render that non-safety related piping to
                       And that seismic support may not provide
           the mitigative feature that is necessary to handle
           that particular failure.  So other mitigative features
           may have to come into play, such as shielding, splash
           guards, pipe restraints, and other mitigative features
           would have to also be considered.
                       And in addition the mitigative features
           that are already in the plant may in fact not be
           sufficient to ensure that failure of these non-safety
           related components would not render a safety system
                       Therefore, regardless of what mitigative
           feature you do have, you may in fact still need to
           include that segment of piping.
                       CHAIRMAN BONACA:  Is this issue a generic
           issue just because of two different plants with really
           different kinds of issues still to do with two over
           one, and is NEI involved as a part of this resolution
           representing the industry?
                       I mean, is it an open issue for the
           industry, or is it just specific to the application
                       MR. GALLETTI:  I wish Kris was here.  I
           don't get involved with the NEI discussions.
                       CHAIRMAN BONACA:  This is a plant specific
           as of now?
                       MS. THOMPSON:  Well, it is on the list of
           remaining open items with respect to the GALL being
           issued for the industry, and I believe there was a
           steering committee meeting last week, and a
           demonstration meeting a week or two before that when
           it was raised as one of the items on the list.
                       MR. GALLETTI:  I think it is fair to say
           that there is certainly generic interest in the
           industry as to how this issue is going to be handled
           and resolved, and how it has been handled and
                       MR. HALE:  There is a list of what we call
           issues for ongoing dialogue between NEI and the staff,
           both associated with the SER.  Well, not the SER, but
           the standard review plan, and the GALL, and two over
           one is one of those.
                       And to get a better handle on guidance and
           the approach, and trying to get a little more
           consistent approach, especially with the older plants.
                       DR. ROSEN:  What is the Turkey Point
           design basis earthquake?  You said it was low seismic?
                       MR. HALE:  Yes.
                       DR. ROSEN:  And what is it?
                       MS. THOMPSON:  It's about .15G if I
           recall.  It is very low.
                       MR. HALE:  Yes, .15 horizonal, and .1
                       MS. THOMPSON:  We are the lowest in the
                       DR. ROSEN:  I don't think so.
                       MS. THOMPSON:  Well, I thought we were.
           Perhaps not.
                       MR. GALLETTI:  So again as you have heard,
           we are going to have some additional dialogue with the
           applicant next week to try to better understand their
           resolution or proposed resolution to that issue.
                       MR. THOMAS:  As I mentioned before, DSSA
           is responsible for the review of the scoping and
           screening, and the results of that review in
           accordance with the applicable regulations.
                       Basically, what I have before you is just
           a slide that captures the scope of our review.  Our
           review -- let me say that the review team that I spoke
           of consists of about 11 individuals, each with their
           specific areas of specialty.
                       Now, I spoke before of the team if you
           will, and let me add that that review process could
           get complicated because of the addition of new team
           members, and utilization of staff for various reviews
           outside of the license renewal review.
                       But to the extent that we can, we try to
           keep some consistency across our applications so that
           there is consistency in the focus on the issues that
           are addressed.
                       For example, the fire protection, or the
           seismic two over one issue.  In this review of the
           Turkey Point application, certainly it was much less
           of a navigational challenge than the Hatch.  And when
           I heard Raj say that the review resulted in a number
           of REIs following some interaction with -- several
           interactions with the licensee.
                       And it turned out that a lot of the REIs
           were just a matter of providing clarification.  But
           basically the licensee took the approach of -- took a
           system approach and a structural approach if you will
           also, where systems, and compliments, and the related
           structures were decompartmentalized if you will.
                       So it was not a very complicated
           application to follow.  It was a matter of looking at
           a particular system, and getting a complete listing of
           all the SSEs within that system, including the
                       Now, there are some areas -- and a lot of
           our REIs have to do with clarification or with regard
           to some other commodity groups.  For example, the
           review of the office building, for example, and the
           containment building, there were REIs that had to do
           with fire retardant components, fire doors, et cetera,
           et cetera, and fire barriers.
                       Those types of complimentaries resided
           under another section, titled, "Fire Rated
           Assemblies."  So in terms of the navigation of a few,
           it wasn't very involved after we got some
           clarification from the licensee.
                       But basically we used the FSAR, the tech
           specs, and any licensing correspondence as stated
           earlier by the licensee, and specifically there were
           design drawings that accompanied the application.
                       And the design drawings highlighted and
           the -- well, let me back up a second.  The FSAR and
           the application, there were high points between those,
           and so it was not from that standpoint.  It was a
           fairly simple review.
                       But the design drawings highlighted the
           extent of the systems to the system boundaries, and
           they were easily read.  We really had no major
           problems in the review process.
                       As you can see, we basically reviewed --
           well, these just highlighted the major systems that
           were reviewed by the DSSA, and reviewed the reactor
           coolant systems, and the engineering safety feature
           systems, and what is presented here is just some
           examples of the systems.
                       But what I have given you is a count of
           the number of systems involved in the review, and all
           together there was 43 systems, and I want to say --
           no, I'm sorry, 37 systems and 16 structures, separate
           structural facilities, that was reviewed.
                       Raj mentioned that we had something on the
           order of 300 REIs, and then that is whittled down to
           like 200, and I think we ended up with maybe about 30
           of those REIs.
                       So as you can see altogether, initially I
           think we had something on the order of 60 REIs.  So
           half of our REIs were more of the clarification
           concern than anything else.
                       And in the end we really had no major open
           items.  Still to come though is how the seismic total
           one item is resolved, and I heard a question before
           about what sort of additional burden that will impose
           on the staff.
                       As was mentioned before, because they took
           a spacial approach if you will, and because they took
           a functional approach, which is as we have seen in
           previous reviews, like with the Oconee and Talbot
           plants, if the approaches to identify an area, and
           identify the safety related systems in that area, and
           identify the non-safety related systems that are in
           that area that are believed to be within the
           proximity, that if there is a failure, will infringe
           upon the functional capability of the safety related
           system, then that I think would not be much of a
                       But the burden of a follow-on review then
           would be much reduced, and that is all that I have.
                       MR. AULUCK:  Any questions?
                       CHAIRMAN BONACA:  Thank you.  If we have
           any questions, we will raise them as we move through
           the systems.
                       MR. AULUCK:  Next is Meena Khanna.
                       MS. KHANNA:  Good morning.  My name is
           Meena Khanna, and I work in the Division of
           Engineering, Materials and Chemical Engineering
           Branch.  Basically I will be presenting the first
           three sections of the Turkey Point license renewal
                       I would like to start by just telling you
           basically the staff and GE that we have got two
           reviews that we conduct; one is on the systems, and
           with the system review, what we do is we just try to
           verify that the applicant has adequately identified
           all the aging effects, and has adequately identified
           the aging management programs to manage these aging
                       The second review is of the aging
           management programs, and Ms. Keim will discuss that
           later in Section 3.8.  She will discuss the process
           that we actually go through in reviewing the aging
           management programs.
                       And I will go ahead and start with the
           common aging management programs.  Section 3.1 of the
           application included a description of the common aging
           management programs.
                       Again, Ms. Keim will also address the
           common aging management programs in Section 3.8. 
           However, the three that we reviewed under common aging
           management programs include the chemistry control
           program, and the FPL quality assurance program, and
           the systems and structures monitoring program.  We
           will go into details again in Section 3.8.
                       CHAIRMAN BONACA:  Let me try to understand
           this.  This is part of what they missed in the
           application as existing aging management programs.
                       MS. KHANNA:  Exactly.
                       CHAIRMAN BONACA:  And you are pulling out
           these three right now in this presentation.
                       MS. KHANNA:  Right.  Let me just say that
           when we call them a common aging management program,
           that is basically an aging management program that is
           going to apply to two or more systems or components.
                       CHAIRMAN BONACA:  I see.
                       MS. KHANNA:  So these three have actually
           been identified as those aging management programs
           that will apply --
                       CHAIRMAN BONACA:  I understand.
                       MS. KHANNA:  And there were no open items
           that were found with either one of these three common
           aging management programs.  However, there is one
           confirmatory action item, and that is in regards to
           the quality assurance program, and that is just a
           minor SER supplement that is needed and Andrea will
           discuss that later.
                       Now, let's go to Section 3.2, the reactor
           coolant system.  I would like to acknowledge Alan
           Hiser.  He was actually the lead for the reactor
           coolant system.  I am going to go ahead and present it
           for him.
                       The components of the reactor coolant
           systems include the reactor coolant piping, Class 1
           and non-Class 1 components; the regenerative and
           excess letdown heat exchangers, pressurizers, reactor
           vessels, reactor vessel internals, reactor coolant
           pumps, and steam generators.
                       CHAIRMAN BONACA:  Now, are these all
           existing programs?  I don't think so.  There are some
           reactor vessel internal inspections which are new
           problems, right?
                       MS. KHANNA:  These are actually the
           systems.  The aging management programs, they are
           handled in Section 3.8, and there is a reactor vessel
           internals inspection there, and that will be covered
                       Notes of interest include Florida Power
           and Lights AMR results were compared to the following
           topical reports.  The first one was WCAP-14574 on
           pressurizers; and WCAP-14575 on piping; WCAP-14577 on
           reactor vessel internals.
                       However, the staff noted that the FPL did
           not incorporate the topical report results by
           reference.  And I would note that I believe there was
           a question that I believe, Mr. Bonaca, you had asked
           earlier about the reactor vessel internals WCAP.
                       CHAIRMAN BONACA:  Yes.
                       MS. KHANNA:  And jus to clear it up, we
           did have REIs that went out on the reactor vessel
           internals action items, and the applicant adequately
           identified them.  We are satisfied with all their
           responses and that was -- and they were noted, all the
           findings were noted in our response, or in their
                       CHAIRMAN BONACA:  Well, my question was
           regarding the pressurizer.
                       MS. KHANNA:  Okay.  Right.
                       CHAIRMAN BONACA:  And there the SER finds
           at least four of the applicant action items -- well,
           I mean, the pressurizer, while topical, has maybe 10
           applicant action items.
                       MS. KHANNA:  Right.
                       CHAIRMAN BONACA:  And the SER identifies
           four as being applicable to Florida.
                       MS. KHANNA:  Right, to Turkey Point.
                       CHAIRMAN BONACA:  To Turkey Point, and I
           was left searching around for where the others are
           being discussed in the application.  Well, not in the
           application, but in the SER.
                       MS. KHANNA:  In the SER, right.
                       CHAIRMAN BONACA:  And where they are
           discussed is in the REI response on the reactor
           cooling system.
                       CHAIRMAN BONACA:  Well, some of them are
           considered non-applicable, and I don't understand why
           they were not applicable in all cases.
                       MS. KHANNA:  Well, we have got Alan Hiser
           here.  Alan, would you like to talk on that?  We are
           talking about the pressurizers, the topical report on
           the pressurizers.  There were four action items that
           were not addressed.
                       MR. AULUCK:  There were four addressed and
           six were not addressed and the question is whether
           they were applicable at Turkey Point.
                       CHAIRMAN BONACA:  Well, I was left with
           searching around for those that were not addressed,
           and having to trust the judgment that says these are
           not applicable.
                       DR. FORD:  And with the exact equivalent
           question for the internals, too.  There are 11 action
           items in the internals program, and that is exactly
           the same question.
                       CHAIRMAN BONACA:  That's right.  And some
           of those in the report for the pressurizer were
           convincing.  Now suddenly they disappear for Turkey
           Point, and the statement says these are not
           applicable.  So I just don't understand.  I couldn't
           find --
                       MR. HISER:  I will have to get you an
           answer on this.  The lead reviewer on that is not here
           right now.
                       MR. HALE:  If I could offer at least from
           our perspective that it's not that the applicant
           action items were not applicable.  The applicant
           action items were already addressed in the
           application, and the reviewer who did the pressurizer
           review recognized, and only asked us those that
           apparently weren't covered in the application.
                       But we have addressed all of the applicant
           action items either in the LRA -- I mean, it wasn't
           because we had the list.  It's just that we had
           already covered the applicant action item in the aging
           management review that we had performed.
                       I can give you an example of one.  It is
           Applicant Action Item, which was covering
           commitments regarding the boric acid waste
           surveillance program.
                       Well, we had already covered that in our
           table, and we had already covered that in Appendix B
           with the boric acid waste surveillance program.  So,
           in the case of the pressurizer, at least in the
           interface that we had with the staff reviewer, he
           recognizes that some of that stuff was already picked
           up in the application.
                       So he only asked us those REIs, those
           applicant action items that weren't covered or weren't
           readily identifiable.  Now, in the case of the
           internals, we got a letter with all of the applicant
           action items listed, and requested a response from us.
                       CHAIRMAN BONACA:  Okay.  That is probably
           the explanation for that.  The text was not clear. 
           The text says that during the staff review of the
           pressurizers, the staff determined that four of the
           applicant action items summarized in the staff SER and
           WCAP were applicable to the AMR for Turkey Point, and
           the staff requested an explanation on this.  And
           that's why the others are not so.
                       MR. HALE:  Right.  They may have concluded
           that because it was already in the application.
                       CHAIRMAN BONACA:  It is just simply left
           me with no answers to the others, and the answer may
           be right in the application.  I agree with that, but
           it wasn't clear.
                       MR. HISER:  I believe in the internals
           topical report that we did list the 11 action items
           and the specific responses.
                       DR. FORD:  Okay.  And were the responses
           to those quantitative, because in that WCAP-14574, the
           reactor vessel internal one, it is continually
           referenced to the ASME 11 code as to what the
           frequency of the inspections would be.
                       It is a beautiful criteria on what an
           aging management program should specify with data, but
           in the response to the REIs on Turkey Point were the
           response quantitative?  Do you understand my question?
                       MR. HISER:  Yes.  I believe in some cases
           they were, in terms of the inspection program
           activities.  In some areas the details on the programs
           are still being developed through industry, and MRP
           programs, and those kinds of activities.
                       So the quanitativeness isn't really there
           at this point.
                       DR. FORD:  Now, are we fairly sure as an
           industry that we are collecting the relevant data?
                       MR. HISER:  We are monitoring everything
           that is going on with the industry.  We have periodic
           public meetings with the MRP to discuss the status of
           their program, and what their plans are.
                       At this point the programs are proceeding
                       DR. FORD:  In a timely manner?
                       MR. HISER:  Yes, in a timely manner.
                       DR. FORD:  Well, it wasn't a statement. 
           It was a question.
                       MR. HISER:  Yes. At this point, yes.  We
           are satisfied with the scope, and status, and plans in
           the program.
                       DR. FORD:  And do we know how to define
           timely in relation to the effect on some risk informed
           basis, like a delta-LOCA?  If we have a failure event
           occurring, which of the ones out of that list of
           components are going to give you a real heartache?
                       And are we in the expected time period
           going to get the data to come up with what renewed
           frequency should be for inspection?
                       MR. HISER:  Well, I think that of the
           items that are listed there that the main activity is
           in the reactor vessel internals area, and the industry
           program timeliness is tied to plants entering the
           license renewal period.  And the plants having
           programs in place as they enter into that period.
                       MR. ELLIOT:  This is Barry Elliot.  The
           reactor vessel's internal program, there are two parts
           to the program.  There is the research part of the
           program, and then there is the inspection part of the
                       The inspection part of the program is a
           commitment by them to do inspections of limiting
           locations in the reactor vessel internals, once during
           the first 10 year interval, and the other unit during
           the second 10 years of the extra period.
                       So they have to have their research
           results to meet that schedule, and they will have it
           to meet that schedule.  That is the plan and that is
           how we have written up the program.
                       DR. FORD:  But these in your intervals,
           Barry, are based on --
                       MR. ELLIOT:  Well, you asked whether or
           not it will be in time.  The time needed for the data
           is in year 41 of the operating cycle of the plant
           operation.  That is the program.
                       They will inspect the first unit in year
           41 according to whatever the research results are from
           the research program.  The second unit will get
           inspected in the next 10 years of the operating
                       It will use the results of the research
           program, plus whatever the results are from the first
           10 year first unit.  Now, that is the plan today.
                       When we get research results, and if it
           shows that there is an immediate problem, then we
           won't do it in year 41.  We might have to do it in
           2002 or 2003.  But that is the current plan.
                       DR. FORD:  I can understand the reason,
           that you have to have a date to go into this.
                       MR. ELLIOT:  Right.
                       DR. FORD:  You can't just say we will
                       MR. ELLIOT:  Right.
                       DR. FORD:  You have to draw a line in the
           stand if you like.
                       MR. ELLIOT:  Right.
                       DR. FORD:  But what concerns me is that
           there is surely enough data in the technical community
           right now to say -- and especially for the older
           plants with the higher fluence level, that a 10 year
           period is nowhere adequate enough.
                       MR. ELLIOT:  Well, that is going to be the
           results of the research programs, and to look at all
           the data, and to come up with an answer for that
           question.  You have to look at everything, and that is
           one of the issues that I am sure the program will look
                       DR. FORD:  Obviously we are getting into
           a great big technical argument of, yes, you do; and,
           no, you don't, but in terms of delta-LOCA as a
           parameter to prioritize where you should be putting
           your money to come up with this data in a timely
           fashion, have they gone through that sort of analysis?
                       MR. HISER:  I don't think it has been
           looked at in a risk-informed sort of mode.  It has
           been more of a deterministic mode, where aging
           mechanisms, and combinations of materials and
           environments have been identified as potentially
           requiring additional attention.
                       And the industry programs are looking at
           the parameters that would be involved and determining
           when and under what conditions the mechanisms could
           become important.  And then developing inspection
           tools that would be effective in managing those
           mechanisms for those materials for these components.
                       DR. FORD:  I guess that this goes way
           beyond Turkey Point, Mario, and specifically it does
           relate to Lochbaum's assertion that relicensing
           programs and the data from which they are based are
           not adequate.
                       CHAIRMAN BONACA:  Well, I believe that the
           examples that Lochbaum made, 8 or 10 were related to
           active components that wouldn't really even fall in
           the scope of relicensing if I understand, if I
           remember that.
                       And again, however, I don't think that
           license renewal insofar as the process we are
           implementing  there is to review the life cycle
           management, and the procedures is going to have all
           the details of what needs to be done in the program
           right now.
                       What we need to have is a commitment by
           the licensee that he recognizes the issue, and he has
           prepared himself to deal with the issue, and that
           through the corrective action program he has, he has
           performed those actions that are considered by the
           requirements to be appropriate.
                       And that will be different when we get
           there than they are today most likely.  I mean, just
           because we will know about it.  Now, I think the only
           place where we can have some discomfort is where some
           issues that may not ever be experienced, and then make
           them up.
                       But again that will have to be dealt with
           at that time, and will be part of the core licensing
           interaction within the staff and the NRC, and not
           necessarily of the license renewal, because that would
           become part of the license renewal.
                       MR. HISER:  And we have tried in
           particular in the reactor vessel internals area to try
           to crystal ball some of the issues that may come up,
           and that we don't think are an issue for 40 years, but
           could with fluences increasing, and exposure times
           increasing, they may become important.
                       And right now the data for relevant
           conditions isn't sufficient to tell us that we
           definitely would have a problem, or we definitely do
           not have a problem.  So the industry is trying to
           collect the data that would help them to determine the
           potential problem, and then propose appropriate
           management schemes.
                       DR. FORD:  I have another question, and I
           don't know who to ask, but on steam generators, we
           have been talking about future events.  But there have
           been problems, and I think it was in one of the WCAP
           documents that was saying that we were safe from many
           of the cracking problems because we monitor the oxygen
           and the chloride contents, et cetera.
                       Well, it is not really oxygen that you are
           interested in.  It is corrosion potential, and you can
           high corrosion potential from copper from condensers
           on the secondary side, and at Indian Point we did have
           cracking of the vessel because of copper coming from
           the condensers.
                       Now, does that come into these programs
           and into these GE management programs?
                       MS. KHANNA:  There is a steam generator
           integrity program that adequately addresses that.
                       DR. FORD:  Then it is just the steam
           generators that are on this slide then?
                       MR. HISER:  Right.  Steam generators is
           one of the components of the RCS.  However, there is
           an aging management program that specifically is
           called a steam generator integrity program, and that
           adequately identifies that.
                       DR. FORD:  That specific item is watched
           for copper tube flux within the --
                       MS. KHANNA:  Could you guys answer that?
                       MR. HISER:  Well, for one thing, when we
           replaced the steam generators, we replaced all the
           condenser tubing with titanium.  All of our feed water
           heaters are stainless tube now.  So we minimize copper
           as an additional preventive action.
                       And we do sludge lancing and all that
           stuff related to ensuring tube integrity is
           incorporated into the steam generator integrity
           programming, as well as our current testing of the
                       And you see that both in your chemistry
           control program and in the steam generator integrity
                       MS. KHANNA:  Okay.  Great.  I will go back
           to the review.  The second note of interest that we
           noted for the reactor coolant system is that the
           reactor vessel had penetration nozzle cracking was
           managed by the reactor vessel had the 600 penetration
           inspection program.
                       There will be a presentation made on the
           Ally 600 penetration inspection program.  There was an
           open issue also identified on CRDMs, and that will
           picked up in a later discussion in Section 3.8.  
                       So basically there were no open items in
           regards to the reactor core systems.  We will go to
           Section 3.3, engineering safety features.  The ESF
           systems include emergency containment cooling systems,
           the containment spray, the containment isolation, the
           safety injection, residual heat removal, emergency
           containment filtration, and containment post-accident
           monitoring and control.
                       The staff found that the applicant
           adequately addressed all the aging effects for each of
           the components and the systems of the ESF, and also we
           also found that the aging management programs to be
           appropriately addressed for each of those aging
           effects as well.
                       So we also found no aging -- I'm sorry, no
           open items with the ESF.
                       CHAIRMAN BONACA:  The containment
           monitoring and radiation protection system, that does
           not have an aging management program for it?
                       MS. KHANNA:  Right.  There were no aging
           effects found to require an aging management program.
                       CHAIRMAN BONACA:  And could you explain
           more on that?  So there were no aging effects found
           for that?
                       MS. KHANNA:  Right.  The applicant didn't
           identify any aging effects, and we found -- well, what
           we do is we use the GALL report and we compare the
           results.  And if we found that they had adequately
           identified the aging effects --
                       CHAIRMAN BONACA:  Well, this was a
           question from John Barton.  What you are saying is
           that it was in scope, but you found no aging effects
           that would justify a management program?
                       MS. KHANNA:  Right, that's correct.
                       CHAIRMAN BONACA:  John thought that they
           were not in scope, and they are in scope.  All right.
                       MS. KHANNA:  But they were identified as
           being in scope, and so we went ahead and reviewed it,
           and it is in scope.
                       CHAIRMAN BONACA:  And there was another
           question here from Mr. Barton regarding the MSIV. 
           There are two different designs for the reserve tanks
           that are used to operate the MSIVs, and on Unit 4
           there are reserve tanks that are used or they are
           simply accumulated that are used.
                       And those are in the scope of license
           renewal.  For Unit 3, there are bottles.  I mean,
           bottles that are used for the safety function.
                       MR. HALE:  That's right.
                       CHAIRMAN BONACA:  So if I understand it,
           you do have reserve tanks that are used for normal
                       MR. HALE:  The MSIV normal operation is
           just basically instrument error.  What these are, the
           air accumulators on Unit 4 and the nitrogen bottles on
           Unit 3, are under certain accident scenarios, if you
           assume leakage of the actuator, and you have an equal
           DP, or a no DP across the MSIVs, it could come back
           open again.
                       So we provided a back up source to
           instrument error for the MSIVs.  Now, with regards to
                       CHAIRMAN BONACA:  Okay.  For Unit 4, they
           are treated different?
                       MR. HALE:  They are different.  It was
           kind of a decision that was made for Unit 4 to go with
           something that didn't need to be replaced
           periodically.  The bottles are monitored for pressure
           and they are replaced periodically.
                       Whereas, the air accumulators on Unit 4
           are just an in-line tank.  So what was the question?
                       CHAIRMAN BONACA:  The question is that you
           do have the instrument accumulative tanks for Unit 4
           are in fact subject to an AMR.
                       MR. HALE:  Right.
                       CHAIRMAN BONACA:  While for Unit 3, you
           took the position that the bottles are not long term,
           and they are replaced.
                       MR. HALE:  Right.  They are replaced on a
           -- the pressure is monitored, and they are replaced
                       CHAIRMAN BONACA:  And how is it monitored?
                       MR. HALE:  Actually, there is tech spec
           requirements that they be maintained at a certain
           pressure level, and if it drops below that for
           whatever reasons -- you know, testing, leakage,
           whatever it might be -- they are monitored and
                       So we considered those replaced
           periodically and as such didn't require an aging
           management review.
                       CHAIRMAN BONACA:  And the monitoring is a
           periodic monitoring with tech specs?
                       MR. HALE:  Yes.  We are required to
           maintain a certain pressure.
                       CHAIRMAN BONACA:  Okay.  All right.
                       DR. ROSEN:  When you say periodic
           monitoring, what do you mean?
                       MR. HALE:  Whatever the requirement is,
           but they are stipulated that we have to maintain a
           certain amount.
                       DR. ROSEN:  Well, does somebody go out and
           look at these bottles every four hours or something
           like that?
                       MR. HALE:  There is pressure indication.
                       DR. ROSEN:  In the control room?
                       CHAIRMAN BONACA:  In the control room, no.
                       MS. THOMPSON:  I don't know if it is in
           the control room.
                       MR. HALE:  I would have to look at the
                       MS. THOMPSON:  They are monitored
           relatively frequently, and we are not talking about
           once every 18 months or something.  They are on
           regular operator rounds.
                       CHAIRMAN BONACA:  All right.
                       MR. HALE:  The same question was raised in
           our REIs and we got a response to that as well, which
           summarizes I think some of the specifics that you are
           asking for.
                       CHAIRMAN BONACA:  All right.
                       MR. AULUCK:  Next we will go to the
           auxiliary systems, and James Davis will cover that.
                       MR. DAVIS:  There are 15 systems on the
           auxiliary systems that we looked at.  We thought that
           the application was very good this time.  The best one
           that I have seen so far.
                       We had a number of REIs, and they were
           fairly simple.  They basically were that the words
           didn't match the tables, and things like that, and we
           just cleared those up very quickly.  There were no
           real surprises.  So we ended up with no open items.
                       Are there any questions on these systems? 
           If not, on steam and power conversion systems, these
           included the main steam and turbine generators, and
           feedwater and blowdown, and the auxiliary feedwater
           and condensate storage.
                       And there were no show stoppers here. 
           They were just conditional REIs, but they basically
           were to just clarify the text and the tables again. 
           And there are no open items here.
                       CHAIRMAN BONACA:  I would like to go back
           just a second.  I had a question about that there is
           a discussion in the SER regarding inaccessible
           locations, the pressurizer, the pressure vessel, and
           steam generators, and vessel internals.
                       And I would like to have a better
           understanding of how that is being dealt with in
           inaccessible locations in the pressurizer, the
           pressure vessel internals, and steam generators.
                       MR. AULUCK:  In the inaccessible areas,
           they go look at the accessible areas for possible
           clues, and then follow it up in the inaccessible
                       CHAIRMAN BONACA:  Well, assume that you
           have a clue and it may be something that is in an
           inaccessible area.
                       MR. HALE:  Well, I think we saw quite 
           disparity in how previous applicants have addressed

           this.  We have had some applicants say that there are
           no inaccessible areas in the power plant, and with the
           right amount of money or whatever, you can always make
           something accessible.
                       We took the perspective that with
           inaccessible areas, if something is not readily
           visible, and something where you would have to take
           extraordinary measures in order to see things.
                       Certainly there are observation techniques
           that you can utilize, such as t.v. cameras on -- you
           now, remote, very tiny t.v. cameras.  In fact, we are
           going to utilize some of that in our head penetration
           visual inspection.
                       So I think that the aging management
           review pretty much stands on its own.  The programs
           that we credit, if we see something, then we would be
           obligated to go look at these other areas if it was
           applicable.  But in terms of how we define
           inaccessible --
                       CHAIRMAN BONACA:  I wasn't in effect
           asking about your obligation.  Of course, you do have
           to fill a commitment.  I would reach the same judgment
           that any inaccessible area can be made accessible if
           you have to, and if you have indications.
                       MR. HALE:  Right.
                       CHAIRMAN BONACA:  One thing that comes
           through the application and the SER are some questions
           regarding looking at operator experience.  And there
           are issues that may prompt you to say that I don't
           have any problem, but there may be something.
                       You have been looking also at other power
           plants in the Westinghouse Owners Group, right?
                       MR. HALE:  Right.  Yes.  As part of each
           one of those GTRs that were mentioned, and not just
           the ones were submitted, but also the other ones that
           we used as source information, it was basically an
           integrated look at all the experience for those
           particular components on the Westinghouse plants.
                       So we did that, and we also have our
           sister plants, or our other plants up at St. Lucie. 
           So we have got a broad database to draw on, and we did
           an extensive review of our operating experience as
                       As you have seen, we actually used
           experience which may have happened at St. Lucie and
           Turkey Point.
                       CHAIRMAN BONACA:  Okay.  Thank you. 
           That's all I needed.
                       MR. MUNSON:  I am Cliff Munson and I am in
           the civil engineering group.  We reviewed the
           structures and structural component section.  The
           applicant divided it into two groups.  The first group
           was containment, and then the second group was other
                       And they further divided these two groups
           into commodities and environments.  So they have steel
           in air, and steel in fluid, concrete, and we looked at
           the aging effects that were identified by the
           applicant to make sure that they included all the
           applicable aging effects.
                       The three aging effects that they
           identified for the steel and concrete groups were loss
           of material, cracking, and change of material
                       And for the containment structure, post-
           tensioning, they also identified loss of pre-stress. 
           For the miscellaneous structure component, they
           identified loss of seal, as well as loss of material.
                       We didn't have any open items.  I have
           reviewed all of the applications up to date, and this

           was very easy to follow.  We were able to find pretty
           much everything we looked for, and they had
           -- I think they thoroughly covered the aging
           mechanisms that would lead to these aging effects.
                       And I thought it was an excellent job that
           they did.
                       CHAIRMAN BONACA:  I have a question
           regarding the in-take structure.  There is no
           management, aging management of this structure, and
           there are a lot of systems or components attached to
           the structure that in fact do have an aging management
                       And I really wondered why -- and also John
           Barton faxed me a comment about that, that there is no
           aging management program of the in-take structure.
                       MR. MUNSON:  Okay.  Is Arnold Lee here?
                       MR. LEE:  Yes.
                       MR. MUNSON:  Can you address his question?
                       MR. LEE:  What was your question again?
                       DR. DUDLEY:  Come to the mike, please.
                       MR. LEE:  I am Arnold Lee.
                       CHAIRMAN BONACA:  In reading the
           application and the SER, clearly there are a number of
           systems or components which are attached to this
           structure which are important to safety which are part
           of the aging management program, but there is no aging
           management program for the structure itself.
                       MR. LEE:  There is no aging management
           program for the structure.  It is for the steel.
                       MR. MUNSON:  For the in-take structure.
                       CHAIRMAN BONACA:  For the in-take
           structure.  Could you explain a little bit why that
                       MR. LEE:  Maybe I didn't understand the
           question.  Could you repeat it again?
                       CHAIRMAN BONACA:  Yes.  Let me just go
           through some notes here.
                       MR. LEE:  There are a number of aging
           management programs to cover the aging effect, and
           there is a structural monitoring program, a systems
           structural monitoring program.
                       CHAIRMAN BONACA:  And that covers also the
           in-take structure?
                       MR. LEE:  I have to look into that.  I
           have to check whether that indeed would manage the
           aging effect for the in-take structure.
                       CHAIRMAN BONACA:  I would like to have you
           find that out.
                       MR. LEE:  Yes, I can find out.
                       MR. HALE:  If you look at the application,
           Table 3.6-13, I am not sure the question that he is
           raising, but we highlight the systems and structures
           monitoring program for structural steel, anchorages,
           and embedments.
                       CHAIRMAN BONACA:  And again the table is
                       MR. HALE:  It is 3.6-13, which is the in-
           take structure, and it lists all the component
           commodity groups which require an aging management
           review on page 3.6-85.  So I am not sure what the --
                       CHAIRMAN BONACA:  So, okay.  You do have
           it.  I believe the question was -- or the one from Joe
           Barton -- related to the structure itself that
           supports so many of these components here.  For
           example, the instrument rack and frames.
                       MR. HALE:  Right.
                       CHAIRMAN BONACA:  And the question he had
           was regarding the actual grid structure.
                       MR. HALE:  Well, reinforced concrete,
           foundation, beams, columns, walls, floor slabs,
           systems and structure of monitoring program.
                       CHAIRMAN BONACA:  Okay.  So it is under
           that, and you have a visual inspection program to look
           at spaulding and things of that kind.
                       MR. HALE:  Yes.
                       CHAIRMAN BONACA:  All right.  So you do
           have it then.
                       MR. AULUCK:  Okay.  Next we will cover the
           electrical portion of the review.
                       MR. SHEMANSKI:  My name is Paul Shemanski,
           and I am with the Division of Engineering, Electrical
           Branch, and basically for the electrical and
           instrumentation, and control section, Section 3.7,
           there were three groups of equipment that were
           identified for an aging management review.
                       These included basically insulated cables
           and connections, uninsulated ground conductors, and
           there were 22 electrical penetration assemblies. 
           These are non-EQ penetration assemblies.
                       There are additional penetration
           assemblies in the plant, but they are treated under
           the EQ evaluation.  They are evaluated as a time limit
           of aging analysis.
                       There were no open items.  However, there
           were two items of interest.  The first one deals with
           non-EQ medium voltage cables that may be subject to
           significant moisture.  The moisture would come in
           basically for cables that are in conduits, cable
           trenches, duct banks, underground vaults, or direct
           buried installations.
                       And at Turkey Point, they have a unique
           design.  These cables are designed with a lead sheath
           around the insulation that basically prevents the
           ingress of moisture, and the moisture would be the
           phenomena that would be the result of a failure in
           these cables if moisture gets in and it is subjected
           to a long term exposure.
                       And also energized at the same time, you
           could get an effect called water traying.  That's
           where the insulation basically breaks down and it
           ultimately could lead to cable failure.
                       This goes back to the Davis-Besse event
           back in October of 1998, I believe.  However, because
           of their unique design at Turkey Point, with the
           alleged sheath around the cable insulation, basically
           that precludes any moisture ingress.
                       So as a result there was no aging
           management program required for these medium voltage
           cables.  And this second item of interest was the fact
           that in response to a staff request for additional
           information, the applicant developed an aging
           management program for non-EQ cables, connections, and
                       And these are the components that may be
           subjected to a localized adverse environment caused by
           increased radiation or temperature.  These components
           will be inspected every 10 years.  It is basically a
           visual type inspection, looking for degradation of the
           cable outer jacket, and looking for discoloration,
           cable cracking, and that type of thing.
                       The program that they proposed, as I
           mentioned, it is a new program, and it is consistent
           with the cable aging management programs that we have
           described for non-EQ cables.
                       CHAIRMAN BONACA:  Let me ask you a
           question now.  Does it mean that this program here is
           also looking at those cables were said are already
           protected by this lead sheath?
                       MR. SHEMANSKI:  No.
                       CHAIRMAN BONACA:  It is not?
                       MR. SHEMANSKI:  We have three separate
           programs deigned in goal.  One of them looks
           specifically at medium voltage cables.
                       CHAIRMAN BONACA:  That's right.
                       MR. SHEMANSKI:  And that one, because
           those are typically inaccessible, a visual inspection
           would not work.  So those cables will be tested every
           10 years, starting at year 40, and then year 50, to
           give you two data points.
                       Because of their unique design here with
           the lead sheath, there was no need for them to enter
           a cable aging management program.  The theory is that
           water should not get into the insulation based on the
           design of these cables.
                       The cable aging management program they
           did propose, those are for non-EQ cables, inside
           containment primarily subject to localized adverse
           environments from radiation and temperature.  And that
           program is consistent with the way they have been
           described in-goal.
                       CHAIRMAN BONACA:  A member of the
           subcommittee who is here raised a question regarding
           the first bullet here, the one protected by a lead
           sheath.  I mean, he was asking the prudency of going
           all the way to 60 years without looking at those
                       I mean, how comfortable are we that this
           design is so consistent that it will last the 60 years
           without even looking at it?
                       MR. SHEMANSKI:  Well, these cables are
           periodically energized and I believe they do periodic
           measure tests on them.  But I think the bottom line is
           that these cables are very robust.  They brought in a
           sample of several of these cables, and again they are
           medium voltage cables.
                       Medium voltage cables are anywhere from
           2,000 to 15,000 volts.  So by their very nature, they
           are very thick.  The one that they brought in a sample
           of, the cable diameter must have been one inch in
           diameter, and maybe 1-1/2 inches, and the alleged
           sheath was quite sizeable.  I forget, but it may be
           nearly a quarter of an inch thick.
                       So it is pretty inconceivable that you
           would get degradation of that alleged sheath even at
           60 years, I think.
                       CHAIRMAN BONACA:  And do you have
           significant industry experience with those?
                       MR. SHEMANSKI:  Well, the interesting
           thing about it is that Florida Power and Light's
           transmission and distribution standards outside of the
           power plants, because we are subject to ground water,
           standardize an alleged sheath cabling specifically to
           ensure reliability of our underground cables in our
           housing, commercial industry, and that sort of thing.
                       So we have a lot of experience with it,
           and that got carried over into our power plants as a
           standard design.  So that particular feature is
           specifically pointed towards a reliability for cable
           that may be subject to moisture.  We have a lot of
                       CHAIRMAN BONACA:  Of course, with 45 years
           passing, and then you went to look at it, you would
           certainly go back and --
                       MR. SHEMANSKI:  Well, we have had a lot of
           T&D installations in for even longer than that.
                       CHAIRMAN BONACA:  I understand that, but
           I am trying to again develop the thought process
           behind license renewal, which is that you would go
           back with your corrective action program, and if
           necessary, you would have to address it for problems.
                       So to the best of our knowledge and
           understanding of the technology right now, you don't
           see the need for that?
                       MR. SHEMANSKI:  No, not at this point.
                       CHAIRMAN BONACA:  All right.  Thank you.
                       MR. AULUCK:  Next we will have aging
           management programs, new programs and existing
                       CHAIRMAN BONACA:  These are all one-time
                       MR. AULUCK:  Yes.
                       MS. KEIM:  My name is Andrea Keim, and I
           am from the Division of Engineering, Materials and
           Chemical Engineering Branch.  I am here to discuss
           their aging management programs.
                       I guess we will go back and start with the
           three common ones that they have listed, which were
           the chemistry control program, the quality assurance
           program, and their systems, structures, and monitoring
                       The staff evaluates all the aging
           management programs using their tenant tributes, or
           elements that are referenced in the standard review
                       We use these elements to determine if the
           intended functions of these structures, systems, and
           components, will be maintained consistent with the
           current licensing basis for the extended operation.
                       And after going over the first three, the
           common ones, there were no open items determined under
           these programs, although there is a confirmatory
           action item in regards to the FSER supplement for the
           QA program.
                       There may be other issues with the FSAR
           supplement due to the REI responses that may need to
           be updated to ensure that the programs are
           sufficiently -- that the program description is
           sufficient in the FSAR supplement.
                       DR. FORD:  Andrea, I heard Mario just say
           that these are really one inspection?
                       MS. KEIM:  Excuse me?
                       DR. FORD:  Only one inspection is made on
                       CHAIRMAN BONACA:  It is a one time
                       DR. FORD:  A one time inspection?
                       MS. KEIM:  I am talking first about the --
           these are the aging management programs.  Each one has
           different frequencies.
                       DR. FORD:  Oh, okay.  So it is not just
                       MS. KEIM:  Yes.  No.  I just wanted first
           to go back to really the three ones that they have
           listed as common aging management programs.
                       CHAIRMAN BONACA:  I understand that, but
           I am saying that what is listed in Appendix B, these
           seven programs are one-time inspections.
                       MS. KEIM:  Some are and some are not.  It
           depends on the frequency listed.
                       CHAIRMAN BONACA:  Well, I went through
           them, and all of them say one-time inspection, and if
           you find something, then you do more.
                       MR. HALE:  I believe the auxiliary feed
           water steam piping inspection is not a one-time
           inspection.  And the galvanic I believe is not, and
           the reactor --
                       MR. ELLIOT:  The reactor vessel internals
           is not a one-time inspection.
                       MR. HALE:  Right.
                       MR. ELLIOT:  We are doing one on each
                       MR. HALE:  But I know that the auxiliary
           feed water steam pipe --
                       CHAIRMAN BONACA:  One time for each unit. 
           Yes, that is the one time for each unit, but I am
           saying that with the others, I went over them, and I
           was trying to understand which ones are one time
                       The reason why we had the philosophy that
           we discussed before, a one-time inspection is an
           inspection performed where you do not believe that you
           are going to have an aging problem developing.
                       So you do it just to confirm that you have
           confidence that you will not have that problem.  Of
           course, now if you find that your expectation was
           optimistic, then you put in a program.
                       And so that's why I think it is important,
           and I want to look at them to convince myself that
           they are confirmatory in fact, and that we don't
           expect to have any problems in those areas.
                       And that's why I would like to ask those
           questions about the fact that they are one-time
           inspections, and they are different from the others.
                       MR. ELLIOT:  The only one I can answer is
           the reactor vessel internal inspection and the small
           bore piping, those are both one-time inspections, and
           the reactor vessel, in terms of one time of each unit.
                       And the small bore piping inspection is a
           one-time inspection, and it is a volumetric inspection
           of the critical locations.  And so these are for
           unanticipated cracks.  We have not seen cracks on
           these small bores yet.
                       And it is intended to look volumetrically
           to see if we do have cracks.  So that is within the
           scope of what you just described.  I can't answer for
           the rest of them.  I can only answer for those two.
                       MR. HALE:  But your interpretation is
           correct.  In those cases where we had a one-time
           inspection, it is usually to verify whether something
           is occurring or not, because we don't know.
                       CHAIRMAN BONACA:  All right.
                       MR. HALE:  Our tools tell us that we
           should have an aging effect, but we haven't seen it in
           our operating experience.  So it is a one-time
                       The auxiliary feed water steam piping
           though I know is one that we have or are going to have
           periodic inspections for, and I think if you read the
           description you will see that.
                       But the one time inspection is one of the
           reasons why most of these are new programs, because
           they are verification, and we have not had the
           operating experience, and it is one of the reasons why
           it is a new one that we haven't done yet if you want
           to look at it that way.
                       Now, the steam piping inspection program,
           based on some recent operating experience, we have
           identified the need to go out and look at not only
           internal, but the external surfaces of that piping,
           and we are doing that now.
                       But in terms of a formal program, we
           wanted to formalize it under license renewal.
                       CHAIRMAN BONACA:  You are correct.  The
           second one is not a one-time.  So I was wrong.
                       DR. FORD:  But in general the rationale is
           that you will inspect these in 30 years or 35 years,
           or whatever it might be.
                       MR. HALE:  We would use it as information. 
           One of the issues that the industry has right now is
           galvanic corrosion in treated water systems.  The do's
           say you have it, but we have not experienced it.
                       So galvanic susceptibility, we want to go
           and look at -- I mean, we certainly have experienced
           it in salt water systems and those where you have a
           high electrolyte process there.
                       So some of these we have not seen the
           experience, but we are going to go and inspect, and
           see if we see anything.  If we do, then we will commit
           to additional inspections.  We don't expect to find
           anything, with the exception of that one.
                       CHAIRMAN BONACA:  And again I am not
           questioning whether or not it is a problem.  It's just
           that typically I always look for the one-time
           inspections because to me when I read that, it is
           telling me that you do not inspect to see a problem. 
           You are just doing it to confirm that.
                       And if you in the verbiage you say that
           you are expected to find it, and then you decide what
           to do then, then a one-time inspection is not good
           enough.  That may be simplistic, but we had some
           understanding of that some time ago.
                       MS. KEIM:  At this point, I am going to
           hand it over to Cliff Munson, who is going to discuss
           the field erected tanks and internal inspection
           program, which does have an open item.
                       And after that, Jim Davis is going to
           discuss the galvanic corrosion susceptibility
           inspection program, which doesn't have an open item,
           but we wanted to highlight that program for you.
                       CHAIRMAN BONACA:  Since there are a number
           of potential questions here coming over the next
           couple of presentations, and that might take some
           time, I think we should break now and take a recess
           for lunch.
                       I think we will gain some time in the
           afternoon, particularly in the discussion here, and so
           we should still stay on schedule.  We will take an
           hour for lunch, and resume the meeting at 1:15.
                       MR. MUNSON:  I must wanted to cover one
           thing briefly.
                       CHAIRMAN BONACA:  Okay.
                       MR. MUNSON:  It is just a five minute
                       DR. ROSEN:  Will that release you for the
           rest of the afternoon?
                       MR. MUNSON:  Yes.
                       CHAIRMAN BONACA:  Go ahead.
                       MR. MUNSON:  This is one of the new aging
           management programs and it is a one-time inspection of
           these three tanks, and these are carbon steel coated
           tanks, and this is a new program, and so they have not
           developed any program requirements, in terms of the
           visual inspection.
                       And they have not developed acceptance
           criteria, and also the application was not clear on
           what previous operating experience there was.
                       So we asked for an REI on this, and they
           came back with some operating experience on the
           condensate storage tank and they actually recoated
           both of the tanks, one in '83 and the other one in
           '91, because of significant corrosion or degradating
           of the coating.
                       So we weren't clear if the demineralized
           water source tanks or the refueling water source tanks
           had been inspected.  So that also was part of the open
           item on this one.
                       So we have not yet accepted this as a one
           time inspection of the condensate storage tanks.  We
           are waiting for additional information.
                       CHAIRMAN BONACA:  Okay.  Let's break, and
           we will come back at 1:15.
                       (Whereupon, at 12:15 p.m., a luncheon
           recess was taken.)
                                A-F-T-E-R-N-O-O-N  S-E-S-S-I-O-N
                                                    (1:14 p.m.)
                       CHAIRMAN BONACA:  All right.  The meeting
           is called to order, and we will continue with the
           presentations by the staff.
                       MR. AULUCK:  We will continue with the
           aging management programs.  Andrea.
                       MS. KEIM:  We were discussing the seven
           new aging management programs, and Cliff Munson had
           gone over the field erected tanks, and internal
           inspection program with the open item, and now Jim
           Davis is going to discuss the galvanic corrosion
           susceptibility inspection program.
                       MR. DAVIS:  What they have done is they
           have identified a number of locations where basically
           you have carbon steel to the stainless steel
           connection.  We have no history of any problems with
           galvanic corrosion in these areas.
                       But they are going to do a one-time
           inspection just to verify that they are not having any
                       CHAIRMAN BONACA:  On all of these
                       MR. DAVIS:  These are all the component
           systems that were selected to be looked at.
                       CHAIRMAN BONACA:  Now, regarding the fuel
           tanks, I believe there is an open item on those?
                       MS. KEIM:  Yes.
                       CHAIRMAN BONACA:  Could you --
                       MS. KEIM:  The field director tanks.
                       MR. AULUCK:  Oh, the field director tanks
           are what you are talking about?
                       MS. KEIM:  Yes.  Can you show that slide
           back up again.
                       (Brief Pause.)
                       MS. KEIM:  And that one had to do with the
           acceptance criteria.
                       CHAIRMAN BONACA:  Oh, yes, I remember
                       MR. AULUCK:  They had not developed the
           acceptance criteria or limiting procedures.
                       CHAIRMAN BONACA:  And so all the 10
           elements are not fully defined, and that's what we are
           waiting for.
                       MR. AULUCK:  Right.
                       CHAIRMAN BONACA:  Okay.  Thank you.
                       MR. DAVIS:  Well, I missed my shot at the
           small bore piping inspection program before, but now
           that I have got an opening here with the galvanic
           program, I will take a crack at it from that point of
                       It is our old friend, the one-time
           inspection program, and galvanic corrosion
           susceptibility strikes me as a place where a one-time
           corrosion program is useful.  You know, I can go in,
           and I can see the damage, and I can characterize
           damage.  It is sort of visible.
                       When I look at the small bore piping
           program -- and until I have a crack, there is nothing
           to find.  I can have fatigue damage accumulating, and
           I am not going to see squat in my one-time inspection.
                       And I am not sure that -- well, that one
           just doesn't strike me as the place where a one-time
           inspection tells me a whole lot.
                       MR. AULUCK:  Well, with a volumetric
           inspection, you will learn something.
                       MR. DAVIS:  I will learn something, but I
           really won't learn -- well, I will learn that I have
           a crack, but a fairly high fatigue damage without
           initiating a crack, and not see anything.
                       There is a much higher threshold there
           before you get visible damage, and in a case of
           galvanic corrosion case and the process is going on,
           I would expect -- well, it is really a cumulative
           process and I would expect to see something.
                       And it strikes me again as something where
           a one-time inspection is useful.  I am not so sure
           that I see it, although the staff likes the one-time
           inspection for the small bore piping.
                       MR. ELLIOT:  Well, on the small bore
           piping, it is for piping that we have not seen a
           problem.  We have not really seen a thermal fatigue
           problem, and we have not seen a stress corrosion
           cracking problem.
                       DR. SHACK:  So it specifically excludes
           all the lines like we have seen int he B&W?
                       MR. ELLIOT:  That's right.  It excludes
           all of those.  If we have seen a cracking problem,
           like the Oconee HPI lines, those have a regular
           inspection program associated with that.
                       The purpose of the one-time small bore
           inspection is for small bore that we have not had a
           problem with, but we could have a problem for either
           stress corrosion cracking in a boiler, let's say, or
           a thermal fatigue problem potential for a PWR.
                       And the one time inspection is looking for
           whether there is a cracking problem associated with
           those types of mechanisms.  Now, it's granted that if
           you do more than one that you are going to get more
           data, but you have to look at it as where are we going
           to expend the resources to do inspections.
                       What we are saying is that we don't expect
           those, for anything to happen here, but just to be a
           little on the careful side, we are going to do the
                       DR. SHACK:  So you really are almost
           excluding the lines where you have seen problems.
                       MR. ELLIOT:  Right.  The lines that we do
           have problems, we have the HPCI program.
                       DR. FORD:  Would you mind going back to
           page 20, and just run down that list of the new aging
           programs just to confirm those.  I understand that
           small bore piping is not a one-time?
                       MR. ELLIOT:  No, it is.  It is.
                       CHAIRMAN BONACA:  The only one that is not
           a one-time inspection is the second one and the second
           to the last one.
                       DR. SHACK:  Well, now that we have brought
           this slide back, I can go to the reactor vessel
           internal inspection.  We are going to work our way
           right back to the beginning of your presentation.
                       The question that I had here was with VT1,
           and our friends with boiling water reactors have had
           lots of experience looking for cracks and have decided
           that VT1 isn't good enough to see cracks.  They go to
           a VT1 enhanced.
                       MR. ELLIOT:  Right.
                       DR. SHACK:  So these guys are doing VT1
           and ultrasonic, and I can justify to myself, okay,
           maybe I really can't see a whole lot with VT1, but
           they are going to do ultrasonic on the baffle bolt,
           and that is the most susceptible component, and I can
           live with it.
                       As I read the SER though, it seems to buy
           off on the VT1.  If I saw a rationale like that in the
           SER, then it is good enough for that reason, and I
           think I would buy it.  I didn't like the SER where it
           seemed to indicate that VT1 was really good enough to
           see stress corrosion cracks.
                       MR. ELLIOT:  That is a good point.  In the
           past we did have VT1 enhanced, and I noticed that in
           this one we didn't -- that Turkey Point didn't commit
           to do that.
                       DR. SHACK:  But they did commit to do the
                       MR. ELLIOT:  Right.  Right.  That was for
           the baffle floor bolt.  This will be proven out in
           essence, and --
                       DR. SHACK:  Well, haven't you already
           proved it in BWR?  I mean, GE didn't jump to VT1
           enhanced because they loved doing it.  They found out
           that they couldn't see cracks.
                       MR. ELLIOT:  But Turkey Point said that
           their experience was that they could see cracks.  That
           was the basis of what their experience was.
                       DR. SHACK:  Well, he has a lot more
           experience looking for cracks in internals than BWRs.
                       MR. ELLIOT:  Well, we will take that into
                       MR. HALE:  I think also one of the things
           that we should mention, too, is that with a PWR that
           you are dealing with a controlled chemistry, and with
           a BWR it is similar to, say, a secondary steam jet,
           from the standpoint of the controlled chemistry in a
                       The chemistry control is not exposed to
           some of the issues that you were raising before, such
           as copper and reactor vessel, and --
                       DR. SHACK:  Well, it is still a question
           of whether I can see a stress corrosion crack with
           VT1, or I have to go to a higher resolution.  I don't
           have a problem because you guys are doing ultrasonic,
           but it is just the more generic kind of thing that the
           notion of whether VT1 would be acceptable to see
           cracks that I have sort of objected to.
                       MR. HALE:  Well, there are a couple of
           things that I would like to clarify.  The stress
           corrosion cracking we are managing with a chemistry
           controlled program.
                       DR. SHACK:  Well, I should say IASCC.
                       MR. HALE:  IASCC.  Our leading indicator
           is the baffle bolts.  That is the area, and it is
           fluence related.  So we are using that as the primary
           indicator, and we are looking at that first.
                       DR. SHACK:  Well, my comment was more
           addressed to the staff.
                       MR. ELLIOT:  We understand your comment,
           but if they find cracks in the baffle bolts, then they
           have to look someplace else.  And if it requires an
           enhanced VT1, then that is what they are going to have
           to use.
                       They are going to have to prove to us that
           they are capable of detecting those type of flaws.  I
           mean, that is ultimately where you have to head here.
                       MR. DAVIS:  In general, the way we have
           been going is that you want to substitute a VT exam
           for a volumetric exam?  We have been requiring
           utilities to resolve a one mil fire with a visual
                       DR. SHACK:  Right.
                       MR. DAVIS:  Which is an enhanced.
                       DR. SHACK:  Which is an enhanced, right. 
           But I don't know why you just don't say that here for
           the RVI program.  If you said one mil against a gray
           background, I'm a happy man.
                       MR. DAVIS:  Okay.
                       MR. ELLIOT:  Okay.  I did not write the
           SER.  You are putting the cart before the horse
           because we have not looked at the baffle form bolts
           yet.  When we do that, and we see a problem, or if we
           see a problem, then this becomes something that we
           will have to consider.
                       CHAIRMAN BONACA:  Well, Barry, we are --
                       MR. ELLIOT:  You are talking about a
           visual examination for baffle bolts, and that is what
           we have been doing in the past.  Where this crack
           occurs is at the shank and where it joins the head. 
           And in looking at the head, you are not going to see
           this crack.
                       DR. SHACK:  Right.  Which is why the UT is
           so important.
                       MR. ELLIOT:  Right.
                       DR. SHACK:  And I am happy with the UT. 
           As I said, the UT is what saves the day as far as I am
           concerned as far as really making this acceptable. 
           It's just the notion that I am then going to look with
           the baffle bolt as my leading component, and if I then
           want to look somewhere else for cracking, I would
           argue that I would need the VT1 enhanced rather than
                       But you are right.  Once you find cracks
           in the baffle bolts, it might be a new ball game.
                       MR. ELLIOT:  And we appreciate your
           comments, and Turkey Point does, too.
                       DR. SHACK:  I have made my point.
                       CHAIRMAN BONACA:  No, no, I am just
           puzzled because I remember slightly the discussion,
           but I don't remember exactly what was said regarding
           just visual.  What you are saying is that if it leaves
           the impression that VT1 is adequate, then that is not
           the right impression.
                       DR. SHACK:  That's what I am saying.
                       CHAIRMAN BONACA:  Although it would be an
           issue for the SER, but not necessarily for the
                       DR. SHACK:  Right.
                       MS. KEIM:  Moving on to the existing aging
           management programs, and aging encompassed all these
           programs.  We are going to really just highlight the
           Alloy 600 program, head penetrations, which is going
           to be Barry Elliot discussing that.
                       MR. ELLIOT:  We sort of discussed this
           program earlier in the morning.  The reactor vessel
           head alloy 600 program, the program that is currently
           in the application is based on generic letter 97-01,
           and in this sense, it is part of your question of the
           regulatory process, too.
                       And that is that 97-01 was concerned about
           cracks in the nozzles themselves, axial cracks in the
           nozzles themselves, and that was what we were
           concerned about when we put out generic letter 97-01.
                       The industry responded to that concern and
           set up a program, and the program was leakage
           detection, and then volumetric inspection of selected
           components in selected facilities.
                       And Turkey Point, in their application,
           complied with that basic program.  And that is what
           this slide says.  Recently we had problems at Oconee,
           and they weren't the nozzle axial cracks.  They were
           circumferential cracks associated with the J-groove
           weld, and the heat affected zone, a different
           mechanism than we had previously seen.
                       So we put out a bulletin asking industry
           to respond to this mechanism, and industry has
           responded, and the staff is evaluating the response,
           and we will formulate with industry a resolution of
           the issue.
                       I just want to make one thing clear to
           you.  The NRC does not solve the problems themselves. 
           We resolve the problem through industry, and that is
           the process here.
                       We set up a process to resolve this
           problem, and the process for license renewal is to set
           up the processes within license renewal so that the
           issue doesn't get lost. It just stays within the
                       And in this case, because this is a new
           issue, the process is to have an open item and then to
           have a licensee to commit to whatever the program is
           that the industry develops for solving the issue in
           the bulletin.  And that is where we are on this issue.
                       CHAIRMAN BONACA:  Any questions?
                       DR. FORD:  I just find it very hard to
           swallow when you say that it is not within NRC's
           perview.  I think the NRC has got to take a leadership
                       MR. ELLIOT:  Let me just say that the NRC
           takes the initiative to identify the problem, and then
           we identify the problem in a way so that industry
           should understand where we are coming from, and what
           we think the problem is, and then we expect to propose
           solutions to us.
                       And if we don't like the solution, we say
           it is not good and we need another rock.  And this is
           the regulatory process.  Now, we have research here,
           and our research is not intended to solve all the
                       It is intended to look into what the
           industry is proposing to see if it is proposing
           something that we can live with, and that is how our
           research fits in here.  There is sort of more of a
           confirmatory aspect.
                       Now, there are areas where our research
           has been not confirmatory.  I will tell you that with
           the reactor vessel, the embrittlement, it was our
           research.  It really wasn't industry research.
           And with respect to the axial cracks in the nozzles,
           that wasn't the NRC.  That was the industry.
                       They proposed it and we went back and
           forth for a couple of years before we got a program
           that we thought was a good program, and the same thing
           is going to happen with the bulletin.
                       It is not going to come out next week, the
           answer, but the industry has proposed something and we
           are evaluating it, and we are going to resolve the
                       CHAIRMAN BONACA:  Any more comments?  All
                       MS. KEIM:  Next will be TLAAs.
                       MR. ELLIOT:  Okay. I am going to be
           talking about reactor vessel radiation embrittlement,
           and under metal fatigue, there is a fatigue issue
           related to the vessel, and I will talk about that.
                       Paul Shemanski will talk about
           environmental qualification of the electrical
           equipment.  There is a whole list of all of the TLAAs
           up there.  All the others don't have open issues.  The
           three that we are going to talk about have the open
           issues.  I'm done.
                       DR. SHACK:  Barry, why was leak-before-
           break for RCS system piping a TLAA?
                       MR. ELLIOT:  That's because of the cast
           stainless steel basically, is that -- you know, when
           they originally did the evaluation did they have
           saturation or not.  And then we have to look and see
           if there is saturation, and how it impacts the leak-
           before-break evaluation.
                       Okay.  On the reactor vessel, radiation
           embrittlement, there are three parts of the analysis. 
           There is the pressurized thermal shock analysis, the
           charpy upper shelf energy, and the pressure
           temperature limits.
                       They are all related to neutron and
           radiation embrittlement.  The pressurized thermal
           shock evaluation is done in accordance with our --
           with the rule, 10 CFR 50.61, which establishes a
           methodology for determining the amount of radiation
           embrittlement, and it establishes screening criteria.
                       In the case for Turkey Point, they did the
           evaluation in accordance with the rule, the screening
           criteria, and the limiting material for their vessel
           is a circumferential weld in the belt line, and the
           screening criteria is 300, and the RPPTS value they
           calculated was 297.4.
                       So they don't have a lot of margin.  So
           they have to keep track of the fluence and make sure
           that it doesn't increase the value of the RPPTS above
           the screening criteria.
                       DR. SHACK:  Do they have flexibility?  Do
           they have a low leakage core ready?
                       MR. ELLIOT:  I would have to ask someone
                       MR. HALE:  Yes, we have a low leakage
                       DR. SHACK:  And that is actually taken
           into account when you calculate your 297.4?
                       MS. THOMPSON:  I don't believe we have for
           all the future years.  We have been operating with a
           low leaking core for a number of years, but I think
           that calculation has some conservatism in it, but we
           do have a low leakage core installed.
                       But I don't believe we have credited it in
           the calculations.
                       DR. ROSEN:  You see, that is the problem
           with this, I think, and that is that you have got 48
           effective full-power years on a 68 year license, and
           that is 80 percent capacity factor.
                       But plants are running in the 90 percent
           capacity factors, and so if you run 90 percent, you
           are going -- well, will you end up with higher than
                       MR. ELLIOT:  The critical issue here is
           not the effective full power.  It is the fluence.  If
           you look on our SER --
                       DR. ROSEN:  Well, more fluence comes from
           more operation.
                       MR. ELLIOT:  Yes, and so that is what they
           have to reach.  They have to keep within that target
           fluence.  They  have a target fluence and at the end
           of 60 years, they have to stay below 4.5 times 10 to
           the 19th.  I think that is the number in the SER.
                       DR. ROSEN:  Yes.  But the point is that
           they are going to get the 48 effective full-power
           years long before they get the 60 years total at 90
           percent capacity factors, which typically everybody is
                       MR. ELLIOT:  But as long as their fluence
           stays -- the accumulated neutron fluence stays below
           4.5, it doesn't matter whether it is 48, or 49, or 50
           effective full power years.
                       It is the neutron fluence which is the
           issue, and as long as they keep track of that neutron
           fluence, and they measure what they are getting,
           versus what they planned on getting, to get the 4.5,
           then they will be fine.
                       MS. THOMPSON:  We have completed almost 30
           years of operation on the two units, and unfortunately
           in the earlier years at the Turkey Point operation, we
           did not have that higher capacity factor.
                       So we actually didn't pick up that much in
           the way of BFPY.  Nowadays, we do operate above 90
           percent, and I don't recall the exact assumption that
           was made for the remaining life of the unit, but it
           was well into the 90 percents to come up with a
           projection of 48 being the bounding for end of life.
                       DR. ROSEN:  So for your first 30 years,
           you add 70 percent capacity factor, and that would be
           21 EFPY; and for the next 30 years, you have 90
           percent, and that would be 27 more.  So that is your
           48; 21 and 27.
                       MS. THOMPSON:  And that is pretty close to
           where we were.  We just switch from 19 EFPY to
           P-T curves in our technical specifications.
                       DR. ROSEN:  So it is going to be a close-
           run thing down at the end is what I am saying.
                       MS. THOMPSON:  And these curves actually
           go in our technical specifications, and basically they
           stay in compliance with our technical specifications,
           and we have to stay within that 48 EFPY.
                       DR. ROSEN:  All right.  So I have voiced
           my concerns about how close it is going to be before
           you get to the end of the 60 years in terms of
                       CHAIRMAN BONACA:  Well, I don't think
           typically that for this calculation that low leakage
           is being considered in it.  With low leakage, the
           radiation is so low.
                       MR. HALE:  You have to realize there is
           some margin in the fluence number, too.
                       DR. ROSEN:  Well, I would like to get to
           the margin question.  That is where I am really
           heading.  When you talk about 297.4 versus a 300
           degree screening criteria, where are the uncertainties
           in this calculation?  Is it 3 percent?
                       MR. ELLIOT:  We threw in a margin of 56
           degrees.  That is part of the calculation.
                       MS. THOMPSON:  That is a lot.
                       MR. ELLIOT:  That is taking into account
           uncertainties in chemistry, fluence, and the
           calculation procedure.  We threw that in.  That is
           part of the procedure.  There is an uncertainty in the
                       DR. SHACK:  They build the margin or they
           build the uncertainty into their acceptance rather
           than calculate it out separately.
                       MR. ELLIOT:  Right.  It is all calculated
           as part of the calculation, exactly.  Okay.  Charpy
           upper shelf energy.  10 CFR, Append G, has
           requirements for Charpy upper shelf energy, and it
           must stay above 50 foot pounds, and if you go below 50
           foot pounds, you have to supplement the analysis.
                       Well, Turkey Point is one of the plants
           that went below 50 foot pounds.  They went below 50
           foot pounds a long time ago.  In the first 40 year
           license, they provided an analysis, and basically all
           they have done in the 60 year license is updated the
           analysis to 60 years.  And that is basically what they
           have done here.
                       Pressure temperature limits are done
           according to Reg Guide 1.99 Rev. 2.  Again, it is a
           transition temperature shift that we are concerned
           about in the pressure temperature limits.  They have
           submitted curves for approval for 32 effective full
           power years, and we have reviewed those curves and
           they are fine.
                       They gave us another set of curves for 48,
           and they did not submit them for approval, but it is
           just a matter of calculating it so they can actually
           do that.
                       And one of the issues here of interest is
           that they didn't use the chemistry factor ratio
           adjustment.  If you have surveillance data, the
           procedure describes how you are supposed to use the
           surveillance data.
                       They didn't do it, and so we are just
           telling them here that you should do it.  Now, it
           turns out that what they did was conservative for the
           data that they have now.
                       They are going to be withdrawing I don't
           know when, but they are going to be withdrawing
           another capsule.  They could get another data point. 
           This is one of the plants that actually has the right
           material in the capsules.
                       So they can actual measure the amount of
           embrittlement for their vessels, and when they pull
           that capsule, we are just telling them that when you
           do it that you need to use the ratio adjustment
                       Now, it turns out as I said that this is
           a benefit for them in this case so far, and based upon
           the data, they could have had even a lower value than
           297.4, or they could have had even a less conservative
           if they had followed or had used their ratio
                       They are not supposed to use a ratio
           adjustment unless the data is credible.  We have
           criteria.  So they followed the reg guide and the data
           was not credible, and so they did what they were
           supposed to do.
                       But it is potential that when you get new
           surveillance data that it could change.  The data
           could become what we call credible according to the
           criteria, and then they would have to use the --
           instead of using the chemistry factor they used, they
           would have to use a different chemistry factor. 
           That's the point there.
                       The second point of interest is that
           normally we think of the belt liners between the
           intermediate shell and the lower shell, those are the
           shell courses.
                       But what happened is that with the longer
           life, all of a sudden we have a new shell course that
           is starting to get a large amount of radiation, and
           right now it is not limiting, but you still have to
           monitor it.
                       And that is this circumferential weld
           between the nozzle belt line and the intermediate
                       CHAIRMAN BONACA:  So it is not limiting
                       MR. ELLIOT:  It is not limiting now, but
           fluences change.  They change some geometries or
           whatever, core geometries, and if they do that, and
           they have to do a reevaluation, then they should also
           look at this other weld.
                       And we have looked at it based upon what
           they have told us, and it is not limiting.  According
           to the PTS rule, if you change core geometry
           significantly, you have to do a reevaluation.  If they
           have to do a reevaluation, we would like them to look
           at this other weld also.
                       DR. ROSEN:  I was puzzled by the
           statements in the application on page 4.2-5 on
           pressure temperature limits.  It is in Section 4.2.3.,
           and it is about the need for a separate license
           amendment which specifically requests approval of the
           48 EFPY prior to expiration of the proposed 32 EFPY.
                       MR. ELLIOT:  Do you want me to explain
                       DR. ROSEN:  Yes.
                       MR. ELLIOT:  Okay.  We give out -- what
           happened is that it is a tech spec.  Pressure
           temperature limits are in the technical
           specifications.  We only approve the curves for 32
           effective full power years.
                       So they can only operate this plant with
           those tech specs until 32 effective full power years. 
           If they want to operate this plant beyond 32 effective
           full power years, they have to put a new tech spec in
           that is applicable for a greater period of time.
                       And they are going to have to put in a new
           set of pressure temperature load for that greater
           period of time.  They have not asked us for that, and
           we have to approve their tech specs.  That is where
           the amendment comes in.  We have to approve the tech
           spec amendment.
                       DR. ROSEN:  Prior to 32 EFPY.
                       MR. ELLIOT:  Right, because the 32 will
           run out.
                       MR. ELLIOT:  And you are out about 21 or
           so now?
                       MS. THOMPSON:  Yes, in that vicinity.
                       DR. ROSEN:  So you have time.
                       MS. THOMPSON:  We have plenty of time.
                       DR. ROSEN:  You have plenty of time, 10 or
           12 years.  But this license renewal extension, or
           whatever you want to call it, although it could be
           granted, will in fact not give you that full term
           until you get this changed, too.
                       MS. THOMPSON:  That's correct.
                       DR. ROSEN:  Why don't you get it changed
                       MS. THOMPSON:  It was a conscientious
           decision that we made for some of the reasons that
           Barry has illustrated.  Those P-T curves that were
           submitted that go to 32 EFPY actually are based on
           calculations that consider the fluence associated with
           48 EFPY.
                       We elected to make them applicable for the
           current term only because we needed that tech spec
           amendment approved prior to this renewal application
           in order to continue operating.
                       Our past curves were only go through 19
           EFPY, and we just thought that proceeding down that
           path would be a more efficient process for us to do at
           the time, and that we would take it as a second step
           to move through to get the 48 EFPY.
                       DR. ROSEN:  Let me see if I understand
           what you just said.  You have got a tech spec change
           already approved to take you beyond 19.
                       MS. THOMPSON:  Right, which we needed to
           continue operation even today.
                       DR. ROSEN:  So you have that, and now you
           are in for a license renewal out to 60 years total
           time, 48 EFPY.  But you are not asking for this change
           at the same time, and I still don't understand why.
                       MS. THOMPSON:  Not at this time, but
           between now and 32 EFPY, we have the opportunity for
           removal of additional specimens for analysis of that. 
           We can potentially improve those curves and give the
           operators more margin.
                       If not, we have performed the analysis,
           and we know what the answer is based on this data, and
           it is the same as we are operating to right now.  So
           we know that we are in an acceptable position, but we
           may be able to put ourselves in a better position. 
           And so we decided to take it on an incremental basis.
                       MR. HALE:  I think it is important to note
           that even new plants when they are licensed, in some
           cases were licensed with 5 year curves, or 10 year
           curves, and the reason is that as you move out in
           time, the more restrictive the curves become from an
           operational standpoint.
                       So sometimes you choose, well, we are
           licensed for 5 years, and before we reach the
           expiration of that, we will submit a license amendment
           for 10 years, and it starts narrowing down.
                       And you can impose, because you have got
           also your concerns over maintaining subcooling margin
           below, and also MPSH on the reactor coolant pumps.
                       So even new plants when they are licensed
           aren't necessarily licensed for 40 years for their P-T
                       DR. ROSEN:  So you are keeping the highway
           as wide as you can and for as long as you can by doing
                       MR. ELLIOT:  Right.  And then it was a
           timing issue like Liz said.  After we had submitted
           the license renewal application, we needed to change
           the P-T curves because we were reaching our EFPY limit
           on those P-T curves.
                       So rather than tieing up our approval of
           those to the 48 EFPY, we decided to go in with a 32
           EFPY with a license amendment that was in process and
           parallel with the license renewal application.
                       DR. ROSEN:  Okay.  Thanks a lot.
                       MR. ELLIOT:  Okay.  The next issue is
           metal fatigue, and that normally is John Fair, and
           Mark Hartsmen issue, but I have an open issue here. 
           And the open issue is WCAP-15338.
                       DR. SHACK:  You get all the vessel stuff
                       MR. ELLIOT:  Right.  So this is the vessel
           stuff, and in 1970 the industry discovered that for
           course grain forgivings, that if you had a height and
           heat input submerged on CLD that you could under beat
           cracks under the CLD.
                       The cracks generally are very, very small. 
           They are on the order of a 10th of an inch, and really
           cannot be detected by ultrasonic inspection.  The way
           this was discovered was from nozzle dropouts, and they
           could actually visually see the cracks.
                       This was an issue in the '70s and it is a
           fatigue issue, in the sense that you have existing
           cracks and over a certain amount of time they are
           fatigued and grow.
                       And the question is do they grow to a
           large enough size that the integrity of the vessel is
           in question.  So the industry in the early '70s did an
           analysis for 32 effective full power years.
                       And now we have license renewal, and so
           the industry has to come up with another analysis that
           has 60 years.  It is still a fatigue issue, and we
           went through this one time before with Oconee, and I
           don't know if you remember that, but I think it is
           Unit 1 that has forgings.
                       And that was a B&W analysis, and this is
           the Westinghouse analysis that we are reviewing now. 
           We have not finished the analysis.  The analysis
           originally was submitted, and they used an air
           environment for fatigue crack growth.
                       We didn't like that.  We wanted them to
           use the water environment, which is a little more
           conservative.  And we also wanted them to look at what
           PTS events could impact Turkey Point, and they did
                       They did everything that we have asked,
           and they resubmitted it, and we are reviewing it.  It
           has gone through a lot of review, and I think as you
           said, Raj, you expect it to be done by --
                       MR. AULUCK:  The middle of next month.
                       MR. ELLIOT:  -- the middle of next month,
           and that's where we stand.  That takes care of
           everything that I have to say, and now it is Paul's
                       MR. AULUCK:  The last slide is
           environmental qualification.
                       MR. SHEMANSKI:  I'm Paul Shemanski,
           environmental qualification on electrical equipment. 
           There are no open items; however, we have two items of
                       The first one deals with the
           classification of how the EQ TLAA was done by the
           applicant.  When they evaluated EQ as a TLAA, they
           used 10 CFR 5421(c)(1)(i), and that basically means
           that the analyses remain valid for the period of
           extended operation.
                       Now, we disagreed with that classification
           because the staff believes that the reanalysis that
           were done, the way that we interpret that is that the
           analyses have been projected to the end of the period
           of extended operation.
                       Basically what they did was they extended
           the qualified life of these electrical components from
           40 to 60 years.  They did a thermal analysis and
           radiation analysis,and we believe that if you look at
           the rule that that constitutes Paragraph
                       It turns out that it is not a big deal
           because it has nothing to do technically with the
           results that they obtained.  It is just a difference
           of what they classify and what the staff classified as
           the evaluation that was done for the EQ TLAA.
                       So again there was no effect on the
           technical adequacy of their evaluations.  Just that
           they decided to classify these as (i), and we believe
           they should have been classified as (ii).  So, no big
                       The second item of interest deals with the
           wear cycle aging effect on various motors, and in
           particular Westinghouse and Joy.  These are
           containment cooler and filtration motors, and
           containment spray pump motors.
                       When we looked at the EQ evaluation that
           the applicant did, we noted that they did not
           adequately address the wear cycle aging effect.  That
           is the start/stop cycles.
                       These are large motors, and when you turn
           them on there are significant electrical stresses on
           the windings, and mechanical stresses on various
           portions of the motor, like the bearing and shaft.
                       Anyway, we had a discussion with the
           applicant, and they went back and determined that over
           the 60 year plant life that they would not exceed
           1,000 start/stop cycles.
                       And they did some further research and
           found that a EPRI power plant electrical document that
           claims that motors of this type are good for 35,000 to
           50,000 start/stop cycles.
                       So the fact that they only anticipate only
           1,000 cycles for 60 years, it looks like they  have a
           tremendous amount of margin in there.  So we accepted
           the evaluation and the bottom line is that they are
           going to go into their EQ file for their particular
                       And they put the EPRI reference document
           in there so when people look at it in the future they
           will have assurance that the wear cycle aging effect
           is minimal.  That's it.
                       CHAIRMAN BONACA:  Now, on GSI 168, they
           are committed -- what is the commitment that they
                       MR. SHEMANSKI:  Basically to follow the
           resolution of GSI 168 and the staff in both NRR and
           the Office of Research, are working on the options for
           resolution on GSI 168, and so they basically in
           essence committed whatever out of GSI 168, and they
           would comply with it.
                       CHAIRMAN BONACA:  Any other questions? 
           Okay.  Thank you.  So, I think we have completed this
           portion of the application.
                       MR. AULUCK:  Is there any action item for
           the staff to follow up?
                       CHAIRMAN BONACA:  Well, I heard that
           insofar as the application is concerned -- and the
           application is quite specific.  I mean, it has
           ultrasonic in addition to the VT1 in that location,
           and that is adequate enough.
                       Are there any other issues that you feel
           should be action items for the staff?
                       DR. DUDLEY:  I think at the end of the
           meeting we will need to describe and discuss what you
           would like to hear at the full committee meeting.
                       CHAIRMAN BONACA:  I would like to do that
           after we hear about the Westinghouse Topical Reports. 
           All right.  With that then, why don't we move into the
           presentation of the Westinghouse supporting documents.
                       I had a question generally.  For the B&W
           plants, we have the B&W topical report also about
                       MR. ELLIOT:  Yes.
                       CHAIRMAN BONACA:  For the Westinghouse
           plants, we do not have that.
                       MR. ELLIOT:  No.  Well, we will let
           Westinghouse speak for themselves here, but let me
           just explain to you.  The Westinghouse plants, they
           didn't build any of the vessels.  They are built by
           Babcock and Wilcox, and Combustion Engineering.
                       CHAIRMAN BONACA:  Okay.  That's what I
           thought actually, but I wasn't sure.  It was more
           curiosity than anything else.
                       MR. HALE:  I think one other point, too,
           is that you have got a much wider variety of plants in
           reactor vessel designs, two loops, three loops, four
           loops, and different power levels.
                       And we in the WOG had a difficult time
           coming up with a generic report on a reactor vessel. 
           It was pretty high  level and so it had to get a
           little more specific.
                       CHAIRMAN BONACA:  All right.  We do have
           handouts for those right, for the vessels?  Yes.
                       MR. ELLIOT:  The Westinghouse Owners Group
           life cycle management license renewal program
           submitted four topical reports for NRC review.  They
           were Class I piping and associated pressure boundary
           components; reactor vessel internals, pressuring the
           reactor coolant systems.
                       The Westinghouse Owners Group people are
           here.  I know that one of them, Charlie Mayer, is
           here; also from the staff here is John Fair, Frank
           Rubelick, Mark Hartsmen, Arnold Lee, Hibo Wang, and
           Mohammed Razuk.
                       I just wanted to explain to you how I laid
           this out so you know where I am going.  I divided it
           into three little sections; what was in the
           application, and which is the first part, and I will
           go through what is in each WCAP.
                       And then I have a page or a page-and-a-
           half of our staff evaluation, and then a final
           conclusion.  So we will start with what is in the
                       And in every case I identified what are
           the materials that we are talking about here, and then
           what are the aging effects that were identified as
           being applicable for these materials and these
                       And then what are the aging management
           programs for those materials, and again effects, and
           then if there are any TLAAs, and that's how --
                       CHAIRMAN BONACA:  Actually, they really
           followed the license renewal formal literally for each
           critical component.
                       MR. ELLIOT:  Yes, they did.  Well, let me
           preference this.  They did a pretty good job
           considering where they were.  They were in the dark. 
           I mean, a lot of the other B&W stuff were developed as
           they were the doing the Oconee application.  So they
           had the advantage of hearing a lot of the issues as we
           were developing them.
                       In the case of the WOG, a lot of these
           topical reports were developed before we even had
           applications.  So they were going in the dark, and
           they were trying to figure out what the issues were. 
                       So what you are going to hear is that we
           had a lot of open issues and a lot of action items,
           but that's because of the way that they were operating
           in the dark here without any previous application to
           go by.
                       And then when I go through the applicant
           action items, the ones are -- you are going to hear a
           lot of the same ones.  We discussed Oconee, and Hatch,
           and it is the same set of issues.
                       CHAIRMAN BONACA:  I would like to ask that
           as far as you know is there any plan on the part of
           the WOG to go back to those four topicals and
           disposition some of these issues given now that they
           have experience on the applications themselves?
                       MR. ELLIOT:  Well, all the items were
           answered by the applicant.
                       CHAIRMAN BONACA:  I understand.
                       MR. ELLIOT:  So they have included in
           their application, somewhere in their application,
           they have addressed all these issues.  Like the small
           bore piping, and the reactor vessel internals program,
           and the fatigue issues.
                       Those are all applicant action items that
           we addressed that were highlighted during the previous
           applications, and they are being carried out here in
           their applicant action items for the topical reports.
                       CHAIRMAN BONACA:  Well, what I meant to
           say is that given what they know now, it could be more
           dispositioning writing the topical reports, rather
           than left to the applicants, and that could be
           convenient to the future applicants.
                       MR. ELLIOT:  Can I just answer that?
                       CHAIRMAN BONACA:  Yes.
                       MR. ELLIOT:  I hope that we are going to
           have GALL.  I hope they are going to implement GALL,
           and if they implement GALL correctly, and they just
           say they meet GALL, and where they don't meet GALL.
                       CHAIRMAN BONACA:  I understand.
                       MR. ELLIOT:  And my preference would be
           that the --
                       MS. THOMPSON:  I think the answer is that
           the WOG does not plan on going back and revising those
           and to address those, and there is a couple of reasons
           for that.
                       One is that as Steve had mentioned earlier
           that there is quite a broad spread of design
           information that is applicable to various different
           components in the Westinghouse class, versus some of
           the other NSSS suppliers.
                       The second reason is that looking at the
           industry and the staff's resources, we are focused
           largely on individual applications now, and if we were
           to put something else on the table for the staff
           review, we realize that would also take away from
           their ability to deal with the applications on their
                       So I think it is a balancing act there,
           and I believe that each applicant will probably be
           able to address these open items.
                       MR. HALE:  Now, we are also -- the WOG is
           taking our response and preparing information for all
           the Westinghouse plants, and they will have that
           available as a source of information that here is the
           way that Turkey Point addressed this issue, and they
           will have that information available.
                       CHAIRMAN BONACA:  Okay.
                       MR. ELLIOT:  All right.  The slide is
           self-explanatory.  The piping and fittings, and value
           bodies, and bonnets and casings are all stainless
           steel, and the reactor coolant bolting are alloy
           steel; and the valve bolting are carbon steel, alloy
           steel, and stainless steel.
                       The aging effects identified are fatigue
           related cracking, corrosion of external surfaces
           caused by leakage of borated water; and reduction of
           fracture toughness due to thermal aging of cast
           stainless steel.
                       And loss of material caused by wear of the
           reactor coolant pumps and values bolted closure
           elements; loss of bolting preload caused by stress
           relaxation of bolted closures.  That is what is
           identified as the aging effects.
                       Now, to manage those aging effects, the
           WCAP takes credit for in-service inspection and test
           requirements of ASME Code, Section XI, and ASME/ANSI
           operation and maintenance standards to manage the
           aging effect of wear.
                       And in-service inspection requirements of
           Section XI to manage stress relaxation.  The
           commitments of applicants and licensees to NRC Generic
           Letter 88-05, to manage corrosion caused by borated
           water leakage.
                       And they also would like to have taken
           credit for analysis methods and inspection
           requirements to manage fatigue related cracking.
                       And to identify analysis methods and
           inspection requirements to manage the reduction in
           fracture toughness due to thermal aging.  The WCAP-
           14575 identifies TLAAs as fatigue and leak-before-
           break evaluations.  That is the piping WCAP.
                       The next WCAP is reactor vessel internals,
           and the reactor vessel internals are stainless steel
           and nickel based alloys.  The aging effects are
           identified as reduction of fracture toughness due to
           neutron irradiation of high neutron fluence
                       And irradiation-assisted stress corrosion
           cracking of high neutron fluence components; and the
           irradiation creep of baffle/former and barrel/former
                       A combination of stress relaxation and
           high-cycle fatigue for preloaded components; and wear
           of components that experience axial sliding and
           components that constitute the interface between
           structural components; and void swelling of high
           neutron fluence components.
                       The WCAP for these aging effects, the
           programs are four; for fracture toughness and
           radiation stress corrosion, cracking, and void
                       They take credit for the in-service
           inspection of the ASME code, and the results from the
           PWR materials reliability project.  That is a program
           that is going on now, and that is to develop
           inspection criteria, and inspection methods, for these
           aging effects.
                       And I think they also take credit for the
           in-service inspection requirements of ASME Code,
           Section XI, of accessible surfaces of PWR core support
           structures, excluding the baffle/former, and
           barrel/former bolts, to manage stress relaxation, and
           wear of keys, inserts, and pins, or they want to take
           credit for noise monitorings as a way for doing the
                       Ultrasonic and eddy current examination is
           proposed per responses to I&ED Bulletin 88-09 to
           manage the wear of the bottom mount instrument tube
           flux thimbles.
                       And augmented ultrasonic examination is
           recommended for baffle/former and barrel/former bolts
           to manage the aging effects of these components.
                       And they would like to take credit for in-
           service inspection requirements of ASME Code, Section
           XI, as a fatigue management program.  And then for the
           internals, the only --
                       DR. ROSEN:  Slow down.
                       DR. FORD:  I have a question.  What you
           are doing is just recording what is in these various
                       MR. ELLIOT:  Yes.  Later on I am going to
           tell you what we agree on and what we don't.  I
           haven't told you that yet.
                       DR. FORD:  Oh, okay.  Fine.
                       MR. ELLIOT:  WCAP-14575 identifies fatigue
           as a TLAA.  And the next WCAP is the pressurizer, and
           there is a whole list of a lot of different materials
           and components in the pressurizer.
                       These are pretty interesting components. 
           It has got case and stainless steel, and in case they
           have alloy steel bolts and alloy steel forgings; and
           they also have Inconel 182/82, as well as stainless
           steel in some components.
                       DR. SHACK:  Is that a vintage thing, that
           the early ones were done with stainless steel butters,
           and then somebody decided to put some improvements in?
                       MR. ELLIOT:  I don't know that much about
           the design of Westinghouse.  I know that some have --
           in the case of Turkey Point, they have stainless steel
           instead of the 82/182.
                       And there are some that have the 82/182. 
           It is a vintage question and I asked Westinghouse
           that, and the answer was vintages, if they have an
                       DR. SHACK:  And Framatome has always stuck
           to stainless steel.
                       MR. ELLIOT:  Right.  But in the
           pressurizer report, they have a list of which ones
           have --
                       DR. SHACK:  Oh, they do?
                       MR. ELLIOT:  Yes.  I saw that in the WCAP
           when I read it.  So in the WCAP, it has a list of
           which ones have 82 and which have stainless steel.
                       And these are the materials.  The aging
           effects offer fatigue related cracking, and primary
           water stress corrosion cracking of Inconel 82/182 weld
           metal and sensitized stainless steel safe ends.
                       The WCAP takes to managing these aging
           effects is the in-service inspection requirements to
           ASME Code, Section XI, and a fatigue management
           program to manage fatigue.
                       And then the in-service inspection
           requirements of Section 11 to manage primary water
           stress corrosion cracking of Inconel 82/182 weld
           material, and sensitized stainless steel safe ends. 
           And then the TLAA -- the only TLAA is fatigue.
                       The last WCAP is the WCAP on reactor
           coolant system supports, and we are talking about
           steel components and concrete embedments
                       .  The aging effects for these components
           are loss of material and decrease of strength of steel
           components resulting from aggressive chemical attach
           and corrosion.
                       The loss of material and decrease of
           strength of concrete embedments resulting from
           aggressive chemical attach and corrosion.  And then
           stress corrosion cracking of bolting.
                       The aging program to manage these aging
           effects are in-service inspection requirements of ASME
           Code, Section XI, and leakage identification walkdowns
           to manage aggressive chemical attach and corrosion for
           steel components.
                       And then in-service inspection to American
           Concrete Institute 349 Code, and leakage
           identification walkdowns to manage aggressive chemical
           attach and corrosion for concrete embedments.
                       In-service inspection requirements of ASME
           Code, Section XI, to manage stress corrosion cracking
           of bolting.
                       And the WCAP indicates that there were
           plant specific action items; that the applicant must
           identify program necessary to ensure proper preload is
           maintained; and the applicant must address the effects
           of irradiation on concrete components; and the
           applicant must address inaccessible areas.
                       The only TLAA here was WCAP-14422, which
           identified fatigue.  That is what was in the summary
           of what was in the application.  I am not going to go
           through with the entire staff evaluation, but just the
           areas that I think are important.
                       The first one is the WCAP on Class I
           piping and associated pressure boundary piping.  We
           set out applicant action items.  We wanted the
           applicant to evaluate the impact of halogens in
           insulation on stress corrosion cracking of stainless
           steel piping.
                       That is one of the things that was missing
           and that we thought was not enough description of how
           it was going to be done.  So that is a plant specific
           license application item.
                       We have guidance in that area, Reg Guide
           1.36, for non-metallic thermal insulation for
           stainless steel components.  We also wanted them to
           perform a volumetric inspection of small bore piping
           that is susceptible to stress corrosion cracking or
           unanticipated thermal fatigue resulting from thermal
           stratification or turbulent penetration.
                       In the past, we have accepted both a
           deterministic evaluation or a risk-informed evaluation
           to identify the locations for the small bore
           volumetric inspection.  In the case of Turkey Point,
           they did a risk-informed evaluation.
                       And the area we think it was needed was to
           evaluate the susceptibility of cast stainless steel
           piping to thermal embrittlement.  Since the issue of
           this particular WCAP, EPRI has put out a report which
           highlights the criteria, and this criteria is based
           upon Oregon test data, and the staff has reviewed the
           EPRI document, and it is EPRI TR106092.
                       And in a letter dated May 19th of 2000
           from Chris Grimes to EPRI, we have established
           criteria now for evaluating all cast stainless steel
           to thermal embrittlement.
                       And we want all the applicants to evaluate
           their material using that criteria.  Now, remember
           that I talked about the TLAAs.  We want them to
           perform a plant specific fatigue evaluation.  
                       We didn't accept the total methodology
           that was in the WCAP.  So this is a plant specific
           action item.  And then we wanted them to do a plant
           specific leak-before-break analysis assessment to
           assessment margins.
                       The criteria for this leak-before-break
           analysis is contained in NUREG 10-61, and the TLAA
           issue here is thermal embrittlement of cast stainless
                       DR. FORD:  Okay.  Barry, on the subsequent
           ones, you have picked out some significant issues.
                       MR. ELLIOT:  Right.
                       DR. FORD:  What was the quantitative basis
           for saying that those are significant?
                       MR. ELLIOT:  It is the ones that I like to
           talk about.
                       CHAIRMAN BONACA:  But why did you choose
                       MR. ELLIOT:  Because there are some issues
           in here that -- well, there are 10.  I mean, I could
           read all 10 of them, and you could read all 10 of
           them, and I looked at all 10 of them and I said these
           are the most significant ones to me.
                       Now, there are some that are most
           significant.  They are all significant or else they
           wouldn't be in there.  There are three that I consider
           administrative, in the sense that you bound the
           report, and do you have an FSAR, and there are a whole
           bunch of those.
                       And then there is a couple that I thought
           were less significant and so I didn't put them in
           here.  And you can go through the list just like I
           can, and if you think there is one in here that you
           want me to talk about, go right ahead.
                       DR. FORD:  I recognize about the
           procedural ones, but I have to put myself in the
           position of being one of the utilities, whoever it
           might be.  And they have all these address this, that,
           and what have you.
                       MR. ELLIOT:  They have to address them
                       DR. FORD:  Well, they have restricted time
           and manpower and how do they allocate that in terms of
                       MR. ELLIOT:  They have to do all 10.  They
           have to do every single one.  They have to answer
           every single one.  I am only doing 10 because I am
           standing in front of you now here and I think these
           are technical issues that I think that are pretty
           important that I want to highlight for you.  That's
                       I just want to highlight the important
           technical issues for this committee, and I could go
           read them all, but that would not be highlighting
           them.  I want to highlight the important ones.  I
           think these are very important.
                       DR. FORD:  And did you have a good reason
           for highlighting them?
                       MR. ELLIOT:  Yes.
                       CHAIRMAN BONACA:  Are you telling the
           licensee that the others are not important?
                       MR. ELLIOT:  No, they are all important
           and every one is significant, but these are the
           highlighted ones.
                       DR. FORD:  I hate to be pushing on this,
           but it is one of the things that I am getting
           frustrated about.  I have yet to see any numbers in
           any of these things, and I have yet to see a number or
           a data point.
                       I haven't seen one data point in the five
           months that I have been on this committee, and it is
           frustrating.  And I have no idea what the margin of
           safety is, how much you can push that margin of safety

           based on fact.  I haven't seen it.
           And that's why I asked you why do you think
           quantitatively why these are important.
                       MR. ELLIOT:  Because I don't want to see
           halogens on the stainless steel components.
                       DR. FORD:  Sure.
                       MR. ELLIOT:  And I think that is an
           important thing that the applicant should take care
           of.  I think that small bore piping -- I can't depend
           upon a leak-before-break there.  So I have got to have
           something and I want to have some kind of inspection.
                       And the cast stainless steel, we have a
           lot of data there, and we want to make sure that data
           gets implemented as part of the aging management
                       DR. FORD:  Let me ask another question. 
           When the staff reviews these LRAs do they in fact see
                       MR. ELLIOT:  We see programs.  We only see
           data if we ask for the data.  We see programs, and we
           see aging effects, and they have to meet the rule.
                       The licensee has three parts to meet in
           the rule.  They have to have a scoping to show that
           all of the components are within scope.  That the
           plants are in scope, and they have to define the aging
           effects, and they don't have to have quantities there.
                       They just have to postulate aging effects
           based upon their experience on what aging effects are.
                       DR. FORD:  I come from a different world,
           but I fail to see how any regulatory body can make any
           definitive statement unless you see data.
                       DR. SHACK:  But he does.  I mean, as he
           said, the EPRI report is what he does the cast
           stainless steel on.  And they have reviewed the EPRI
           report and accepted it, and it has got the data.
                       But they are saying is that the Turkey
           Point people have to commit to using the data analysis
           method to do it.  They don't have to see the data over
           and over again.
                       MR. ELLIOT:  We have data for thermal and
           brittle cast stainless steel.  We know where it
           saturates, and we set up criteria so that we know what
           is susceptible and what is not susceptible.
                       We simplify it.  We don't go and say go
           tell us what is susceptible.  We say use this criteria
           here and tell us what is susceptible.
                       DR. SHACK:  I suppose they could come back
           in and argue with me.
                       MR. ELLIOT:  They certainly could.
                       CHAIRMAN BONACA:  I really think a couple
           of things.  One is clearly license renewal documents
           at the end is nothing else but a series of management
           commitments in the areas where a need for managing
           aging effects have been identified.
                       Now, those commitments are then translated
           into very specifics for reports about what kind of
           techniques, what kind of locations, what kind of
           issues, and so on and so forth.
                       So you can go down to the specifics in
           each one of them, and it doesn't happen at this level
           because those commitments are already in existing
           topical reports, and in core licensing basis, and so
           on and so forth.
                       However, I would say -- and we discussed
           this briefly with some of you during the break -- it
           is frustrating to a reviewer maybe when one looks at
           an application or a self-evaluation report on a
           license renewal.
                       And I thought that probably it would be
           worthwhile to have in SERs like a 3 or 4 page
           description of this logic of what really the intent of
           the license renewal work is.  It is the establishment
           of commitments, and how that merges together with the
           current CLB and commitments that exist.
                       Because I think that would provide some
           explanation, and it could be almost like three pages,
           a boiler plate description, that is used in front of
           every SER so that the reader comes in and has an
           understanding that the world doesn't start and end
                       I think that there has to be some
           explanation somewhere, because if you pick up the SER,
           and you read it through, you don't get that kind of
           feeling, and I know that we have gone with questions,
           each one of us, to Mr. Grimes on how do you do this,
           and he has explained it to us many times.  So we are
           slowly learning and appeasing our frustration I guess
           that way.
                       But I think just the communication issue
           of what the license renewal application is supposed to
           do in addition to the core relicensing commitments.
                       DR. ROSEN:  Let's talk about frustration
           again.  This is one of the things that you talked
           about and this was brought up on the circumferential
           weld, the 297 degrees.
                       And the answer was we got 56 degrees of
           uncertainly or margin, and so to think about 56
           degrees and added to 241, and you get your 297.  That
           sounds like a lot, but you really have to do an
           absolute temperature before you realize if you are
           going to do any kind of assessment like that.
                       So when you do it in absolute temperature
           terms, it is really not that much.  It is about 8
                       MR. ELLIOT:  Well, the 56 is an
           engineering number.
                       DR. ROSEN:  Well, that is my frustration. 
           I have no clue how you got the 106 degrees as being
           adequate as an uncertainty in this case.
                       MR. ELLIOT:  We use the least squares
           method of evaluation.  We have two values that go into
           it that, and we have the uncertainty in the initial RT
           NDT, which is what you start from, and then we have an
           uncertainty in the shift in reference temperature.
                       WE combine those two using the least
           squares method, and we come up with a margin term. 
           That is how we develop it.  If you read the preamble
           to our safety evaluation, it describes all of that. 
           We describe that in the safety evaluation in that
                       DR. ROSEN:  But I don't see the data.
                       MR. ELLIOT:  Excuse me, hold it.  The data
           was the data that we used to develop Reg Guide 1.99
           Rev. 2.  It is all the surveillance data that we have
           accumulated to make that Reg Guide.
                       There is hundreds of data points.  That
           was originally reviewed I'm sure by the ACRS at one
           time or another, and endorsed that Reg Guide, and that
           margin term comes from that Reg Guide.  So that is not
           a license renewal issue.  That was an issue of the Reg
                       DR. ROSEN:  I have not seen the data.  You
           see, I'm not bound by what the ACRS did in the past.
                       MR. ELLIOT:  Well, if you already looked
           at it, it is a Reg Guide, Reg Guide 1.99 Rev. 2, and
           there is an analysis the staff did based on the data
           to find out how in margin term what was to be
                       DR. ROSEN:  I can't conclude sitting here
           without having done all of that, that because it is so
           close to the screening criteria, that that amount of
           margin that you built in is in fact soundly based.
                       What if I were to take it myself and do
           the analysis over, and I got 65 degrees of margin
           instead of 56.  Then they would be over the screening
           criteria.  Then what would have happened?  Tell me
           what the next step would be.
                       MR. ELLIOT:  If they were over the
           screening criteria, the rules say what you have to do. 
           But in all likelihood they would not be sitting here
                       DR. ROSEN:  What is that that they would
           have to do if they were over the screening criteria?
                       MR. ELLIOT:  The Reg Guide says you have
           to have a supplementary analysis to be done to show
           that PTS is not a concern.  There is a supplementary,
           and you have to look at your plant specific PTS
           events, and how you could mitigate those PTS events.
                       And you have to do a whole basic
           probablistic fraction mechanics evaluation to show us
           that you could meet the criteria.  We have another
           criteria, another Reg Guide, where we have established
           a criteria that we would have to meet with this other
           if they go over the screening criteria, and you could
           argue with that.
                       But that was reviewed by the Commission,
           and we put it on SECE 82-465, and if they meet that
           criteria for a PTS event, failure frequency, we would
           accept that.
                       DR. ROSEN:  We have not done that many of
           these little license renewals yet, Mario, but can you
           help me understand how close the other people, the
           other licensees, have been to the screening criteria
           for the circumferential weld?  Is this the closest one
           we have seen?
                       CHAIRMAN BONACA:  No, they are pretty
                       MR. ELLIOT:  I will answer that.  Most of
           them are not close.  Oconee was very close.  One of
           the Oconee units --
                       DR. ROSEN:  Most of them are not close?
                       MR. ELLIOT:  Yes, most of them have not
           been close.  Oconee was very close.  One of the Oconee
           units was like 2 or 3 degrees.  It was like this.  It
           was very close.  It was not a circumferential.  It was
           an axial.
                       DR. ROSEN:  You have to remember that the
           300 degrees was set up by sort of a bounding analysis
           for the PTS events.  So it has the conservatism built
           in.  I mean, it is a probablistic fracture mechanics
           analysis, but it is a bounding probablistic fracture
           mechanics fracture analysis.
                       And what you would do when you hit the
           screening criterion is to do a plant specific, and
           Barry said probablistic fracture analysis.  So there
           really is a fair amount of margin built into the 300. 
           It was intended to be a bounding generic analysis.
                       CHAIRMAN BONACA:  This is really a
           screening criteria.
                       MR. ELLIOT:  Yes, it is a screening
           criteria on whether you have to do a plant specific
           evaluation.  That's all it is.  It is a screening
           criteria to determine whether or not you have to do a
           plant specific evaluation.
                       If you are below the screening criteria,
           we think that you have -- because of the way that we
           set up the curve or the analysis, you have adequate
                       DR. DUDLEY:  Now, would you have done that
           for all of the licensees for 40 years?
                       MR. ELLIOT:  That screening criteria that
           I am talking about is done based upon fraction
           mechanics and it is not done for any amount of years. 
           It is done or based upon fraction mechanics, and
           postulated transients for BWRs.
                       This was a generic issue, and it was
           resolved in SECE 82-465, and this is how we got to
           this screening criteria.  This was looked at for
           years, and this is how we resolved it.
                       MS. THOMPSON:  Barry, if I could add, I
           believe that the methodology, the uncertainty terms,
           the stipulation of what constitutes data that can be
           used and so forth, is all under 50-61 if I am not
           mistaken; 10 CFR 50-61 is it?
                       MR. ELLIOT:  That is the rule that governs
           the criteria, and what you do above the criteria.
                       MS. THOMPSON:  It is quite explicit
           actually in the process that we follow for analyzing
           the data, and the staff typically does a confirmatory
           analysis really to come up essentially with the same
                       And if we were not able to meet the
           screening criteria, then we would go through staff
           review again for the subsequent analysis that would be
           done, and basically those are really stipulated by
           regulation at this point.  I believe it is 50-61 if I
           recall correctly.
                       MR. ELLIOT:  And the staff has done the
           review of their analysis?
                       MR. ELLIOT:  We reviewed their PTS's in
           accordance with 10 CFR 50.61, and they meet it, and
           are satisfied that they are under the screening
           criteria of 297.4.  We wrote it up in the SER.
                       DR. SHACK:  No, I think he is saying to
           you do you check their calculations?
                       MR. ELLIOT:  Yes, we check their
                       MR. HALE:  In fact, if you are interested,
           we summarized all those calculations in the REI
                       MS. THOMPSON:  There is a specific REI on
           this particular item, and typically --
                       DR. ROSEN:  Could you give me a reference
           to it?  Not now, but later?
                       MS. THOMPSON:  Yes, absolutely.
                       MR. ELLIOT:  And the reviewer checks the
           calculation.  I want you to understand that we just
           don't say to you -- well, this is not a hard
           calculation.  For our reviewers, this is what we do. 
           We check out calculations.
                       This is a very important issue for us, and
           so we don't want them to go over the screening
           criteria.  So we check that.  We have to check the
           pressure limits and that requires an embrittlement
           calculation.  We check that.
                       Upper shelf energy evaluations, and if it
           says above 50 foot pounds -- and in this case it
           doesn't matter because they are below it.
           But if a plant says they are above 50 foot pounds, we
           check it.  We get to check their margin calculation if
           it is below 50 foot pounds.
                       DR. SHACK:  Right.
                       DR. ROSEN:  And here again I presume that
           one of the parameters in this regulation, in the Reg
           Guide and database, is fluence?
                       MR. ELLIOT:  Yes, definitely.  Our Reg
           Guide for radiation transition temperature shift is a
           function of neutron fluence, and the amount of copper,
           and the amount of nickel.
                       DR. ROSEN:  So if any of those shift by
           any amount --
                       MR. ELLIOT:  Well, cooper and nickel
           should not shift.  That is what they fabricated it
                       CHAIRMAN BONACA:  But fluence can change?
                       MR. ELLIOT:  Built into the rule is a
           stipulating that if you change the basis design of the
           core so that the neutron fluence changes
           significantly, they have got to come back and tell us
           the recalculation all over again.
                       It is built into the rule.  It even
           specifies the accuracy to which they have to calculate
           the fluence.
                       CHAIRMAN BONACA:  Right.
                       DR. SHACK:  But the copper and nickel --
                       MR. ELLIOT:  Well, the copper and nickel
           is another issue.  The copper and nickel was a problem
           for a long time, and we put out a generic letter, 92-
           01, and then we put out a 92-01 supplement, and then
           I think we now have it pretty good.
                       We know that copper and nickel for all the
           vessels in the United States, and that data is in the
           reactor vessel integrity database, and it is on the
           NRC home page.  Well, not home page, but one of those
           things, and you can get to it.
                       DR. ROSEN:  So let me understand this.  If
           this number had been submitted by the applicant as
           299.4 instead of 297.4, it would have said the same?
                       MR. ELLIOT:  That's right.
                       DR. ROSEN:  And if he had said it was
           299.9, it would have said the same thing?
                       MR. ELLIOT:  No, we have to calculate it,
           recalculate it at 299.9.
                       DR. ROSEN:  And they were okay.
                       DR. SHACK:  It is just like ASME code
           calculation.  If the allowable stress is 50 KSI, and
           you come in at 14.9, you are golden.  If you come in
           at 15.1, you have a problem.
                       CHAIRMAN BONACA:  Well, the screenings say
           you have to do specific calculations.
                       DR. ROSEN:  Well, we have specific numbers
           that people have to hit all the time, and there are
           various rules and codes, and we have essentially built
           the margins into those acceptability limits.
                       I mean, that is the real secret.  Nobody
           believes that you calculate the numbers that
           accurately, but you have put the margin into the
           acceptance limit.  And I got a little excited when I
           saw numbers, Peter, and then I said, wait a minute, I
           must have read that wrong.
                       MR. ELLIOT:  This is one of the areas
           where we actually have numbers.
                       DR. ROSEN:  But then I realized very
           quickly that I didn't have any numbers.  I just had
           answers.  I didn't have any rationale for them.
                       DR. DUDLEY:  On NUREG 15.11, that has a
           database in it?
                       MR. ELLIOT:  No, it doesn't  This is not
           the database.  NUREG 15.11 is the status report.  That
           is the status report on all the reactor vessels in the
           United States with respect to upper shelf energy, and
                       The actual database -- no, that's not it. 
           The database is controlled -- I have to go to Oak
           Ridge.  Oak Ridge has the entire database.  And by the
           way, they are looking at whether or not they should
           revise all of this.  This is all commercial reactive
           data that was in 1982.
                       DR. ROSEN:  What if they revise all of
           this and now the database only supports 295?
                       MR. ELLIOT:  Then we have a lot of plants
           that are going to have to do something.
                       DR. DUDLEY:  There is an ongoing research
           project in the Office of Research where they are
           reevaluating the PTS screening criteria.
                       MR. ELLIOT:  That's right.
                       DR. DUDLEY:  And they are attempting to
           identify all the uncertainties of the numbers that go
           into the calculation, and the assumptions for the
           scenarios that would get you into the PTS event, and
           wrap those into a single program which comes out with
           a probability of reactor vessel failure, and the
           associated uncertainties.
                       DR. ROSEN:  But look at the margins for
           lower shelf and intermediate shelf.  It is Unit 4 to
           use the worst case at Turkey Point, and under the best
           case Turkey Point is 64.7 degrees on the lower shelf,
           and it has a screening criteria of 270 degrees.  You
           have an enormous amount of margin.
                       MR. ELLIOT:  Right, because it has very
           little copper.
                       DR. ROSEN:  But then when you go to the
           circumferential weld, it is this tiny little thing.
                       DR. SHACK:  It wasn't a good idea to add
           copper to the weld.
                       CHAIRMAN BONACA:  But if you look at the
           technical foundation of the criteria used to make the
           judgment, you get comfortable about the conservatism
           built into the calculation.  I mean, the confidence
           level of the vessel ability to withstand the PTS, this
           big transient, given that criteria, it is so high.
                       MR. ELLIOT:  Well, it is very low.  The
           failure probability is low.
                       DR. ROSEN:  Well, I am way out of my depth
           in materials and metallurgy.  That's where I rely on
           Dr. Ford to have the requisite level of confidence.
                       CHAIRMAN BONACA:  Well, if you take any
           one of those bullets there and you go to the
           references that support the application, you will find
           a lot of numbers.
                       In fact, you lose yourself into those, and
           then soon enough you commit suicide probably if you
           want to read them all because there is so much there. 
           So there is plenty of technical information.
                       DR. ROSEN:  But, Mario, my sense of this
           application is that there is a very broad degree of
           conservatism and good engineering practice, and
           prudence in this application.
                       In this one area, it looks like it skins
           right up against the criteria.  It as close as one
           could go realistically, without having to do a whole
           lot of different things.
                       CHAIRMAN BONACA:  But you have to look at
           it and it is not intended to be my judgment of fail
           safe criteria.  This actually is a determination of
           whether or not you do some more homework or not.
                       DR. ROSEN:  And so if you wanted to be
           conservative, and if you were, for example, at a
           national laboratory, one could say that we did it at
           this calculation and it comes out to 297.4, and that
           is pretty close to the screening criteria, and so we
           are going to do a plant specific analysis in addition
           and submit it, just so you get a sense of what the
           real answer is.
                       MR. ELLIOT:  Well, we already did that,
           and that's how we got the 300.  That's how we did
           that.  We did a lot of probability studies on
           transients and fracture mechanics evaluation, and that
           is how we got the 300 and the 270 screening criteria.
                       DR. DUDLEY:  And as I remember, your
           margin criteria was based on the relationship to the
           event being less than 10 to the minus 6th probability.
                       MR. ELLIOT:  Well, less than 10 to the
           minus 6th was the probability of failure we were
           looking for of the vessel, and then we threw that --
           the mean value came out to be like 210 or something
           like that for all the studies.
                       And so we threw the 56 in and it came to
           260, and then we had another study for the
           circumferentials and that is how we did it.  This had
           a tremendous database of analysis to get the screening
                       And the analysis had margins in it to get
           to the 5 times 10 to the minus 6 failure probability,
           and that's how we got the screening criteria.
                       DR. SHACK:  Putting it into PRA terms,
           think of it as the difference between the containment
           design pressure and the containment failure pressure.
                       CHAIRMAN BONACA:  Yes, I would say that
           there is even more margin there.
                       DR. SHACK:  And in fact a lot of times you
           will end up with a containment design pressure, like
           60, and you hit 59.7, and the main steam line break or
           large break --
                       DR. ROSEN:  In some plants, you hit 36.
                       DR. SHACK:  They still breathe easy when
           they hit 59.7.
                       DR. ROSEN:  SECE 82.465 has got the
           background on how to select this circumferential weld
           for screening.
                       MR. ELLIOT:  No, that is the background
           for the PTS rule.  If you want to know how to do the
           calculation, it is Regulatory Guide 1.99 Rev. 2.  But
           it is also in the rule.  And Reg Guide 1.99 Rev. 2 has
           also been implemented into the rule itself, which is
           10 CFR 50.61.
                       DR. FORD:  All right.  Can we get back to
           Turkey Point?  On the 11 renewal applicant action
           items, I recognize that the old REIs was done before
           this came out as I understand it.
                       Looking back on it do you think that the
           REIs took into account those 11 action items?  I think
           Al said there had been some REIs on many of those
           items; is that correct?
                       MR. ELLIOT:  Yes.  The applicant responded
           to these items, and I looked it up because I wanted to
           make sure, is Turkey Point SER, Section, has
           a discussion on the applicant action items for the
           reactor vessel internals.
                       CHAIRMAN BONACA:  What section is that?
                       MR. ELLIOT:  SER Section, and that
           is for the internals.
                       MR. HALE:  The REI response letter was
           L2000176, and it was REI 3.2.5-4, and all 11 applicant
           action items are in that response.
                       DR. DUDLEY:  Could you provide us with a
           copy of that?
                       MR. ELLIOT:  Of what?
                       DR. DUDLEY:  Of the REI response?
                       MR. ELLIOT:  I can get you a copy.
                       DR. SHACK:  I have a question.  Will all
           of those be on a CD some day with the application?
                       DR. SHACK:  Does anybody know?
                       MR. KOENICK:  No, there is no requirement
           to update the application once we grant the license.
                       DR. SHACK:  So anybody in the public who
           wanted to do this would have to track them down
           through ADAMS?
                       CHAIRMAN BONACA:  Or call and get a copy.
                       MR. ELLIOT:  All right.  Continuing on. 
           There were 11 renewal action items for the reactor
           vessel internals WCAP.  I highlighted four of them
                       We want to evaluate the synergistic
           effects of thermal aging and neutron embriddlement on
           fracture toughness of cast austenitic stainless steel. 
           The staff's issue on this -- and we have talked to you
           in the past about this, is that we want them to
           identify the limiting locations for inspection, and
           then utilized information from the MRP program on
           reactor vessel internal identify the inspection
           methods and the criteria.
                       That is our position, and that is also the
           same position we have for avoid swelling, cracking,
           and loss of fracture toughness.  And another issue
           that we would like to address on a plant specific
           basis was their baffle/former and baffle bolting page
                       The staff's position here is volumetric
           inspection of the junction of the bolt heads of the
           shank is the important place to look for cracks. 
           Visual inspection won't be adequate and you need a
           volumetric, and MRP is developing an industry program
           for this issue.
                       And then as far as the internals, we need
           a plant specific to achieve evaluation.  For the
           pressurizer, there were 10 renewal applicant action
           items, and I highlighted only two of them here.
                       Perform plant specific fatigue evaluation,
           including insurges and outsurges and other transient
           lows not included in the current licensing basis.
                       And then evaluate the potential for
           bolting to develop stress corrosion cracking.  Our
           position here is that bolting is susceptible to stress
           corrosion cracking when the bolting is fabricated,
           producing a yield stress graded at 150 KSI.
                       And whether there is excessive torquing of
           the bolts, an introduction of contaminants and
                       CHAIRMAN BONACA:  And then for Turkey
           Point, you have accepted.
                       MR. ELLIOT:  Yes.  They claim that they
           have procedures to prevent excessive torquing, and
           they control their lubricants, and that is the basis
           for our accepting the bolting.
                       CHAIRMAN BONACA:  That's right.
                       MR. ELLIOT:  And then there are 16 renewal
           applicant action items for the reactor vessel
           supports.  I didn't highlight anything here.  If there
           is something that you would like to talk about, we
           have people who did the review here.  Are there any
           issues that you would like to highlight?
                       CHAIRMAN BONACA:  Well, the top bullet
           under pressurizer, that is actually counting -- I
           mean, looking at actual transients, right?
                       MR. ELLIOT:  Yes, actual transients. 
           Mark, and then John, did the fatigue part of the
                       MR. FAIR:  Yes.  This is John Fair with
           the Mechanical Engineering Branch.  What they have
           done on Turkey Point is that they have a fatigue
           monitoring program, and what they are monitoring is
           that the design transients that they assumed in the
           original analysis do not get exceeded in the period of
           extended operations.  So they did not go back and
           recalculate anything.
                       MR. ELLIOT:  And our conclusion is that
           upon completion of all renewal applicant action items
           the license renewal applicants who reference the WOG
           reports adequately demonstrate that the aging of the
           components within the scope of the WOG report can be
           managed so that there is a reasonable assurance that
           the components will perform their intended function in
           accordance with the current licensing basis during the
           period of extended operation.  That is our finding for
           license renewal.
                       DR. ROSEN:  What are these 16 renewal
           applicant action items?  Are they administrative kinds
           of things?
                       MR. ELLIOT:  No.
                       DR. ROSEN:  Will you characterize them for
                       MR. ELLIOT:  There are technical issues
           that we want them to address when they submit an aging
           management program for a reactor coolant support over
           and above what is in the WCAP.
                       DR. ROSEN:  Could you pull an example out
           for me?  What are we talking about here?
                       MR. ELLIOT:  Well, we have a lot of them. 
           We have had the 10 here and the 16 there, and 12
           there, and so on.
                       DR. ROSEN:  I am trying to get a sense if
           these are overwhelming issues?
                       MR. ELLIOT:  No, I don't think they are
           overwhelming.  We have reports here.  Hai Bo here is
           the reviewer of the WCAP and wrote the action items. 
           So he can give you some insight.
                       DR. ROSEN:  And I had the pleasure of
           reading it as well.
                       MR. WANG:  My name is Hai Bo Wang from the
           License Renewal Branch.  I reviewed the WCAP, but I
           didn't review the application from Turkey Point.  What
           Turkey Point did, I don't know.
                       The original draft SER had nine action
           items, and six open items, and my concern was
           generated to all the work numbers.  And we converted
           all the open items to action items as well.
                       For instance, the WCAP has pictures for
           all the components support reactor vessel, and we have
           five reactor vessel support configurations.
                       DR. ROSEN:  Now, Hai Bo, what you are
           talking about is your review of the WCAP?
                       MR. WANG:  Yes.
                       DR. ROSEN:  But my question was what are
           the 16 renewal applicant action items relative to that
           WCAP for Turkey Point?
                       MR. WANG:  Well, I have no idea what the
           renewal action items do.  I did not read the Turkey
           Point application.
                       MR. HALE:  The reactor coolant supports,
           we had a draft SER at the time that we submitted the
           application.  So we summarized how Turkey Point
           addressed the open items and applicant action items,
           all 15 I guess, in the application for that one,
           because we had a draft SER.
                       So you will find that in the tables in
           Chapter 2.
                       DR. ROSEN:  So I look at Chapter 2 of your
           application, and I find those action items, and what
           you are just saying, Barry, in this slide --
                       MR. ELLIOT:  I am telling you what my
           review of the WCAP is.  This is a slide that says that
           we reviewed the WCAP and this is what we found.  It
           has nothing to do with Turkey Point.
                       DR. ROSEN:  Then Hibo is telling me about
           these things, about one action item.
                       MR. ELLIOT:  And there are about 14 or 15
           action items.  They are not all like that.  There was
           one issue that I looked up, and there is an issue on
           strain aging on there.  There are other issues, and
           you just have to look at them.
                       The reviewer looked at issues, and said
           these are issues that I don't see you answered in this
                       DR. ROSEN:  And FPL has answered them in
           the application.
                       MR. ELLIOT:  Right.
                       DR. ROSEN:  And those 16 applicant action
           items are not open items?
                       MR. ELLIOT:  Right.  We are satisfied with
           their answer.
                       DR. ROSEN:  And specific ones that Barry
           was saying, you know, that Westinghouse identified
           temporal embriddlement and strain aging as two of the
           degradation mechanisms that could affect the support.
                       They ruled out temporal embriddlement on
           a generic basis because the temperatures were too
           high, and the applicant had to address whether a
           strain aging could affect his reactor supports.
                       MR. WANG:  But in the WCAP, they never
           mentioned -- they didn't say nothing about strain
                       MR. ELLIOT:  So this whole thing here is
           the staff's review of the WCAP and our evaluation of
           the WCAP, and where we think the applicant must
           supplement the information in the WCAP.
                       And they have supplemented it, and we have
           reviewed it, and not only that, we have reviewed their
           reactor coolant system support as part of some
           program, and found it acceptable, and that's what you
           heard this morning.
                       DR. ROSEN:  Well, the supports were
           reviewed when the plant was licensed, I assume?
                       MR. ELLIOT:  No, they were reviewed as
           part of the license renewal, all within the scope of
           license renewal.  So they had to be reviewed for their
           aging effects, and for their aging management
                       MS. THOMPSON:  I would like to just
           emphasize that for Turkey Point that we did not
           incorporate by reference these particular generic
           technical reports.
                       We simply addressed -- we performed our
           own aging management reviews, and provided that
           information in the application, and then these reviews
           were in process at the time.
                       So as part of our application, we tried to
           anticipate questions that may come from the staff, and
           we addressed those open items or applicant action
           items that were available to us at the time in our
           application, really in anticipation of potential
           questions from the staff.
                       And for those that were not on the table
           at the time that we submitted, we addressed those
           through REIs.  But our aging management review really
           stands on its own merits, and has been reviewed by the
                       CHAIRMAN BONACA:  Let me say if you had to
           perform the application today, you would take all nine
           items on the pressurizer, and address them
           individually, just as you did in this table here.
           2.3.3., and have a total correspondence between the
           topical report that supports it and the application.
                       MS. THOMPSON:  Yes.
                       CHAIRMAN BONACA:  So there was that kind
           of mishmash, and it was because you didn't have
           available all those questions at that time.
                       MR. ELLIOT:  We are finished.
                       CHAIRMAN BONACA:  All right.  Why don't we
           take a break right now, and then come back at 3:15 and
           talk about the application.  I think we have to talk
           briefly about Westinghouse Topical Reports and our
           judgment, and we had specific reviewers assigned to
           some of them.  So let's take a break right now.
                       (Whereupon, at 3:05 p.m., the meeting was
           recessed, and was resumed at 3:25 p.m.)
                       CHAIRMAN BONACA:  Okay.  The meeting is
           called back to order, and what we need to do now is
           two things.  One, to go around the table for the
           members of the subcommittee and provide their views,
           if there is any additional view in additional to what
           they already provided regarding, first, the Turkey
           Point application.
                       And then separately we will talk about the
           WOG documents, and again provide views on those.  Once
           we have done those two things, we will talk about what
           we are going to do, and the issue is this application
           was pretty clear, and pretty thorough.
                       We have seen four open items, of which
           really only one it seems to me is a true open item. 
           It is very likely that they are closed in the very
           short term.  In the past, when we had situations like
           this, we did not write an interim letter.
                       And when the final SER came weeks or just
           a couple of months after the interim SER, and so we
           pointed out to the Commission that we in fact did not
           write an interim letter because of that reason.
                       And we would then write a letter when the
           final SER comes to us.  And then we will discuss that,
           and then at that point we will talk also about whether
           or not we need to write a separate letter on the WOG
           documents, considering that the application from
           Florida Power did not include reliance or reference to
           those documents.
                       And those documents may not be used by
           other applicants in the future because they may use
           simply our report.  So we will decide on all these
           things, and let's go around the table, first of all,
           regarding the applications from Florida Power for
           Turkey Point.
                       I would like to have your views and
           anything new that you may have to what you have
           already provided with your question and answers.
                       DR. ROSEN:  Well, I have nothing in
           addition to those, although I would just like to kick
           them off to make sure that we know what the points are
           that I think were interesting or important.
                       First, of course, is the question of the
           proximity of the calculated RT PTS to the screening
           criteria, and how we handle that, or if we handle that
           in the letter, or even in discussion with the
           committee, or if the committee chooses to make any
           kind of reference to that to the commission, I don't
                       That is all to be determined, but at least
           that is a subject matter from my point of view.  The
           other thing that I thought was interesting is that in
           talking to the staff and thinking about the large term
           nature of license renewal, and the need to retain the
           corporate knowledge of the applicant, and the fact
           that the staff had not looked into the engineering
           support personnel training program with regard to
           license renewal, was sort of illuminating to me.
                       Now, the licensee did clearly in their
           remarks, they said that they had dealt with that, and
           I think probably what they are doing is appropriate. 
           But the staff hadn't tumbled to that, and I rather
           think INPO hasn't.
                       If you go all the way back to the INPO
           documents, and I used to know their numbers, but I
           have forgotten them now, that define the requirements
           for engineering support personnel training programs,
           I will bet you that there is not much about license
           renewal in them.
                       So if we can successfully do something to
           help that get embedded in the industry's training
           programs for engineers, that will be good for
                       Another point that I made and followed up
           a little bit on in the discussions was the fact that
           I didn't get a lot of clarity in how equipment used in
           the emergency operating procedures, and the emergency
           review guidelines was in fact covered by the staff, in
           terms of proper scoping and screening, and aging
           management reviews.  Maybe it is because it went by
           too fast, but --
                       CHAIRMAN BONACA:  You mean the use of
                       DR. ROSEN:  ERGs and the daughter, EOPs,
           that come from the ERGs, and whenever you put
           something in an EOP, an operator is going to look at
           this during this severe accident, and you need to
           think about is that thing that he is going to look at,
           is it in scope?
                       CHAIRMAN BONACA:  You have to realize that
           the EOPs and ERGs is an issue that we raised, and
           specifically the staff had put in their reference to
           the scoping process EOPs as a document to check for
           additional information, although by the license
           renewal rule it is not in scope really specifically.
                       DR. ROSEN:  Why is that?  I don't
           understand why it is not in scope.
                       CHAIRMAN BONACA:  And the NEI agreed to
           that, and then NEI agreed and they put it as a
           reference in their reference attachment in the NEI
                       Now, we also recommended that severe
           accident guidelines be included as a reference
           document, and the staff endorsed that, and NEI did not
           as far as I can tell, because they feel it is a
           voluntary program and that kind of stuff.
                       DR. ROSEN:  You mean SAMSA is voluntary,
           but license renewal is not voluntary.  I mean, it is
           voluntary on their part, but the staff doesn't have to
           grant it.
                       CHAIRMAN BONACA:  Well, the EOPs, they
           have agreed to look into this, and so I don't know. 
           We may ask them to address this issue with them next
           week during the full committee meeting, and just
           simply tell us how they look at them.
                       DR. SHACK:  I thought the commitment that
           we got from the staff today was probably as much as we
           could get without changing the rules.  If you really
           want it to define that part of the scope, then I think
           you almost have to change the rule.
                       And it sounds to me like they were sort of
           doing the best that they could and whatever arm
           twisting --
                       DR. ROSEN:  The staff has to do that, but
           we don't have to.  We can comment to the Commission on
                       DR. SHACK:  Well, we can comment, and I
           think we said that we didn't need a rule change.
                       DR. ROSEN:  And I think that we probably
                       CHAIRMAN BONACA:  Especially if you take
           the Westinghouse ERGs.  I mean, they go far from your
           design basis.  I mean, they look at the possibility of
           all kinds of scenarios.  So that is an issue that we
           have to tackle.
                       DR. ROSEN:  But I have this pristine
           clarity and insight that comes from not being involved
           so much, and it seems to me that things an operator
           might rely on during a severe accident late in the
           life of a plant, the 58th year, what a work, and we
           ought to have a lot of confidence in all of this. 
           That's all I am saying.
                       CHAIRMAN BONACA:  And we wrote two letters
           in which we put our position and recommendations to
           the Commission, and they were endorsed, but endorsed
           that these documents would be guidance that they would
           look at, and not endorsed as a change to the rule to
           explicitly incorporate those documents.  So it would
           be important to understand how the staff is using them
           at all.
                       DR. ROSEN:  Well, you asked me what I
           thought after listening to the subcommittee.
                       CHAIRMAN BONACA:  Well, actually, you are
           picking things up fast.  You already have covered two
           past letters in a row with that issue, because we
           really brought it out.
                       DR. ROSEN:  So those are the three things.
                       CHAIRMAN BONACA:  Great.  Thank you. 
           Going around the table.  Peter.
                       DR. FORD:  I just feel myself capable of
           answering the questions about degradation loads.  I
           liked the Turkey Point LRA, and I think that the staff
           identified all of those EOPs that required modifying,
           et cetera.
                       So I don't doubt that the regulations will
           be met, which is all that is required at this stage. 
           My big problem, however, is that I have not seen any
           data that addresses the kinetics of that degradation.
                       And that impacts on two broader issues
           which is outside the Turkey Point application, and
           that is the validity of once only inspections.  The
           phenomena that we had identified on the inspections at
           Turkey Point, they are defensible.
                       But for the ones that require multiple
           inspections -- internals and the other phenomena --
           they depend very much on the accuracy and the
           completeness of the various disposition relationships. 
           That is, degradation versus time, et cetera.
                       And unfortunately the data that we have in
           the industry as a whole you increasingly find, and
           especially as far as cracking is concerned, is not
           adequate, and is of poor quality, and sometimes
                       And that is more of an industry problem,
           and it is completely outside the Turkey Point
           application, and is something that industry is going
           to have to tackle.
                       CHAIRMAN BONACA:  Yes, that issue would
           truly be affecting also aging in the current licensing
                       DR. FORD:  Absolutely.
                       CHAIRMAN BONACA:  Okay.  Bill.
                       DR. SHACK:  I thought that this was a good
           license renewal application, and I liked the table
           format.  I thought that the electronic version was
           quite useful.
                       And I am not sure that there is any way to
           get around the thing, but there is a certain amount of
           jumping.  You think they are talking about the reactor
           vessel head penetration here in this section, but it
           is really just mentioned here and it is discussed over
                       And you are about to conclude that the
           discussion is totally inadequate until you realize
           that you are looking in the wrong place.
                       DR. ROSEN:  You pop the hyerlink and --
                       DR. SHACK:  And on the electronic version,
           you pop the hyperlink and you get to the right place.
                       And in the paper version, you kind of look
           and say, oh, my god, and you are getting ready to send
           off a nasty-o-gram, and you stumble on the real
           discussion somewhere else.  And I think that is
           inevitable in something as large and as massive as
           these things.
                       The only technical quibble I had was with
           this thing on the VT1, and again, I think we have
           discussed with the BWR VIP that you really need
           enhanced inspections to IASCC or SCC, and although I
           don't see a problem here because they have got the
           ultrasonic for the baffle bolts --
                       CHAIRMAN BONACA:  This is the one for
                       DR. SHACK:  Yes, cracks in the internals.
                       CHAIRMAN BONACA:  And concerning the SER.
                       DR. SHACK:  Yes, and if the SER said we
           didn't like this, but it is okay, then I could buy
           that.  But when the SER sort of implies that this is
           fine and dandy, I am less happy.
                       CHAIRMAN BONACA:  And that is probably
           something we will mention in the letter, and as a
           minimum, was a note that we don't believe that --
                       DR. SHACK:  Well, the staff doesn't
           either.  I mean, any time they are really serious
           about it, they have asked for enhanced VT1.
                       CHAIRMAN BONACA:  Any other comments?  All
           right.  I reviewed this and clearly in the perspective
           of the others, it was a good application.
                       I mean, for me, it was visibly easy to
           follow, and I liked some of those tables that allow
           you to see under 5 or 6 columns, and the component,
           and whether it is in scope, and the environmental
           conditions, and the aging effects, and the function.
                       And for an interested person that wants to
           look at it -- and I don't know who would be interested
           outside, but still that could be -- that would be a
           useful format.
                       And I thought that it was quite complete,
           and I thought that the scoping was effective.  In
           fact, I found in some cases that the scoping went
           beyond what I had seen before.  For example, the spent
           fuel pool.
                       There was an effort to define the
           functions that were complete and covered more ground
           than other applicants had done before in my judgment.
                       The screening was also appropriate, and I
           think the definition of functions was quite thorough. 
           I thought the discussion of environment and aging, or
           aging effects was good also.  I thought the programs
           were significant.
                       And again the points that Peter made as to
           that were absolutely valid, and that really speaks of
           how currently we operate these plants.  So it is true
           also for this operating plant.
                       I agree with the findings of the staff. 
           I think that of the four open items that only one is
           an open item truly.  It still troubles me that it is
           a repeat.  I think that it probably in-part is tied to
           the licensing basis of the specific plant, and how
           they define things, and is probably beyond my
           understanding right now of why it is a repeat issue
           that comes again.
                       But in general I thought it was a good
           application.  I do believe again that this power plant
           in my judgment is a better plant now because it has a
           detailed series of commitments and an analysis of this
                       And that's why I think it is so important
           about the point that Steve was making before, that the
           plant is trying to train the personnel to understand
           what they have, and the commitments that they have,
           and what they have learned from it.  This is important
           for everybody concerned.
                       So before we talk about the WOG reports,
           we had a situation before where we reviewed an SER and
           found that it was completely readable and we
           understood it, and also the application we understood,
           and we had very few open items.
                       And we made a decision then not to write
           a letter, and the reason is that we got the final SER
           in no time after that, and so we just simply wrote a
           letter for the final SER.
                       And we have a choice right now.  We can
           choose to do the same for this application, or to
           simply write a full report next week.  I would like to
           hear from you guys on what you would like to do.
                       DR. ROSEN:  Well, let me ask you a
           question in-turn.  What is the timing for the final
           SER?  They said they were moving it up, and working
           with the staff now to try to --
                       CHAIRMAN BONACA:  The earliest is
           December, or in January, and we would be writing a
           letter in the February or March time frame.
                       DR. ROSEN:  That is the schedule we
           anticipated.  It says May now, right?
                       MS. THOMPSON:  We have asked the staff to
           look at a March of next year decision point for our
           renewed license.
                       DR. ROSEN:  So that would be February, and
           our letter would be at least a month before that, and
           so we are talking about writing something now in
           October, and we might have another letter in March.
                       CHAIRMAN BONACA:  Well, the value of an
           interim letter has always been that if we had
           something that we wanted to communicate -- like, for
           example, we don't like something, or you should do
           something else.
                       DR. ROSEN:  Well, specific to this
           license, and we want to communicate something in
           general, or generic, yes; but if we had something
           specific to this license --
                       CHAIRMAN BONACA:  Well, I don't think we
           do very much.  So my recommendation would be to go to
           the full committee and tell them that we are not going
           to write a letter at this time, and the most we could
           do would be to send a very brief note saying that we
           have chosen not to write a letter because of the
           quality of the application and a few open items.
                       DR. ROSEN:  I think that would be better,
           is to write a brief letter that says that, but also
           says some things like in our letter which we expect in
           the first quarter of 2002, we may have some comments
           about or that could lead to general improvements that
           came up during the review of the Turkey Point
           application that could lead to some generic
           improvements in the process, or something like that.
                       DR. DUDLEY:  Just from the staff's
           viewpoint, I would rather leave that as an option of
           something that we can do, because as soon as we put it
           in writing to the EDO or the Comission, it almost
           becomes a have to do.
                       CHAIRMAN BONACA:  Yes.  Well, my
           suggestion is that we don't write a letter.
                       DR. ROSEN:  Okay.
                       CHAIRMAN BONACA:  And then we will decide
           if we write a brief piece of information, or as we did
           for Arkansas when I wrote the letter for that, we

           chose not to write a letter and because, and we
           pointed out the reasons.
                       DR. ROSEN:  And were the reasons technical
           or logistical.  In this case, they are logistical.
                       CHAIRMAN BONACA:  It was mostly for
           Arkansas that we felt that the application was very
           good, and complete, and were very few open items.
                       DR. ROSEN:  Isn't that where we are here?
                       DR. SHACK:  Yes.
                       DR. ROSEN:  So we would say the same thing
           in this case.  We would write a letter that says the
           applicant's application is very good, complete, and
           there are a few open items, and we expect a final
           letter very shortly.
                       CHAIRMAN BONACA:  Well, no.  Noel has said
           no, and --
                       DR. ROSEN:  Well, I think we should write
           a letter and it should be a brief one.
                       CHAIRMAN BONACA:  Well, we will talk about
           it next week with the full committee.  We will bring
           it up and decide.
                       DR. ROSEN:  Well, notwithstanding Noel's
           comment to the contrary, I think I would signal the
           fact that it is a learning process for us as well, and
           as part of this discussion that we have perhaps found
           some things that we could lay on the table that could
           either help the staff in the way they review
           applications, or the applicants and in the way they
           put them together.
                       CHAIRMAN BONACA:  Okay.  So, we will bring
           that recommendation up to the committee, and the
           committee may decide to do something otherwise.  Now,
           the second issue is the Westinghouse Owners Group
                       We have specific assignments on those
           reports, and I can speak about the pressurizer one,
           and I reviewed it in detail, and I felt that it was a
           good report in several ways.  One was a description of
           all the types of pressurizers that are in the
           Westinghouse family.
                       And I think that was quite descriptive of
           components, and the environment, and the face, and the
           materials, and really had a form that was a typical
           license renewal form all the way through.
                       I liked very much the form where we got
           together the WOG report with the SER in front of it,
           and the SER specifically listed in the back portion
           the renewal applicant's action items.  It was very
                       And there was a linkage between those and
           what the WOG said.  So the WOG said only three action
           items for the individual licensees, and the staff
           said, no, we disagree with that.  We have nine action
           items, and they put them forth clearly.
                       And I liked the fact that in the back
           there was a full listing for the request for
           additional information and answers to those.  So
           within the report, I believe there was a full feeling
           for the interaction that took place between the WOG,
           the staff, and the conclusions.
                       And that when I looked at this document,
           and I looked at how it is being used to support
           something like Turkey Point, especially Turkey Point
           by relying on it and including it for reference, I
           thought it would be very well supported, in the sense
           that it becomes like an integral part of that.
                       So I thought it was a good document.  I
           could not pass judgment on every single aging effects. 
           I am not an expert on materials so that I could do
           that, but it seemed reasonable based on what I have
           seen in the GALL report before.
                       DR. SHACK:  Except for that confusing
           section in the pressurizer where they talk about the
           erosion of stainless steel components, and then sort
           of in the next sentence decides that it is really not,
           and I can't figure out the logic, although I agree
           with the conclusions.
                       CHAIRMAN BONACA:  This is the issue where
           the staff felt there was confusion?
                       DR. SHACK:  Right, the staff felt it was
           confusing, and I was confused.
                       CHAIRMAN BONACA:  Well, I thought that I
           understood what they were saying or where they were
                       DR. SHACK:  Well, I understood where they
           got to, but what I didn't understand is how they got
           there.  But that's okay.
                       CHAIRMAN BONACA:  That's interesting that
           you are bringing that up, because I thought it was the
                       DR. SHACK:  It is on page 55.
                       CHAIRMAN BONACA:  All right.
                       DR. SHACK:  They have the potential to
           cause erosion, and then the next sentence says only
           one component is considered to have flow conditions
           that have the potential for erosion.  So the next
           sentence contradicts the previous sentence.  But the
           conclusion, when it is all said and done, is something
           that I would agree with.
                       CHAIRMAN BONACA:  And at the bottom it
           says that only one is considered to have flow
           conditions that have the potential for erosion.
                       DR. SHACK:  They all have it and then it
           says only one has it.
                       CHAIRMAN BONACA:  Because only one has the
           flow condition that could justify erosion.  The others
           are not faced by that flow condition.
                       DR. SHACK:  And several are exposed to
           fluid flows that have the potential for causing
           erosion.  If you understand it, that's fine, because
           I am a bit confused.
                       CHAIRMAN BONACA:  Well, anyway, that was
           my feedback on the pressurized items.  And now the
           other reports.
                       DR. SHACK:  Well, I looked at the pressure
           boundary, and I thought they were good reports, and as
           you said, I really like this format where we get
           everything.  And that is the usual difficulty here, is
           that the REIs are off somewhere in ADAMS, and all you
           see are references to REI, and you have no
           idea what is in there.
                       CHAIRMAN BONACA:  That's right.
                       DR. SHACK:  Now, I was a little puzzled by
           some of the things that seemed to be open issues here,
           and then Barry clarified that by saying that I had not
           quite appreciated just the time frame that this was
           all done.
                       CHAIRMAN BONACA:  Yes.
                       DR. SHACK:  And no doubt that things would
           be a little different if they were doing them after
           the benefit of a couple of license renewals.  But I
           think they will turn out to be quite useful, although
           as I said, maybe GALL is even a better way to
           reference things, but this is still a very useful
           overall technical package.
                       DR. FORD:  Okay.  I did the reactor
           internals.  I also liked the report.  I have a few
           comments that I liked.  For instance, the general
           layout, and the fact that Table 2.2 clearly listed
           those parts and subcomponents needing aging management
                       I disagree that the hold down springs, for
           instance, don't need a review, but maybe there is a
           good regulatory reason for that.  But that is a minor
                       I would also disagree with the fact that
           on page 4.1 that cracking and material degradation due
           to corrosion and stress corrosion cracking is
           insignificant.  That was written before the Oconee
           incident, and I assume that would no longer be a
           believable statement.
                       And I am assuming that no one would take
           that as the gospel at this time.  And I particularly
           liked the fact that this would be used as template. 
           I liked the Tables 4.1 through 4.8, which lay out the
           criteria that should be covered in an aging management
           program attributes.
                       They were clear and gave examples for the
           various components or phenomena -- radiation, stress
           corrosion cracking, et cetera, and which obviously
           would be plant specific.
                       And as I stated before, even though
           someone said there is data in here, there is not one
           data point in this whole report.  I would love to see
           some supporting data in any aging management program
           that would support what the margin is, and how this
           program is going to ensure within that project.  But
           the report I liked very much.
                       CHAIRMAN BONACA:  But I am sure that the
           report must have referenced some activities.
                       DR. FORD:  Oh, it does, and the report
           gives a lot of --
                       CHAIRMAN BONACA:  It has to be planned on
           existing activities.
                       DR. FORD:  Absolutely.  >From a
           readability point of view, we have a million-and-one
           documents pushed in front of us.  It would be nice to
           see, if only two pages, the state of the art, with a
           couple of graphs in there showing where the data
           relates to the disposition curves if you are going to
           use that for an ASME Section XI inspection.
                       But these sure give the idea that there
           are some data to back up these inspection results
           which are being given in these Tables 4.1 through 4.8.
                       CHAIRMAN BONACA:  So we covered the
           pressurizer, and the internals, and you reviewed which
           one, Bill?
                       DR. SHACK:  The boundary components and
                       DR. ROSEN:  Yes.  I thought this was an
           excellent document.  It has these pictures in it of
           the support and pictures of the various support
           configurations.  This happens to be one of the best
           ones, but this is a steam generated support
           configuration four, and reactor coolant pumps support
           configuration six.
                       So I just happened to have that one, and
           this is a picture of your plant, and then there is a
           table that tells you which plants have which
                       And then there is another table that tells
           you which plants are built to which code standards,
           and just a compilation of all of that must have been
           a mammoth task.  I thought it was very well done.
                       DR. SHACK:  It would have been very nice
           to have the --
                       DR. ROSEN:  So this table, Table 2.2-2,
           primary components support configuration
           classifications for all the plants, and which tells
           you what configuration of all of the configurations of
           what each plant has for the reactor vessel, and what
           configuration it has for the RCPs, et cetera.
                       And so you can find the plant and go
           across there, and if you have enough patience, you can
           get a mental picture of what all the supports look
           like for each plant.
                       CHAIRMAN BONACA:  And so I even know the
           size of your pressurizer.
                       DR. ROSEN:  It is bigger than most isn't
           it?  All the others are 84 and ours is a hundred.  But
           it is very descriptive, and I must say that I
           hesitated to read it, bring a PRA type operating guy,
           and I finally brought myself to look at it, and it
           wasn't all that bad after all.
                       CHAIRMAN BONACA:  So the question I have
           for you is we have three choices.  If we don't write
           a letter on Turkey Point at this meeting, should we
           write a letter on these supporting documents now?
                       And the second option will be to write a
           separate letter when we are writing also the letter,
           the final letter for Turkey Point; and the third one
           is to do what we have done before, although the staff
           does not like it.
                       And that is to incorporate comments on
           these documents at the time at which we write a letter
           for Turkey Point.  That is the way that we did it for
           Oconee, and referencing the case, the B&W genetic
                       And also we have done it for Hatch, where
           we referenced the BWR documents, and also for Calvert
           Cliffs, where we referenced to see the documents.
                       DR. SHACK:  Well, again, these things are
           not going to be revised.  The SERs are done, and as
           far as I can see the only incentive for writing a
           letter is if there is something that you disagree
           with.  And I haven't got anything.
                       CHAIRMAN BONACA:  So my suggestion is to
           just leave them behind and talk about them when we
           reference or write a letter on Turkey Point.
                       DR. ROSEN:  Isn't here another piece of
           support for leaving them behind and not doing too much
           with these Westinghouse Topicals, and Turkey Point did
           not use them, or at least directly.
                       They explained how they did, but they
           didn't officially reference them.  So I think to pull
           a letter out of our hat on the topicals at this point
           doesn't make sense.
                       CHAIRMAN BONACA:  I agree with that.  So
           we have a recommendation to bring it to the committee,
           and what I would like to do is the following.  I would
           like to talk now about what is going to happen next
                       We have two hours on the agenda, I
           believe, and I think we need a presentation by the
                       DR. DUDLEY:  The staff.
                       CHAIRMAN BONACA:  We need a presentation
           by the staff and to focus on open items, and really a
           summary of the report.
                       DR. DUDLEY:  Could the staff address some
           of the questions that have been raised here about
                       DR. ROSEN:  That would be excellent, as
           that was the whole purpose of the subcommittee meeting
           wasn't it?  Was to let the staff know what we think of
           the application and of their review?  So that if there
           are any questions, they can come back to the full
           committee and perhaps dispatch them.
                       DR. FORD:  Could I just ask a question? 
           What are we going to do about these documents?
                       CHAIRMAN BONACA:  Right now we are not
           going to write a letter on those.  We are going to
           comment on those probably when we write the final
           letter on Turkey Point.
                       DR. FORD:  Bill, you just said that these
           are not going to be revised.
                       (Discussion off mike.)
                       MR. NEWTON:  My name is Roger Newton, and
           I am also Chairman of the Westinghouse Owners Group
           License Renewal Working Group, and so I am here to
           answer any questions that you may have concerning the
                       And we can talk a little bit about how we
           envision them being used on Turkey Point, and that was
           kind of the first plant to use them, and as was
           mentioned here, they didn't have the full SERs and the
           action items on them.
                       I would expect the next generation of
           plants would use them more discreetly, and
           specifically address the licensee action items like
           you talked about here.
                       And the purpose is to define and simplify
           the review for the NRC, and define what the applicant
           should be looking at, and that is his guide.
                       Now, Turkey Point still has to do a full
           evaluation, but he has a cookbook to compare himself
           to to see if he has missed anything, or if he found
           anything that is different.
                       And that's why every first action item was
           to say how are you bounded by the WCAP and SER, and if
           you find something different, you are obligated to
           then identify it, and to deal with it.
                       And with respect to update in the GTRs,
           this is an ongoing issue within the Westinghouse
           Owners Group as to how much we should do in that area. 
           Right now we have asked Westinghouse that any time
           something new comes up to put it in the folder related
           to that GTR.
                       And if those issues become big enough, or
           value enough at some time in the future we may say,
           yes, it is time to do another revision.  And would we
           take that revision through the NRC to get an augmented
           SER on it, or would we just publish it, those are all
           items down the road that we would decide what is worth
                       And maybe it would be a joint decision
           between us and the NRC as to whether it is worth doing
           or not.  But those are things that are -- I am just
           making sure that we do maintain this.
                       And if something does come up, we try to
           make sure that our members are aware of what it is so
           that they can factor it in to their reviews.  So, this
           is not a finished product, and the report is well-
           defined, but just the management of the issue for the
           long term, and we plan to keep our eye on each of
           those areas as part of our responsibility to our
                       CHAIRMAN BONACA:  Thank you.
                       DR. DUDLEY:  I did have a chance to go
           through and identify those items that were raised and
           that the staff may want to speak to next week.
                       CHAIRMAN BONACA:  And they are?
                       DR. DUDLEY:  The concern about the
           proximity of the RT PTS to the screening criteria;
           retention of corporate knowledge in the engineering
           training program.
                       MR. AULUCK:  This is for the engineering
           personnel preparing the application; is that what you
           are talking about?
                       DR. ROSEN:  Well, yes.  And how also that
           information is transferred to the ongoing staff once
           the license renewal is approved.
                       DR. DUDLEY:  Also, clarifying how the
           committee's recommendations about using EOPs in the
           screening process and how that has been worked into
           the guidance.
                       MR. KOENICK:  Noel, we need to go back. 
           I know that we have talked about that at past
           meetings, and we may have written you a letter on
           that, because the main thing was in deciding the scope
           the primary path to maintain safety, that is defined
           by your safety related equipment.
                       And the EOPs include that safety related
           equipment that you rely upon for success.  But then it
           goes on and credits additional means to achieve, more
           or less like second or third ways of achieving that.
                       And it may rely on equipment that is not
           safety related, and it gives them other options.  But
           the scope of the rule is set up to ensure that we wold
           have a path, a guaranteed path more or less to achieve
           that safe condition.
                       And so we are trying to maintain that
           current licensing basis and to ensure that that path
           will be there.  And the EOPs were included as a
           reference document, along with others, as a source
           that if you feel that is a good place to go to get
           information, and to double-check your other screening
           and scoping type of stuff that you have done, it is a
           possible source document.
                       But it is not a requirement that
           everything that is included in the EOPs being in the
           scope of a license renewal.
                       CHAIRMAN BONACA:  And right now it is a
           source document, and which the answer is not as
           written which is in the EOP is going to be in the
           scope of license renewal.
                       MR. KOENICK:  Correct, and doesn't need to
                       CHAIRMAN BONACA:  But the EOPs we are
           looking at because we wanted to make sure that you
           would find some piece of equipment very important to
           safety that had been otherwise not considered, just
           like you look at the TLAAs and VIPs.
                       MR. HALE:  Just for my own benefit, are
           these items being characterized as an issue with the
           Turkey Point application?
                       CHAIRMAN BONACA:  This one?
                       MR. HALE:  No, just any of these that --
                       CHAIRMAN BONACA:  No.
                       MR. HALE:  So these are just recommended
                       CHAIRMAN BONACA:  With the EOPS, we have
           recommended them before, and the staff came back and
           said that they considered them.  And we debated within
           this committee whether we wanted to go all the way to
           the Commission and ask for a change to the rule, and
           we decided that it was not appropriate.  
                       And as far as training, again it is a way
           for us to learn a little bit what is happening, and it
           is a good question for the staff of utilities, who is
           likely to ask that question again.
                       MR. HALE:  But the item is for the staff
           to be looking at applicant training.
                       DR. ROSEN:  And maybe somebody would walk
           the copy down to INPO at some point.
                       MR. AULUCK:  But the question does not
           relate to qualification of engineering personnel at
           Turkey Point, or their training, or imparting
           knowledge to other plant or site personnel at Turkey
           Point, right?
                       CHAIRMAN BONACA:  No.
                       MR. AULUCK:  It is a generic question.
                       CHAIRMAN BONACA:  That's correct.
                       MR. NEWTON:  Can I comment on both items? 
           Again, my name is Roger Newton, and one of my earlier
           hats in the Westinghouse Owners Group was I was the
           first chairman for the group that developed the
           emergency operator response guidelines, which the EOPs
           are derived from.
                       A few have studied those guidelines and
           they deal with the accidents, and the design basis
           accidents, but they also deal with multiple accidents
           so far down the probability chain, and they go into
           the plant and say is there anything available that
           could deal with those.
                       So when you go down the risk aspects of
           what you may be using, it is pretty far down the risk
           chain of some of these things that the EOPs or the
           ERGs call on.
                       So that was one aspect that -- and when we
           talked about trying to eliminate things from a risk
           standpoint and the license renewal rule, the NRC threw
           it out.  That was primarily the concern over where the
           emergency operator procedures may go.
                       And the other aspect was that the
           maintenance rule did include the EOPs from a
           maintenance reliability standpoint, and properly
           relates them of risk in the maintenance rule.
                       So I think the NRC felt that the EOPs were
           adequately covered in the maintenance rule, but it was
           something that the license renewal did not have to
           address, just like active components.
                       So that was kind of evaluated and whether
           it should be in the scope of license renewal, and that
           was talked about and at that time judged to be already
           covered adequately.
                       DR. ROSEN:  Now that you say that again,
           Roger, I remember that is what the staff presenter
           said, that he thought that the maintenance rule
           covered that adequately, and that may be all you have
           to say.
                       CHAIRMAN BONACA:  The reason why we raised
           the issue was because the concern we had was that you
           may have a component, like a pump, and the maintenance
           rule says it is important, and therefore, you are
           looking at the active component under the maintenance
                       MR. NEWTON:  Well, the maintenance rule
           looks at the performance of whatever it is intended to
           do from an active standpoint.  Does it supply
           electricity, or water, or whatever it may be way down
           the road.
                       So it covers both the active components,
           as well as what is needed to support getting it there,
           too.  The second item, Steve, that I would like to
           address is the ESP program.
                       The ESP program is the training of
           engineering support personnel for your current
           licensing basis.  And in your current licensing basis,
           does that include license renewal, or the aging
           effects of the plant includes everything else.
                       I would expect that once a plant gets a
           renewed license, and he has to manage the license
           renewal and the requirements for the long term under
           this new license, what he will have to do on how to
           manage that will be rolled into the ESP programs at
           that time.
                       But to do it now wouldn't make sense
           because there is no regulatory requirement to address
                       DR. ROSEN:  Well, I agree a hundred
           percent with the timing, but my point was that I fully
           expect Turkey Point's license will be amended to
           provide them with an extended period of operation.  I
           don't think that is much in doubt.
                       And so they night as well get on with
           working on what they do to the ESP at this point, and
           also communicate to INPO that ESP guidance documents
           ought to include another bullet under the engineering
           support personnel training program that says for
           plants that have obtained license renewal, and here
           are the things that they should add to this program.
                       MR. NEWTON:  For example, when you make
           mods to the plants now, you have checks for fire
           protection, and for EQ, and for everything.  There is
           likely to be a check for is this important to license
           renewal.  It does make sense to put that into Turkey
           Point now, but once they get their license, it should
           be there, and ESP should cover that.
                       DR. ROSEN:  Right. I agree with that.
                       CHAIRMAN BONACA:  All right.
                       DR. DUDLEY:  There are two or three more
           items that I would like to throw out as possible
           discussions.  One was Dr. Ford's concern about
           multiple inspections, depending on variables such as
           crack growth, where there is no data available.
                       DR. FORD:  There may well be data
           available, but not clearly relevant.
                       MR. KOENICK:  Are you asking us to address
           that at the next meeting?
                       DR. FORD:  No, I don't think so.
                       CHAIRMAN BONACA:  Well, you can raise the
           issue again, but to ask the staff to address it, we
           will have to ask for some formal --
                       DR. FORD:  No, I am not asking for that. 
           My opinion about this application has not changed. 
           It's fine.  It's just that from a systemic point of
           view, I would like to see a brighter picture.
                       CHAIRMAN BONACA:  I think it would be
           important that you raise the issue again at the full
           committee, and it is an issue that you have to bring
           up if you feel concerned about that, but I don't think
           the staff should address it out of the blue as part of
           the license application, and I don't think that is
           appropriate, because it would single out the
           application as one that has these issues, and that is
           not the case.
                       MR. AULUCK:  And to keep the focus on the
                       DR. DUDLEY:  There was Dr. Shack's issue
           about the VT1 for PWRs and the acceptability of that.
                       CHAIRMAN BONACA:  It is important because
           this has not to do with the application, but with the
                       MR. KOENICK:  What I understood that to be
           was that the SER wasn't clear.
                       DR. SHACK:  The SER accepted it, and I can
           understand accepting the license renewal application
           because again they are going to do UT and it doesn't
           really matter too much whether the VT1 is effective or
           not.  The UT is really the thing that is going to do
           the job.
                       I didn't like the SER because there was no
           reservation there that VT1 without some enhancement
           would be able to in fact protect cracking, which is
           the case that you have always made in accepting the
           BWR VIP documents, for example.
                       MR. KOENICK:  So it sounds like we need to
           clarify the SER.
                       DR. SHACK:  Yes, and I have no problem
           with the application.
                       MR. KOENICK:  We just need to address what
           we are going to do with the SER.
                       CHAIRMAN BONACA:  We don't need a
           presentation on that.
                       DR. SHACK:  Well, one of you may need to
           address it next week.
                       MR. COUCH:  Well, we will go back and look
           at the SER write-up, and take it as an action to go
           and look at the SER write-up to make sure that it is
           clear that we are crediting the UT.
                       MR. AULUCK:  And that can be done at the
           final SER, but not for next week.
                       DR. DUDLEY:  And then next week a
           presentation on the open items, with emphasis on the
           two over one.
                       CHAIRMAN BONACA:  Now, I think what we
           would like to do now is we should have a presentation
           by the staff, including also a brief presentation on
           the four WOGs reports, and then I will have maybe 15
           minutes in which to provide a presentation to the full
           committee on the reason why we are recommending that
           we don't have a letter at this time, and that it is
           the conclusion of this subcommittee that it is a good
           application, and we will plan to write a report.
                       All right. I think we have it.  Any other
           comments by the members or suggestions for next week's
           meeting?  If not, any other comments from the staff or
                       MR. AULUCK:  I have a comment.  On the
           engineering staff training of personnel, and the EOPs,
           since we already talked about that, do you still want
           us to cover that next week?
                       DR. ROSEN:  You can talk to Galletti, and
           he knows about it.
                       CHAIRMAN BONACA:  I think you can mention
           that since a member of the subcommittee raised the
           issue, EOPs are utilized solely as a source of
           information and state the facts.  So if there are no
           other comments or questions, we will adjourn the
           meeting now.
                       (Whereupon, the meeting was recessed at
           4:20 p.m.)


Page Last Reviewed/Updated Tuesday, August 16, 2016