ML15160A189
| ML15160A189 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/09/2015 |
| From: | State of NY, Office of the Attorney General |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 27908, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR | |
| Download: ML15160A189 (121) | |
Text
NYS000492 Submitted: June 9, 2015 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BRIEFING ON SUBSEQUENT LICENSE RENEWAL
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THURSDAY MAY 8, 2014
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ROCKVILLE, MARYLAND
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The Commission met at the Nuclear Regulatory Commission, One White Flint North, Commissioners Hearing Room, 11545 Rockville Pike, at 9:00 a.m., Allison M. Macfarlane, Chairman, presiding.
COMMISSION MEMBERS:
ALLISON M. MACFARLANE, Chairman KRISTINE L. SVINICKI, Commissioner GEORGE APOSTOLAKIS, Commissioner WILLIAM D. MAGWOOD, IV, Commissioner WILLIAM C. OSTENDORFF, Commissioner
2 1 EXTERNAL PANEL:
2 RICHARD A. REISTER, Department of Energy 3 SHERRY L. BERNHOFT, Electric Power Research Institute 4 MICHAEL P. GALLAGHER, Exelon 5 CHRISTOPHER E. EARLS, Nuclear Energy Institute 6 DAVID LOCHBAUM, Union of Concerned Scientists 7
8 NRC STAFF PANEL:
9 MARK SATORIUS, Executive Director for Operations 10 JOHN LUBINSKI, Director, Division of License Renewal, Office 11 of Nuclear Reactor Regulation 12 BO M. PHAM, Branch Chief, Division of License Renewal, 13 Subsequent Renewal, Guidance and Operations 14 Branch, NRR 15 MIRELA GAVRILAS, Branch Chief, Division of Engineering, 16 Corrosion and Metallurgy Branch, Office of Nuclear 17 Regulatory Research 18 19 20 21 22 23 24 25 26
3 1 P-R-O-C-E-E-D-I-N-G-S 2 (9:02 a.m.)
3 CHAIRMAN MACFARLANE: Is everybody ready?
4 I'd like to welcome the staff, the industry, the Department of Energy, 5 members of the public who are here for today's meeting. The focus of 6 the meeting today is the area of what we call subsequent license 7 renewal and sometimes it's referred to as life beyond 60.
8 In 1991, the NRC established regulations at 10 CFR 9 Part 54 for license renewal and amended those regulations in 1995.
10 Since that time the staff has issued 73 license renewals and there are 11 another 19 units currently under review. We now have 20 units 12 operating in their period of what we call extended operation.
13 The regulations currently permit the possibility of 14 additional license extensions, and some licensees are actively 15 evaluating this option. The NRC staff, the Department of Energy, and 16 industry are actively researching the aging related issues associated 17 with operating nuclear power plants beyond 60 years.
18 Today the Commission is going to be briefed by two 19 panels. First we'll hear from an external panel, the folks seated here, 20 including Mr. Richard Reister from the Department of Energy, Ms.
21 Sherry Bernhoft from the Electric Power Research Institute, Mr. Michael 22 Gallagher from Exelon, Mr. Christopher Earls from the Nuclear Energy 23 Institute, and Mr. David Lochbaum from the Union of Concerned 24 Scientists.
25 This will be followed by a staff panel discussion of how 26 the staff is preparing for handling applications for second license
4 1 renewals. I look forward to both presentations, the set presentations 2 and our discussion from the Commission, but first let me ask my fellow 3 Commissioners if anybody would like to make any comments. No?
4 Okay, great.
5 In that case I think we'll start with the external 6 panelists. We'll start with Mr. Reister from the Department of Energy.
7 MR. REISTER: Good morning. Thank you for 8 inviting me here today to discuss the Department of Energy Office of 9 Nuclear Energy's program on Light Water Reactor Sustainability.
10 The LWRS program began in 2009 with the recognition 11 that the U.S. government had a strategic interest in supporting the long 12 term operation of our existing fleet of nuclear power plants in support of 13 energy security, climate change objectives and to help avoid or at least 14 defer the high cost of building replacement capacity.
15 The program supports the President's all of the above 16 energy strategy and climate action plan. The LWRS program 17 conducts research that is generally longer term, higher risk than what 18 industry typically performs.
19 Along with material issues, typically a focus of 20 licensing, the LWRS program addresses the long term viability or 21 economics of continued plant operation. We believe that this federal 22 government program, by reducing uncertainty, helps to create an 23 environment for industry to make the long term investments necessary 24 to keep these plants operating safely and efficiently. Next slide, 25 please.
26 This graph illustrates the current and projected
5 1 capacity of existing nuclear power plants with 40- and 60-year licenses.
2 Assuming all plants received 60-year licenses, the slope of retirements 3 is very steep at about five plants per year in 2030 to 2035.
4 The rate of retirements that would occur without 5 subsequent license renewal would clearly present a significant 6 challenge to both our electricity supply infrastructure and our goal to 7 reduce carbon emissions.
8 The LWRS research program has three main focus 9 areas, materials aging and degradation; advanced instrumentation, 10 information, and control systems technologies; and risk-informed safety 11 margin characterization. I will cover each of these three areas in a little 12 bit more detail.
13 As plants age, the degradation of materials will 14 continue to occur. Our research is focused on being proactive by 15 conducting research on relevant materials. This includes materials 16 harvested from plants and materials that undergo accelerated aging.
17 When possible, mechanistic aging models are developed and 18 validated.
19 The results of our research are used by industry and 20 the regulators to inform and update their aging management programs.
21 More than half of our research funds are devoted to materials research.
22 For materials degradation issues we cover these five 23 elements, the collection of high quality data on observed degradation, 24 again from both the laboratory with accelerated degradation and from 25 materials harvested from operating plants; determining the underlying 26 physical phenomena causing the degradation; development of
6 1 mechanistic models based on the physical mechanisms rather than just 2 empirical trends; developing improved monitoring techniques by taking 3 advantage of new sensors and advanced data analysis techniques; and 4 investigating mitigation strategies to limit degradation. And, if needed, 5 economical repair or replacement with materials less susceptible to 6 degradation.
7 These are the materials and degradation mechanisms 8 we are focused on. The list and prioritization were developed from our 9 support and involvement in the development of the expanded materials 10 degradation assessment, a joint project with NRC's Office of Nuclear 11 Regulatory Research and with industry input.
12 Metals degradation remains a high priority research 13 area, including irradiation-assisted stress corrosion cracking; phase 14 transformations and swelling of core internals; embrittlement of the 15 reactor pressure vessel; cracking of nickel-based alloys; high 16 temperature effects on the aging of cast stainless steels; and the effects 17 of environmental conditions on the fatigue resistance of materials.
18 Concrete and cables aging in unique nuclear 19 environments for long term operation are fairly new research areas.
20 This work is needed to gain confidence in the expected performance of 21 these materials under extended service.
22 Finally, we are working with industry on advanced 23 repair and replacement technologies including weld repair of core 24 internals and advanced non-destructive examination techniques that 25 can help improve our ability to detect and understand existing 26 degradation. This research is closely coordinated with both the
7 1 Electric Power Research Institute using joint research plans and with 2 the NRC's Office of Nuclear Regulatory Research.
3 Our instrumentation, information, and control systems 4 research helps address the aging and reliability concerns of existing, 5 mostly analog, instrumentation and control systems still in use today.
6 We are conducting research with industry through a 7 series of pilot projects to develop and implement technologies needed 8 as part of a long term modernization strategy. The desired outcome of 9 the research is to facilitate the transition of nuclear power industry from 10 one that is labor-intensive and that still relies on analog I&C 11 technologies to one in which human performance is highly effective, 12 leveraging digital technologies that will be familiar to our future work 13 force.
14 And our third area is research on risk-informed safety 15 margin characterization and supports a methodology to better 16 understand plant safety margins. A better understanding of how plant 17 safety margins are changing, for example, with plant changes such as 18 power upgrades or with aging effects, would be helpful for decisions on 19 plant investments.
20 The methodology uses deterministic simulation of a 21 plant with probabilities used for various scenario events in a Monte 22 Carlo style analysis. This results in a distribution of outcomes.
23 A set of tools are being developed that we hope will make this 24 methodology practical for use by industry, and they're listed on the 25 slides. RELAP-7, a thermal hydraulics code, RAVEN is a simulation 26 controller, and an aging simulation model we call Grizzly.
8 1 Specific to long term operation we are looking at aging 2 cycles such as irradiation, thermal stresses, and fatigue to better 3 understand how they influence plant safety margins.
4 In summary, DOE research is focused on supporting 5 continued safe and economic operation. We are proactively focusing 6 on degradation that might occur beyond 60 years of operation. Our 7 research has not yet identified any technical showstoppers to long term 8 operation.
9 We are developing improved materials monitoring 10 techniques that will help detect degradation earlier should it occur. We 11 work with industry and the regulator so that our research results can be 12 used to update and enhance aging management programs. Thank 13 you.
14 CHAIRMAN MACFARLANE: Thank you.
15 Ms. Bernhoft?
16 MS. BERNHOFT: Yes, thank you for inviting me this 17 morning. I'm very happy to have the opportunity to share a brief 18 background on the research that EPRI's been doing to support long 19 term operations.
20 As a tee up, the EPRI Long Term Operations Program 21 has been in existence since 2009 and it has two purposes. One is, our 22 first purpose is to provide information for the plant owners that are faced 23 with evaluating a decision whether to extend their operating license or 24 not, and second is we want to ensure that we have confidence that all 25 the research is being performed in a timely manner to support these 26 decisions for long term operations of the fleet of plants. Next
9 1 overhead.
2 So aging management programs are well established 3 and successfully being used today to inspect, evaluate, and as 4 necessary take corrective actions based on inspection findings. This 5 overhead lists some of the aspects of aging management programs 6 where R&D plays a critical role.
7 As we'll present in the next few overheads, we have 8 living issue programs that have been performing research in all these 9 areas for several decades. Based on this wealth of knowledge, we 10 have a good understanding of aging mechanisms, inspection 11 technologies, and have performed evaluations and assessments based 12 on these inspection results.
13 This work is documented in EPRI technical 14 publications, many of which are referenced by the U.S. NRC in GALL 15 rev 2 as the acceptable method for aging management programs.
16 Next overhead, please.
17 The left hand column shows the high level summary of 18 some of the aging impacts that are included and have been identified in 19 our research projects. The right hand column shows the highest 20 priority components for consideration for long term operations. These 21 are considered the highest priority, since the cost to repair or replace 22 these components could be significant.
23 Last year we completed a project within EPRI that 24 mapped the existing EPRI research programs to the aging 25 management programs in the GALL rev 2. We did this as a parity 26 check to ensure that the research programs and plans that we have in
10 1 place right now are complete and on our target.
2 From this effort we concluded that all the necessary 3 research has been identified and is in place to support aging 4 management programs for continued safe long term operations. In the 5 next few areas I'm going to touch briefly on these four high priority 6 research areas. Next overhead, please.
7 Before starting into some of the details on the metals 8 research, I'd like to highlight how as an industry we manage RCS 9 metals. In 2004, the industry formally established what they called NEI 10 Initiative 03-08.
11 This was implemented at the coming together of 12 several of the industry executives to put together a standard or a 13 template of an overarching, industry-led management strategy. Some 14 of the aspects of it are the requirements for inspection, evaluation and 15 repairs; documentation and reporting of inspection results; sharing of 16 the operating experience; and routine reports to the NRC.
17 EPRI also has a formal process called the Materials 18 Degradation Matrix, or the MDM, and the Issue Management Table that 19 we use to identify research for aging mechanisms and prioritize those.
20 These documents were used, as Mr. Reister talked 21 about the EMDA, they were some of the source documents that were 22 used for development of the EMDA. They are living documents.
23 They are updated routinely based on expert solicitation, operating 24 experience, inspection findings, and research results. Next slide, 25 please.
26 These are some of the action plans or the issue
11 1 management programs that are all managed under the NEI Initiative 2 03-08. It shows that we have several programs in PWR, BWR steam 3 generators, basic corrosion research, water chemistry, and we also 4 have the engagement of the major Entrepolis vendors -- the PWR 5 Owner's Group, and then the GE is involved through BWR VIP 6 program. Next overhead, please.
7 In the area of primary metals there is decades of 8 ongoing research that has been established to manage aging effects 9 such as understanding initiation of flaws, flaw growth rates, inspection 10 and monitoring methods, mitigation strategies, and repairs. This R&D 11 is driven by these living issue programs that I talked about on the 12 previous overhead, and the research results are routinely shared in 13 technical presentations and publications.
14 Specific to the reactor pressure vessel, the material 15 properties of the reactor pressure vessel are assessed through periodic 16 removal and testing of surveillance capsules to establish trend 17 correlations. There is an existing surveillance data out to 80 years of 18 operations, and actions are in place to generate additional exposure 19 data by using previously tested specimens, and reintroducing capsules 20 into host reactors increase this database and improve the trend 21 correlations out to the long term operations time frame. This data will 22 be used to support and supplement our existing database.
23 Additionally, as Mr. Reister discussed, EPRI works in 24 close coordination and communication with DOE in all the RCS metals 25 areas and just materials aging in general. Next overhead, please.
26 Another area of focus for high priority research was
12 1 with electrical cables. Similar to the situation with metals, EPRI has 2 been conducting research for greater than 25 years to better 3 understand cable insulation material aging and possible degradation 4 mechanisms. Several publications and technical presentations have 5 been made in the area of cable aging management, inspections, and 6 monitoring.
7 The primary purpose of the EPRI projects are to 8 support the utility members for making informed decisions on cable 9 management program implementation and look for possible cable 10 replacements or additional monitoring methods to support long-term 11 operations. Working closely with the DOE Light Water Reactor 12 Sustainability Program and NRC Research we have a very detailed 13 road map that talks about the research activities that are still ongoing to 14 collect additional information on thermally and radiation aged cables, 15 cables in submerged environments, and develop improved cable 16 testing and condition monitoring techniques.
17 We also have a very well established cable users 18 group which meets twice a year to share operating experience and 19 research results. Next overhead, please.
20 The other area of interest for long term operations, 21 primary area, is in the concrete. EPRI has established an R&D 22 working group in the area of concrete, and this is to help inform the 23 members of operating experience and research results.
24 Based on existing literature and information obtained 25 from international test programs on concrete radiation exposure, there 26 is data available on concrete mechanistic properties when exposed to
13 1 radiation levels expected to occur out to 80 years of operation at the 2 biological shield wall and reactor support structures.
3 This data shows no appreciable deformation with 4 respect to compressive strength or expected radiation levels out to 80 5 years of operations. The next step in our research plan, working 6 closely with the DOE program, is testing to verify the concrete 7 mechanical properties at the far end of the curve for the higher fluence 8 and bounding plant levels.
9 We are also in the second of a three-year program to 10 model the impacts of boric acid on spent fuel pool structures and we're 11 developing techniques for improved surface and below surface 12 inspection and monitoring of concrete structures. Next slide, please.
13 So in summary, the technical basis for aging 14 management is well established and in use. The use of aging 15 management programs will ensure detection of aging effects, provide 16 the technical basis for evaluation, and as needed, corrective actions.
17 The EPRI R&D programs discussed today are parts of 18 living programs. We work with our members to gather operating 19 experience, inspection results, and update the technical reports based 20 on this information and the research results.
21 Continuous improvements for long term operations is a 22 significant part of our research plans and closely coordinated with the 23 DOE. Some of these efforts are better modeling of the degradation, 24 improved inspection technology, advances in our assessment and 25 evaluation methodology, and online monitoring. Thank you for your 26 time today.
14 1 CHAIRMAN MACFARLANE: Thank you.
2 Mr. Gallagher?
3 MR. GALLAGHER: Okay, good morning. And 4 thanks for this opportunity to express views for myself and the industry 5 on this important topic.
6 Just a little bit of background about myself first. I've 7 been in the industry for 33 years, for my whole career. I've been doing 8 Exelon's license renewal projects since 2006, and previously before 9 that I had a senior reactor operator license at our Limerick Generating 10 Station and was the plant manager there for a period of time.
11 So first of all, just expressing the industry's interest in 12 subsequent license renewal, we are very interested in subsequent 13 license renewal. And the main reason is, if you can go to Slide 2, is 14 because our nuclear plants are very beneficial to our nation. We think 15 they're important national assets. They're important to our nation, our 16 community, and our customers.
17 And to get that message across, recently we've 18 embarked on a campaign to give our perspective on the value of our 19 nuclear plants to our nation. This is an industry initiative, and we call 20 this campaign, Nuclear Matters. And I believe these key points are 21 valid not only for now, but also for why subsequent license renewals 22 should be pursued.
23 So first of all, there's some unique aspects for our 24 nuclear power plants, and again they are national assets. The first is, 25 always-on reliability. So the reliability of the electric grid depends on 26 nuclear energy.
15 1 One-fifth of our nation's power is generated using 2 nuclear power. Nuclear energy plants maintain national average 3 reliability between 85 and 90 percent, and many power plants routinely 4 operate in a 93-95 percent capacity over extended periods of time.
5 The loss of nuclear energy plants would have major impacts on electric 6 prices, greater liability, and access to dependable energy for our nation.
7 Another key benefit as Mr. Reister talked about is our 8 carbon-free electricity. So nuclear energy facilities are among the 9 cleanest sources of electricity available. They produce virtually no 10 carbon dioxide or air pollution.
11 Nuclear energy produces more clean-air energy than 12 all other sources combined, and is the only one that can produce large 13 amounts of electricity around the clock, 365 days a year. Nuclear 14 accounted for 64 percent of America's clean energy in 2012, and 15 existing nuclear plants prevented 561 million metric tons of carbon 16 dioxide emissions in 2012, and that's equal to about 110 million 17 automobiles.
18 Those same plants also prevented one million short 19 tons of sulfur dioxide which contributes to acid rain, and a half million 20 short tons of nitric oxide which causes urban smog. So without 21 nuclear energy, the United States cannot meet its clean energy or 22 carbon reduction goals.
23 And lastly, our nuclear plants are very important to our 24 economy. They are economic engines in our communities. Nuclear 25 production costs were among the lowest of all around-the-clock 26 generating sources at 2. cents per kilowatt hour, and by comparison,
16 1 coal is about 3.27 cents per kilowatt hour, natural gas 3.4.
2 So in fact, the average production costs for nuclear 3 energy has remained well below three cents a kilowatt hour for the past 4 18 years. The supply of reliable, resilient, and affordable energy helps 5 power America's economy.
6 Nuclear plants generate substantial domestic 7 economic value in electric sales, $40-50 billion each year, and provide 8 100,000 well-paying jobs in the United States. These jobs pay on the 9 average 36 percent above prevailing local wages and more than any 10 other generating source of equivalent size.
11 Nuclear plants procure $14 billion of goods and 12 services from over 22,000 domestic vendors annually, and they 13 contribute $8.3 billion through local, state, and federal taxes. So the 14 individual plants are major economic engines for the communities in 15 which they operate. The typical U.S. nuclear plant has an average 16 annual payroll of $40 million, and it generates about $470 million a year 17 in sales of goods and services and pays $16 million in local and state 18 taxes that benefit schools, roads, parks, and other infrastructure.
19 So we really believe that our nuclear fleet is very 20 important to the nation, and for that reason subsequent license renewal 21 is very important. If you go to Slide 3. Because these assets are so 22 important, it is so important for us to get this right.
23 And I just want to give some of our perspective on what 24 we believe is doing it right. And the first is we must continue to operate 25 the plant safely. That's our responsibility. That's a given. We 26 understand our responsibility to ensure the health and safety of the
17 1 public, and we will continue to operate in this manner throughout the 2 period of extended operation and the subsequent periods of extended 3 operation.
4 The next key point I have here is about regulatory 5 stability, so this is essential. Our belief is that the existing rule is 6 comprehensive. It accommodates subsequent license renewal. It's 7 proven, and we can continue with it moving forward. And this is 8 essential for us that we have the regulatory stability.
9 If you go to Slide 4, another aspect for success would 10 be to accommodate the lead times for energy planning. We need lead 11 times for the energy planning, but also lead time for rigorous application 12 development, the thorough reviews from the NRC staff, and enough 13 time for final NRC decisions well before any license terms expire.
14 And if you look at the license renewal application lead 15 times for this round of license renewals, as the Chairman said there's 16 73 licenses that have been approved, this chart here shows the 17 application submittals prior to expiration, and on average of about 13 18 years before expiration for the first renewals.
19 But you can see the range there going from around 20 five, which is the time for timely renewal, to even greater than 20 for 21 some folks, and that's based on their business planning and business 22 needs of that particular applicant.
23 If you go to the next slide, Slide 5, so because the 24 process is proven and so mature, you know, we think we should build 25 off the success of the first license renewals for subsequent license 26 renewal. You know, aging management is a continuum. We don't
18 1 see any cliffs in aging management. And we already have a lot of 2 experience in managing the aging of our plants.
3 Yes, we're in a period of extended operation for 20 4 plants for five years, but we have over 45 years of aging management 5 experience as many of the programs that we implement were existing 6 programs. Existing programs that in some cases were enhanced, but 7 in some cases were in place fully before any license renewals were 8 developed.
9 And the license renewal implementation guidance is 10 thorough and has been frequently updated. Aging management has 11 improved with operating experience and ongoing research, as Ms.
12 Bernhoft and Mr. Reister indicated, and so we think we should continue 13 to build on the over 45 years of industry aging management experience.
14 And finally, I'll just close with Slide 6. It's just a 15 pictorial depiction of how aging management programs are developed 16 and maintained. And, you know, the beauty of this particular rule and 17 process is that it incorporates corrective action program and operating 18 experience to provide that feedback loop to continue to ensure that we 19 have the right aging management programs in place and that can 20 continue on into subsequent license renewal. So thanks again for this 21 opportunity.
22 CHAIRMAN MACFARLANE: Mr. Earls?
23 MR. EARLS: Thank you very much. I would also like 24 to express my thanks for the opportunity to address you today on this 25 very important topic.
26 As Rich and Sherry have mentioned, there's been
19 1 extensive R&D efforts ongoing and will continue in the future. Mike's 2 expressed the interest in the industry in moving forward in this area, in 3 particular subsequent license renewal.
4 What I'd like to focus in on is the SECY that was 5 recently released by the staff on the ongoing staff activities to assess 6 the regulatory considerations of the power reactor subsequent license 7 renewal. Next slide, please.
8 I think, before we get into talking about the specifics of 9 the proposed rulemaking and options, I think it's important to revisit two 10 of the key guiding principles that the Commission established back in 11 1991 around the license renewal. I'm going to go ahead and read 12 those.
13 The first is, the current regulatory process is adequate 14 to ensure that the licensing basis of all operating plants provides and 15 maintains an acceptable level of safety so that operation will not be 16 detrimental to public health and safety or common defense and 17 security.
18 And secondly, each plant's licensing basis is required 19 to be maintained during renewal term in the same manner and to the 20 same extent as during the original licensing term. These are two very 21 key principles that guide the license renewal.
22 And I think as we go through the examples today we 23 should keep those in mind. The Commission back in 1991 recognized 24 the ongoing efforts that occurred on a daily basis with oversight and 25 interaction between the regulator and the licensee, and deemed those 26 activities to be sufficient to cover the normal operation period.
20 1 And that enabled the rule to be focused more, and 2 more focused on the period of extended operation, in particular with the 3 aging management programs in that time period and any other specific 4 issues that may be specific to an extended period of operation. Next 5 slide, please.
6 Before I discuss the various conclusions of the staff, I'd 7 like to express and applaud the efforts of the staff in reviewing the 8 experiences with the first go-around in license renewal. The staff has 9 conducted many public meetings soliciting feedback from the public on 10 those lessons learned, that they've expressed a willingness to accept 11 feedback.
12 They've conducted many, several audits at plants that 13 are in the period of extended operation to assess how well the aging 14 management programs are established and maintained, and 15 throughout these efforts they've gained a good appreciation for how 16 well the license renewal process has worked.
17 So in the first recommendation or conclusion that we 18 would strongly support is that the program worked well. I mean, as 19 you mentioned earlier, 73 plants have been through the process. No 20 significant issues have arisen. The process, the rule works very well, 21 and we feel that it will work well going forward.
22 The next conclusion was that the environmental issues 23 are sufficiently covered. We agree with that as well. We think that 24 process provides a good opportunity to review those issues, and in fact 25 the guidance surrounding that was just recently revised last year.
26 With regards to the conclusion on some of the
21 1 guidance and guiding documents, specifically the GALL, we also 2 support those efforts to review those documents with a view towards 3 subsequent license renewal. And in fact the industry has stood up a 4 group of folks to help provide input to the staff on those revisions to try 5 to reflect our understandings in a current situation and make sure that 6 we've got those incorporated in, and we support those efforts.
7 And then finally we support the conclusion that the staff came 8 to with regards to the use of PRA. PRA does not have a specific 9 application in subsequent license renewal. While we believe it's 10 important and continue to work with the staff in trying to identify ways to 11 better use it, we don't believe it's specific to subsequent license renewal 12 and would support the staff's conclusion on that. Next slide, please.
13 We do have some concerns with the staff's interest in 14 pursuing rulemaking. We believe that no significant safety issues 15 have been identified. No significant problems with the process have 16 been identified.
17 And as a result we think this rulemaking would be a 18 very low priority considering all the other activities that are going on 19 right now. And so we believe pursuing rulemaking in this area would 20 be inconsistent with the efforts to focus on the cumulative impacts on 21 the industry.
22 The staff has indicated that this rulemaking would 23 make the process more efficient. We don't quite understand that.
24 There's been no evidence to support that, and in fact we think a 25 rulemaking at this time might actually complicate the situation and 26 certainly would delay the application, the submittal of an application.
22 1 So that's another aspect to consider. Next slide, please.
2 I'm not going to spend a lot of time on this slide. This 3 basically summarizes the various options. Option 1 is no change.
4 Options 2 and 3 and 4 build upon each other and go from minor 5 changes to more extensive changes. Each successive step 6 subsumes the previous one, so Option 4 would include the items in 7 Options 2 and 3. Next slide, please.
8 Option 1. Option 1 is the no rulemaking option. We 9 strongly support this option. As we've stated, the process has served 10 us well. This process was set up with the intent of being repeatable.
11 It had subsequent license renewal in mind when it was 12 put together. There was no limitation on the number of times renewal 13 could be pursued. And so we think that's an important aspect of this.
14 As stated by Sherry and Rich, we have R&D in place 15 that's providing the technical background for what we're doing. The 16 regulatory processes that we rely on during operations continue to be in 17 place and continue to be sound, and for these reasons we think Option 18 1 is the right option to pursue in addition or along with some changes to 19 guidance to strengthen the program in that area. Next slide, please.
20 Options 2 and 3 are pretty minor in nature. Option 2 is 21 really almost just editorial in nature, and in fact the staff recognized that 22 with the statement that the changes alone may not warrant resource 23 allocation to conduct the rulemaking. We would agree with that. We 24 think they're sufficiently covered now and would not require rulemaking.
25 Timely renewal. We think this is a very unusual or 26 does not occur very often. We've only had one circumstance where
23 1 it's occurred, and the staff and the licensee worked together to deal with 2 that situation in a very good way. They were able to make the 3 transition and maintain the focus on safety and will be able to transition 4 into the license renewal period once we get through the waste 5 confidence rule. With regards to the additional pieces of equipment for 6 scoping, we identified two areas. The loss of large areas or B.5.b or 7 aircraft impact, whatever you think of it as, and the FLEX equipment 8 associated with our response to Fukushima.
9 We believe these classes of equipment should be 10 treated in a manner similar to EP and take reliance on the activities that 11 are in place or will be in place to monitor this equipment and to inspect it 12 on an ongoing basis.
13 We also think if these systems were incorporated that 14 they would have only a minor impact on the scoping because they do 15 not have a lot of passive equipment associated with them. Next slide, 16 please.
17 This is Option 4, and I think this is the crux of the staff's 18 interest in rulemaking and that has to do with the monitoring and 19 trending and assessment activities of the aging management programs 20 and operating experience.
21 We believe that there's sufficient rule language and 22 guidance out there. We are pursuing these. I'll be glad in the Q&A 23 session to describe a specific example of how we deal with an aging 24 management program and provide assessment and feedback.
25 And so we don't believe this would warrant a 26 rulemaking in and of itself. We think guidance can handle it, and in fact
24 1 the industry is working on a couple of efforts to strengthen guidance in 2 this area. Next slide.
3 Limit the time on subsequent license rule. I won't 4 spend a lot of time on that. We don't think the situation has changed 5 since the original rulemaking in this area, and we do not believe that we 6 should reduce the time frame for which an application can be filed.
7 Next slide, please.
8 Final piece of Option 4 with regards to the design 9 parameters, we think this is out of step with the principles of the license 10 renewal and I would refer you back to the original principles that I 11 started off with. We don't believe that it's efficient or effective to re-look 12 at the design and licensing basis during the license renewal process.
13 And the last slide.
14 Summary. As we've stated today, the process works.
15 It's set up to deal with subsequent license renewal, and we think we 16 should move forward with that as it stands. Thank you.
17 CHAIRMAN MACFARLANE: Thank you.
18 Mr. Lochbaum?
19 MR. LOCHBAUM: Good morning, and thank you for 20 this opportunity to share our perspectives from a slightly different 21 standpoint. Slide 2, please. I'll focus on three issues today and will 22 do so in less than a dozen slides for a change. Next slide, please.
23 UCS believes there's nothing inherently unsafe about a 24 nuclear power reactor operating for up to 60 or even up to 80 years.
25 Next slide, please. Our first concern involves the one-time evaluations 26 of severe accident and mitigating alternatives. For example, because
25 1 the Limerick plant evaluated SAMAs during initial licensing, SAMAs 2 were not reevaluated with their license renewal application. Next 3 slide, please.
4 One-time SAMA evaluations rely on three invalid 5 assumptions. That safety innovations will not have emerged since the 6 last evaluation, that populations have not increased since the last 7 evaluation, and that costs have not changed since the last evaluation.
8 Next slide, please.
9 Our second concern involves the bizarre position in 10 line approach to nuclear safety. Ginna and Point Beach are very 11 similar plants in terms of design and age, but because the NRC revised 12 its license renewal requirements in between, Point Beach is required to 13 have an Alloy 600 aging management program while Ginna is not.
14 Next slide, please.
15 The NRC's regulations in 10 CFR 50.100 and 50.109, if 16 followed, would require all relicensed reactors to have Alloy 600 aging 17 management programs or none of them to have them, not just those 18 that are towards the end of the license renewal line. Next slide, 19 please.
20 Our third and last concern this morning deals with 21 compliance with current licensing basis requirements. The NRC 22 revised its license renewal regulation in late 1991 to presume that its 23 oversight activities ensure that reactors comply with the current 24 licensing basis requirements. But ample evidence shows that this 25 assumption is invalid.
26 A 1997 report by the NRC showed that design errors
26 1 were being found on almost a daily basis, until two days ago. More 2 recently, the Fort Calhoun plant restarted late last year after two and a 3 half years of being shut down to fix a litany of design basis errors and 4 current licensing basis shortfalls.
5 Many of these shortcomings had existed undetected at 6 the plant for decades. More recently, Browns Ferry Unit 3 scrammed 7 due to a design flaw that has yet been found and fixed two days ago, 8 May 6th. Next slide, please.
9 The bottom line is that compliance with current 10 licensing basis requirements has never been shown to be valid at any 11 nuclear plant in the country, not any plant at any time. Next slide, 12 please.
13 To resolve these concerns, we recommend that SAMA 14 evaluations be required with all license renewal applications, that the 15 NRC comply with 10 CFR 50.100 and 50.109, and that the NRC verify 16 compliance with current licensing basis requirements either during 17 license renewal or as part of its routine oversight activities. Thank you.
18 CHAIRMAN MACFARLANE: Thank you. All right, 19 now we have time for questions, and we will start off with Commissioner 20 Magwood.
21 COMMISSIONER MAGWOOD: Thank you 22 Chairman, and thank all of you for your presentations today. We had a 23 lot of good comments. Let me start off by welcoming Rich to the table.
24 Rich and I worked together in the past. It's good to see you again, and 25 your colleague Tom in the back there.
26 So it's always a pleasure to see you folks and to see
27 1 you're doing good work. Oh, I should say that some of this sounds 2 familiar. I swear we talked about this about 15 years ago and you're 3 still doing the same thing, so hopefully there's been progress in that 4 time frame.
5 One question that comes to mind, because I know 6 some of this work has been talked about in the past. I'm sure Tom 7 remembers the NEPO program, for example, one of the earlier 8 programs in the 1990s. And I wonder how much of the old work got 9 used by industry?
10 Did it simply go on a shelf someplace and collect dust?
11 And if it did, how do you keep what you're doing now from collecting 12 dust? It's great to hear you're coordinating with EPRI, but how does it 13 actually go from the research that DOE is sponsoring at the labs or 14 wherever else it's being sponsored and actually end up being used by 15 plants, not just become a report that sits out in cyberspace?
16 MR. REISTER: Thank you. I probably can't speak 17 well to the past programs, you know, how well that was used. But our 18 current programs, we do work very closely, I would say, with EPRI and 19 the industry to identify how our research projects, although they do tend 20 to be longer term and more basic in nature and it's a little bit more 21 difficult for them to be applied directly by a plant, we work with EPRI on 22 how to convert those basic research outcomes into guidance that they 23 can provide to their plants in the guidance that they do. So they help to 24 convert those more fundamental research products.
25 I mean all the research that we complete, the reports 26 are available publicly, and we also work with NRC's Office of Research
28 1 so that they have access to that information as well. And so we do try 2 to, we're very cognizant of this issue and try to work to make our 3 research results useful.
4 COMMISSIONER MAGWOOD: Yes, Ms. Bernhoft, 5 you wanted to comment on that?
6 MS. BERNHOFT: Yes, probably the best way to 7 illustrate it is an example. And so one of the examples we have is 8 called an advance welding project. Current materials like vessel 9 internals with a high radiation exposure, you can't weld on those right 10 now due to the helium inclusions in those. So joining with DOE, we're 11 doing some advance welding.
12 And so, you know, we've got the development of some 13 laser welds going on in EPRI. We're partnering with Oak Ridge 14 National Labs. They're irradiating samples. They're building the hot 15 cells. And then we're taking those research results together, doing the 16 finite element analysis to show that we're lowering the stresses on the 17 weld so that you can weld highly irradiated materials.
18 And then they'll complete that work at Oak Ridge by 19 2015, and then working with EPRI we'll take it through the code 20 committees to get that repair technique approved. That's just one 21 example.
22 COMMISSIONER MAGWOOD: No, I appreciate that.
23 And since we have an operator at the table maybe you can round this 24 out. How does this long term research that DOE sponsors and is 25 coordinating with EPRI, how does that reach the plant level? How 26 does this actually get used?
29 1 MR. GALLAGHER: Yes, I think it mostly is through 2 the EPRI products, but I know that some of the background, you know, 3 you always want to have the breadth of input on the research, and 4 some of the base research that DOE does through the programs they 5 have is utilized in the EPRI products and then we apply those EPRI 6 products.
7 Many of the products, EPRI products, you know, are 8 part of the aging management programs themselves so we implement 9 that specific product in order to have an effective aging management 10 program. So I think that the base research is in there from DOE.
11 COMMISSIONER MAGWOOD: So does that 12 suggest that if a DOE research project doesn't find its way into an EPRI 13 report you don't use it?
14 MR. GALLAGHER: You mean are there other ways 15 we could use it, other --
16 COMMISSIONER MAGWOOD: No, I'm asking of 17 DOE has a research result that doesn't find its way into an EPRI 18 document, does that mean that you don't see it and you don't use it?
19 MR. GALLAGHER: I wouldn't say that. But I think 20 our corporate program owners, you know, will search for products that 21 are out there relative to issues we're working on, say, you know, a 22 buried pipe program, the program owner will look for the body of 23 research that's out there and utilize it.
24 So, you know, it is available and I'm sure that we'll use 25 that from a program perspective.
26 COMMISSIONER MAGWOOD: Okay, I'll ask a
30 1 general question to Ms. Bernhoft and Rich Reister. What do you see, 2 just for a really broad question here, what do you see as the long pole in 3 the tent when you think about plants operating for that additional 20 4 years, you know, 60 to 80?
5 What is the technical issue that you think will need the 6 most research and will need to receive the most attention?
7 MR. REISTER: I'm not sure of what the particular 8 issue might be. I think the area we tend to spend our most resources 9 on are materials issues and metals in particular.
10 So I think the long term aging and the strategy for 11 addressing those issues, an example might be core internals, where 12 there's still issues about how long, and the best strategy for managing 13 the aging of core internals is whether you can repair them or whether 14 you need to replace them at some point.
15 So I think those types of issues that really are driven by 16 economics ultimately, how much would it cost to fix an issue, could 17 drive, you know, long term operation decisions by plants.
18 MR. GALLAGHER: Just to add. You know, the 19 initiative we actually have with EPRI and DOE participating is really a 20 long term operation. So here we're focused on subsequent license 21 renewal, so materials issues are one of the bigger things in subsequent 22 license renewal. But, you know, the breadth of long-term operations is 23 basically everything in the power plant.
24 And I know there's initiatives in some of the 25 instrumentation, you know, for replacing analog instrumentation so it's 26 more of a reliability issue. And we've used a lot of those products over
31 1 the years. Even there's initiatives in more effective outage 2 management centers, you know, some technology that can be used for 3 command and control centers and electronic work packages and things 4 like that. So those type of initiatives, you know, are for long term 5 operations, not necessarily needed for subsequent license renewal but 6 for the long term operations. So we use a lot of those.
7 COMMISSIONER MAGWOOD: Ms. Bernhoft, did 8 you want to add anything to that just briefly?
9 MS. BERNHOFT: It will somewhat echo what you've 10 heard here is I would just identify that, you know, aging mechanisms 11 have basically been identified. Aging management programs exist to 12 help the licensee with the management of that.
13 You asked about what the long term or the long pole 14 would be, and it's the continued working on the mechanistic 15 understanding to do two things. One is, can we get better inspection 16 and repair techniques, more timely inspection and repair techniques?
17 And also mitigation strategies, like stress reliefing or, you know, better 18 chemistry to help with the economics and the safety of the long term 19 operations.
20 COMMISSIONER MAGWOOD: Thank you. Let me 21 spend my last minute and a half with David Lochbaum. Always 22 appreciate David's slides being shorter. That's always easier to 23 absorb the message.
24 One thing, first, let me thank you for, I think it was your 25 Slide 3 where you make the very important broad point which is, you 26 know, reactors can operate long term if they're properly maintained, but
32 1 if not properly maintained they can't operate even in the short period.
2 That's something, I think, is at the very basis of how we approached this 3 issue.
4 And you raise what's a very important issue about the 5 current licensing basis, and you sort of spoke to the issue but you didn't 6 really propose a particular path forward on that. Do you have a 7 thought?
8 MR. LOCHBAUM: Well, I think the first thing I'd 9 recommend is do a lessons learned on Fort Calhoun, because there 10 were a lot of fundamental issues identified there that weren't caught 11 early on by the oversight program.
12 I'm not saying all of those should have been caught by 13 the oversight program, but perhaps some of those should have been 14 caught earlier. So revisions to the oversight program, the ROP, what it 15 does and how it does it might come out of that lessons learned at Fort 16 Calhoun. There was a pretty good list of the NRC's restart checklist in 17 the licensee's own action, so start that as, and should this trigger any 18 changes in the ROP?
19 COMMISSIONER MAGWOOD: I think that's a very 20 fair question and I think it's one that, I'll bring this up at the staff, and I 21 think it is a conversation the EDO and I have had in the past because of 22 Fort Calhoun.
23 And, well, I'll defer and let the staff kind of respond to 24 that first then we'll chat about it some more. But I appreciate you 25 bringing up that issue. I think it's a very important issue. Thank you, 26 Chairman.
33 1 CHAIRMAN MACFARLANE: Thank you.
2 Commissioner Ostendorff?
3 COMMISSIONER OSTENDORFF: Thank you, 4 Chairman, and thank you all for your presentations. I'm going to start 5 off at this end of the table. Mr. Reister, I'll start off with you. I'm 6 interested in what is the current DOE knowledge base as to the 7 projected life of a reactor pressure vessel?
8 MR. REISTER: Well, the current basis is based on a 9 projection that we use projecting the, using the Charpy V-notch 10 samples that project how long the reference transition temperature will 11 shift over time and radiation. There's additional research being done 12 as part of our program to see if those projected embrittlements pan out, 13 maintain the same trend beyond 60 years.
14 And so I think that question is still being evaluated.
15 There's some prediction of some scientists that there might be other 16 phenomena that would become dominant in those out-years, and some 17 people have called them late blooming phases. Basically some of the 18 non-copper elements in the reactor pressure vessel material would 19 create, would migrate to areas and cause embrittlement that would 20 become more noticeable in longer term operation. But that is yet to be 21 demonstrated.
22 So we have a program that looks at, well, we work with 23 the industry both getting samples out for that time period and also 24 looking at model materials doing --
25 COMMISSIONER OSTENDORFF: So is there data 26 that supports an 80-year lifetime for a reactor pressure vessel?
34 1 MR. REISTER: Well, I think the data would be 2 collected in time before the plants would operate to that period of time.
3 So we don't have the data today, but we have a program to collect the 4 data well before they would operate in that time period.
5 COMMISSIONER OSTENDORFF: Okay, thank you.
6 Ms. Bernhoft, let me ask you, maybe a comment and a 7 question. I really had a chance before this meeting to review the EPRI 8 cable R&D program and I was very impressed with the rigor.
9 I also noted there's some knowledge gaps that you all 10 have identified but I wanted to commend that effort. I think it was very 11 helpful to understand the scope of existing programs to try to 12 understand some of the aging issues.
13 I know that in the submarine force we had, a whole 14 group stood up in the early 1980s called the SIMS performance 15 monitoring management team to look at aging of issues and to use 16 infrared sensing tomography techniques to check for degradation of 17 insulation and those kinds of issue. So I applaud the EPRI effort on 18 the cables.
19 Let me turn to a different topic area though. I'm trying 20 to get an understanding as to industry and vendor consensus on 21 projected service lives, let's say, for pumps and valves, just basic 22 mechanical components, not electrical.
23 Is there a consensus within EPRI or within the industry, 24 and if others want to add in on that please feel free to, that would 25 suggest that the original equipment manufacturers' data for this service 26 life is 40 years or 60 years or some other number? Is there much
35 1 confidence that that data exists as far as the applications in commercial 2 nuclear power plants?
3 MS. BERNHOFT: That's a large question to answer.
4 I think with a lot of the safety related components there's robustness in 5 the manufacturers' database.
6 Within EPRI we have a specific program area on 7 nuclear maintenance that gathers operating experience and works on 8 the technical basis for preventive maintenance programs for repairs 9 and replacements.
10 And so I think there's probably a better program 11 manager than myself to answer that, but we do have an extensive, and 12 we work closely with INPO with our equipment reliability group to gather 13 that type of data and share that operating experience.
14 COMMISSIONER OSTENDORFF: Okay. Did you 15 want to say something, Mr. Gallagher?
16 MR. GALLAGHER: Yes, Commissioner. I mean, 17 those particular components are in our asset management plan 18 because they're active components and it's all part of our asset 19 management. So we have pump inspection and replacement 20 schedules for all the major pieces of equipment, the reactor coolant 21 pumps, the condensate pumps, feedwater pumps, and they're all 22 different, you know, depending on what type of material it is or what 23 type of manufacturer it is. The main turbine, the generator, we do 24 rewind stator replacements. That type of thing. That's all part of our 25 long term operations and plant reliability.
26 COMMISSIONER OSTENDORFF: No, I understand
36 1 that. But is there consensus that there's a sufficient engineering 2 experience to predict accurately the service life of these components?
3 MR. GALLAGHER: Yes, on those we have 4 inspections and are able to keep on top of that type of equipment. I 5 mean that's a routine activity in all refueling outages.
6 COMMISSIONER OSTENDORFF: Okay, thank you.
7 Let me go to Mr. Earls. The SECY paper, and you 8 spent some time talking about it and industry concerns. And the staff's 9 Option 4 would require reporting by industry the operating experience in 10 aging on a plant basis as well as reporting on the effectiveness of aging 11 management programs.
12 Is that something -- but I think you mentioned that there 13 are other ways of doing that other than rulemaking, or are you opposed 14 to the Option 4 philosophical reporting requirement? Because our 15 staff has told me, and I'm just curious because, and we'll hear from 16 them later on. Our staff has told me that they don't really have a 17 regulatory footprint to require or to receive industry aging experience.
18 MR. EARLS: We don't believe that's the case. We 19 believe the staff does have a regulatory footprint. We believe there is 20 sufficient regulatory language to have us do it. In fact, the staff is 21 revising the inspection procedures as we speak to incorporate aging 22 management specifics into them. So we believe that's already there.
23 COMMISSIONER OSTENDORFF: What's the 24 specific regulatory footprint now that would require industry to report --
25 MR. EARLS: Well, Mike described it in that last flow 26 chart that he had on his slides. It shows the feedback mechanisms, so
37 1 the corrective action program.
2 If we identify an issue with an aging management 3 program that gets identified through the corrective action program 4 which then, you know, goes through a review process, and that is 5 subject to inspection. That Appendix B covers this type of thing. So 6 we believe that that will cover aging management programs.
7 COMMISSIONER OSTENDORFF: Okay, we're 8 running out of time, but I'll just comment that there's a different view 9 from our staff as to the applicability of what you're saying as far as 10 reporting back to the NRC, but I don't have time to go into that further.
11 But let me ask Mr. Gallagher. I need a 30-second or 12 less answer because I need to talk to Mr. Lochbaum here just a minute.
13 Give me one example in your Slide 6 that Mr. Earls refers to on the 14 feedback loop where you have industry OE that feeds into the block, 15 develop/modify aging management programs.
16 Give me one example that Exelon has experienced 17 where you've modified your aging management programs in response 18 to OE.
19 MR. GALLAGHER: Just to -- one major one. Alloy 20 600 program. And so that was based on operating experience.
21 And there was an industry initiative created, it was an 22 NEI 03-08. And that= s what Sherry mentioned. And that= s one 23 major program that was based on operating experience.
24 COMMISSIONER OSTENDORFF: Okay, thank you.
25 I appreciate that. Let me go to Mr. Lochbaum here. I agree with Mr.
26 Magwood= s commentary on the clarity and the conciseness of your
38 1 presentation.
2 I just wanted -- the safety by queue example, your 3 second of the three examples, what kind of feedback have you gotten 4 from our staff on that? Because this probably not something new from 5 your perspective, this has been --
6 MR. LOCHBAUM: They told me they couldn= t go 7 back to the make the earlier plants do it because the license renewal 8 rule was voluntary. They didn= t -- nobody held a gun to their head was 9 almost the exact words.
10 But the original license was voluntary also. And yet 11 you still require people to meet 10 CFR 50. So you have the authority.
12 You have with the -- you may lack the wherewithal, but you could go 13 back and make the earlier plants do it.
14 I= ve heard from the industry that they= re voluntarily 15 doing it because they have a large asset to protect. But safety dictates 16 that that same regulatory footprint exists no matter where you are on 17 the line.
18 COMMISSIONER OSTENDORFF: Okay. Anybody 19 response to the safety by queue comment by Mr. Lochbaum? Mr.
20 Earls?
21 MR. EARLS: Yes, I would like to respond to that. If 22 an issue is significant from a safety perspective, the staff has the 23 mechanism to impose that on the licensee. The example he= s using 24 is the GALL. The GALL is the generic aging lessons learned.
25 Those issues, while they improve the process, are not 26 -- don= t necessarily raise to that level. But if they do, the staff has the
39 1 means to impose that on plants.
2 And as we pointed out in the Alloy 600 example, Ginna 3 has implemented that program. You know, that is an active program at 4 Ginna.
5 So to suggest that you know, these earlier plants don= t 6 do these things, that= s not accurate.
7 COMMISSIONER OSTENDORFF: Okay.
8 MR. LOCHBAUM: Can I just get in here a little?
9 COMMISSIONER OSTENDORFF: Yeah.
10 MR. LOCHBAUM: Ginna may have voluntarily have 11 one, but if they stop doing it tomorrow, the staff would lack any 12 mechanism to force them to them to reinstate it. At Point Beach it= s 13 part of the license renewal application. If they stop doing it, the NRC 14 can sanction them for doing it.
15 It= s either right -- it can= t be right in both cases.
16 Because they= re so different.
17 COMMISSIONER OSTENDORFF: Okay. Thank 18 you very much.
19 CHAIRMAN MACFARLANE: Thank you. Okay.
20 The comments that you made at the previous questions Mr. Reister, 21 were a bit concerning and that= s in part because my background as a 22 scientist, I spend a lot of time thinking about processes that occur over 23 time. Solid, solid reactions, that kind of thing.
24 And so I -- and with your comment on the pressure 25 vessel and whether you understand now what all the issues might be, 26 brings home to me the importance of whether we really do understand
40 1 all the processes that may affect the plant over that longer period of 2 time.
3 So do you have confidence that we understand all the 4 processes that -- and the mechanisms of aging out there?
5 MR. REISTER: Well I= d say that= s part of our 6 research.
7 CHAIRMAN MACFARLANE: Right.
8 MR. REISTER: Is to get a better understanding of 9 those mechanisms. I would think, I would say that we haven= t seen 10 any you know cliff edge effects in the 60 to 80 years that the effects 11 seem to follow a predictable evolution. And then --
12 CHAIRMAN MACFARLANE: But my question is are 13 there processes that you may not be aware of yet that may exist?
14 MR. REISTER: Well, I can= t prove a negative. I 15 can= t prove that there won= t be any processes. But I would say --
16 CHAIRMAN MACFARLANE: Yes, the unknown 17 unknowns.
18 MR. REISTER: Right. But I would say that we have 19 -- we= re doing the research to try to detect those in that time frame.
20 And we also have programs in the industry that I= m aware of where you 21 would be able to detect things that occurred in a time frame that you 22 could address the issue.
23 CHAIRMAN MACFARLANE: So who= s doing the 24 research for you guys?
25 MR. REISTER: Well, most of the research we did is 26 National Labs.
41 1 CHAIRMAN MACFARLANE: National Labs?
2 MR. REISTER: Oak Ridge is the materials lab.
3 MS. BERNHOFT: And we would work either with the 4 National Labs, we work with a number of universities.
5 CHAIRMAN MACFARLANE: Okay, Ms. Bernhoft, are 6 there plants that no longer have material testing coupons in their 7 reactor vessels?
8 MS. BERNHOFT: There are some of the BWRs that 9 are.
10 CHAIRMAN MACFARLANE: Okay, and so how are 11 you going to characterize the long term situation of those particular 12 plants?
13 MS. BERNHOFT: With those particular situations, we 14 are going into a program now, you know there= s the integrated 15 surveillance program right now out there for the 40 to 60 years that 16 adequately covers the BWRs.
17 Looking to the question of the 60 to 80, we= re working 18 on a program right now with some of our researchers to compare or 19 baseline the data from the PWRs, its to compare that to the BWRs.
20 The PWRs lead influence levels to the BWRs.
21 CHAIRMAN MACFARLANE: So how many plants 22 don= t -- do we not have those coupons?
23 MS. BERNHOFT: That I couldn= t= answer for you 24 right now.
25 CHAIRMAN MACFARLANE: And you know, I guess 26 it just leads to a litany of questions. You know, how different are the
42 1 materials used, you know, in the different chemistries, the different 2 radiation fields, et cetera. Anyway.
3 MS. BERNHOFT: But we understand that. To 4 somewhat build on the point that Mr. Reister was making earlier, we 5 assessed through surveillance capsule removals. We plot that on 6 embrittlement trend correlations. We confirmed that by pulling the 7 Charpy V-notch test.
8 With some of the cases we are extending the interval 9 that a number of the capsules are in the vessel, recognizing that you 10 know, some of those capsules are already out. So we do have a 11 program formally established to extend the service life of some of those 12 capsules so we capture that lead factor for those capsules.
13 In other cases were working with the industry right now 14 to reintroduce some surveillance capsules that have been previously 15 been removed so that we can get some additional exposure time on 16 those. And the plan is to stay ahead with the research and the 17 surveillance capsules ahead of where the operating plants are.
18 CHAIRMAN MACFARLANE: So question for you Mr.
19 Gallagher. You are concerned that rulemaking would take a long time.
20 But the first plant that would need subsequent license renewal 21 wouldnt= t need it until 2029. It seems we have an ample amount of 22 time here.
23 MR. GALLAGHER: Yeah, I think you know, as I said, 24 the industry would like you know, a sufficient time for energy planning.
25 Ideally youd be submitting these applications about ten years out.
26 So that would be 2019 for the first plants. As an
43 1 industry we thought it was good to you know, get one in and get through 2 the process. Because you know even with no rule change, there will 3 be guidance change. The staff is working on guidance change for the 4 GALL, the SRP.
5 And then from there, the industry can be putting in the 6 applications about ten years out. And we think that that= s an 7 appropriate time frame for energy planning.
8 CHAIRMAN MACFARLANE: I understand the energy 9 planning piece. I= m concerned that we don= t have adequate data 10 sets to --
11 MR. GALLAGHER: Well, just on the data set, I mean 12 my understanding on the reactor vessel data, is that we do have 13 research data that shows material properties through 80 years. What 14 we will be doing is with reactor vessel surveillance coupons --
15 CHAIRMAN MACFARLANE: Those are predictions.
16 Those are extrapolations, right?
17 MR. GALLAGHER: Predictions and test reactor data, 18 okay.
19 CHAIRMAN MACFARLANE: And have we 20 characterized the uncertainties associated with extrapolating out that 21 far?
22 MR. GALLAGHER: And -- well that= s part of the 23 extrapolations. So basically what we would as an industry what we 24 would be doing is having an integrated vessel surveillance program, 25 just like we have now.
26 Not all vessels were part of the -- had to have a capsule
44 1 for the existing program. Because theres groups and subsets of 2 reactors where you can you know, have appropriate numbers of 3 capsules in appropriate reactors to stay ahead of the curve for 4 evaluating the specimens.
5 So we would continue with a program that has to be 6 reviewed and approved by the staff. On what reactor will have what 7 specimens where and for how long, in accordance with Appendix H.
8 And then so we can show and stay ahead of the curve.
9 CHAIRMAN MACFARLANE: Okay. Mr. Earls, 10 NEI= s position is that no change is necessary, right?
11 MR. EARLS: No rule change is necessary.
12 CHAIRMAN MACFARLANE: No rule change is 13 necessary.
14 MR. EARLS: We believe there is some value in 15 updating and developing some new guidance.
16 CHAIRMAN MACFARLANE: So does that -- okay, so 17 that means you do think that there are some lessons that we= ve 18 learned from the past 20 years of implementation of Part 54?
19 MR. EARLS: Oh absolutely, absolutely. I didn= t 20 mean to suggest otherwise. What I was suggesting is that those 21 lessons would not drive us to a rulemaking. It does drive us to update 22 guidance, so for example the GALL update to reflect our current 23 understanding on the aging management program just an example.
24 We are working on additional guidance to strengthen 25 our assessment of the effectiveness of the amps at the plant. And also 26 strengthen our operating experience programs through the INPO
45 1 process that already exists.
2 CHAIRMAN MACFARLANE: Mr. Lochbaum. So, 3 first of all you know you wrote a post a little while ago called Nuclear 4 Plants and Nuclear Excuses, This is Getting Old, concerning oversight 5 of aging components, its the aging effects on components.
6 Do you believe that the license renewal focus now on 7 aging effects on passive components is flawed? And I= m interested in 8 your thoughts about these issues of uncertainties projecting out 9 mechanisms that we understand now and those that we don= t.
10 MR. LOCHBAUM: Well that blog post is actually 11 active components where the NRC staff identified current deficiencies 12 in its oversight of active components and nothing was done by senior 13 management. When you identify a problem and then pretend it 14 doesn= t exist, that= s not very good.
15 On the passive side, we think the aging management 16 programs are pretty sound. The scope of what they do and how they 17 look at it. The one exception might be in electrical equipment. The 18 long pole question that was asked earlier about pumps and valves.
19 CHAIRMAN MACFARLANE: Right.
20 MR. LOCHBAUM: The transformers and breakers 21 seem to be failing at a high rate and causing problems. They= re 22 non-safety related equipment, but they challenge safety systems.
23 They don= t seem to be covered adequately either by 24 amps or the NRC= s license renewal rule. They seem to be failing at 25 an undue rate. There seems to be a gap there that needs to be closed.
26 So with that exception, the scope and thoroughness of
46 1 the aging management program seems to be okay. That= s not our 2 issue, its some of the collateral issues we see.
3 CHAIRMAN MACFARLANE: I see. So you don= t see 4 that theres a real long pole in the tent going out to 80 years.
5 MR. LOCHBAUM: No, in fact the question earlier 6 about the reactor vessel and some of the things, the backstop for us, we 7 would point out to is the NRC= s experience a decade ago with control 8 rod drive mechanism nozzle cracking.
9 That was unforeseen, but when it was detected at 10 Oconee, the NRC issued the bulletin in August of 2001 that required 11 everybody to address it. So we think theres backstops to address the 12 known, unknowns, or whatever -- whatever the right term is.
13 And it would be nice if we avoid those. We think there 14 are things in place to deal with them if they arise.
15 CHAIRMAN MACFARLANE: Okay, okay, thank you.
16 Commissioner Svinicki.
17 COMMISSIONER SVINICKI: Thank you all for your 18 presentations and actually Mr. Lochbaum I was going to begin kind of 19 on the point that you just made, so I appreciate that. Which I was 20 going to ask -- direct it to some of our licensee folks here, is that what is 21 the fundamental showing to the issue of license for the reactors that are 22 operating now, whether in their initial period of licensing, or their 23 extended period of operations?
24 Is the showing in order to be granted a license that you 25 come in with the absolutely high confidence data that every component 26 is to last X number of years of the terms of the license?
47 1 Or is the fundamental reliance for issuance of a license 2 on the oversight program and then the mechanisms to address the 3 unknown unknowns or unexpected degradation that should come in?
4 MR. GALLAGHER: Yes Commissioner. Yes, the 5 rule is actually that we don= t have to prove that certain equipment you 6 know, lasts a certain period of time, 80 years whatever. We have to 7 have the programs in place to manage the aging before the loss of 8 intended function. And that= s what the rule is.
9 So now you do in some -- for some equipment, you do 10 in the time limit aging analysis, you do do projections. And based on 11 the projections, you can either you know, show that you are projected 12 through the 80 year period, or you have a program in place to manage it 13 in the period of extended operation.
14 So it= s more of a program implementation to make 15 sure we have the right programs, right inspections in place to manage 16 the aging.
17 COMMISSIONER SVINICKI: So in light of that 18 answer and Mr. Earls= response to an earlier question about the staff= s 19 assertion that they have no regulatory reach into looking at problems 20 related to the aging of components. And then also even Mr.
21 Lochbaum= s statement of you know, how in using the control rod drive 22 mechanism as an example of how we might have an unforeseen 23 emergent issue, and the regulatory tools that we have to address that, 24 I= m more than a little puzzled over an assertion that the NRC does not 25 have regulatory reach into addressing these problems.
26 Now if the staff wants something specifically labeled
48 1 as oversight of aging management. But I -- if I take aging 2 management not as a program, but just in lower case as you know, 3 looking at phenomena and degradation, I= m not aware of any area 4 where the NRC, if there were an emergent problem, wouldnt be able to 5 reach that and require a regulatory response.
6 So if it= s that we= re not getting it labeled under the 7 right term, I you know, frankly think that that= s the kind of you know, 8 bureaucratic fly specking that NRC is often accused of.
9 So I look forward to exploring that with the staff. I 10 don= t know what aspects of looking at safety significant aging 11 phenomena and degradation that we would not be able to compel a 12 response to.
13 So I= m just very puzzled by that. But on the research 14 and development program, based on Commissioner Magwood= s 15 comments, you know that= s a long term operations has been looked at 16 for a very long time.
17 Could anyone, either this would principally be operator 18 or DOE. Could you talk about how over perhaps even the decades 19 that that work has been going on, is there a feedback mechanism as 20 you look at a certain phenomena, if you find that it is even more 21 significant than you thought? Has there been a consistent feedback 22 into the R&D program of work over time so that you are looking at what 23 is or isn= t more or less significant.
24 And then using that to tailor the programs going 25 forward. And then how also does plant, not just the research feedback 26 group, but OE, operating experience from the plant, how is that fed into
49 1 your programs?
2 MS. BERNHOFT: Yeah, that= s a very good question.
3 On the overheads I talked about what we called our materials 4 degradation matrix. I could urge you to look at that. It is publically 5 available.
6 It= s a very extensive database. We go through each 7 metals component. You know down one column, we go across the 8 top. We= ve identified what we feel could be all the possible aging 9 actors on that.
10 And then we sit down on a consistent basis, it= s a 11 living program that= s routinely updated. We take the operating 12 experience through our issue programs. Some of them meet two or 13 three time a year.
14 We get all that operating experience, not just the U.S.,
15 but international, fed in through our issue programs. We sit down 16 formally once a year. We look at that materials degradation matrix.
17 We have the operating experience. We have the 18 researchers with the research results. And we also bring in 19 international experts, so there= s also some expert solicitation process.
20 We go through and we update that materials degradation matrix.
21 In 2010, looking forward to this, you know the 22 possibility of supporting subsequent license renewal. We actually 23 went through and we reevaluated that entire matrix with what we called 24 LTO flags.
25 So if you go in and you pull that up online, you= re going 26 to see where there= s a little LTO flag where we pose the question, is
50 1 there additional investigation that needs to be done on this aging 2 mechanism for this component for 60 to 80 years?
3 From there what we do is we have what we call our 4 issue management tables. And that specifically looks at you know, the 5 safety significance. You now the gaps in possible knowledge. And 6 then we prioritize the research based on that.
7 And that= s what we take back through to our different 8 utility members and advisory committees. So when we get to our 9 issue management meetings you know, two or three times a year.
10 We= re briefing out operating experience and we= re briefing out 11 research results. And where we line up with our issue management 12 tables.
13 COMMISSIONER SVINICKI: So in terms of 14 emergent materials phenomena in the plants, it sounds like there= s a 15 fairly frequent and direct feedback loop for you to incorporate that into 16 planning and programs. I= m sure it takes a little bit of time to get the 17 research started.
18 But it sounds like at least the feedback loop is pretty 19 immediate.
20 MS. BERNHOFT: Yes, we have the feedback loop, 21 that= s the formal process. We always are prepared to handle 22 emergent issues. And that really comes under the governance of the 23 NEI 03-08 initiative.
24 And a big part of that is the operating experience 25 exchange. When that happens, we have international phone calls with 26 the researchers, the utilities involved, and we tie in NRC management.
51 1 And we brief them on you know, what we= re seeing and what actions 2 we= re taking.
3 COMMISSIONER SVINICKI: Thank you. My last 4 question would get a little bit to the history. I think at least two of you 5 talked about the NRC= s initial experience with license renewal. It was 6 a bit of a failure, I= ll use that, I know it= s a harsh term. But there was a 7 kind of a -- they went back to the drawing board.
8 My understanding of that history is that it was 9 principally a problem of scope in that as they worked on the first couple 10 of pilots, it was discovered that the scope of license renewal needed to 11 be calibrated very specifically not to become a dual or overlapping 12 system with the ongoing oversight of operating plants.
13 And therefore, if you have secondary reporting 14 mechanisms, a whole separate schema for inspection of aging, 15 fundamentally you would have NRC with two systems. And that 16 becomes somewhat unmanageable if there is, I think the 17 acknowledgment was if there was something missing that you 18 discovered that you needed for aging management, it is likely you 19 needed it right now for ongoing operations. There were not -- you 20 know, if something was safety significant on 40 years plus one day, it 21 was likely safety significant right now.
22 So do you think that in Option 4 there is the potential for 23 unlearning that lesson and running afoul of that if you= re going to have 24 a separate additional oversight system for flex equipment or something 25 like that under aging management, in addition to any to any oversight 26 we have in the ROP?
52 1 MR. EARLS: Yeah, I think you= re absolutely correct.
2 And that is a concern that we have that we see what appears to be a 3 push to try to set up separate systems.
4 I= ll use the operating experience as an example. You 5 know, we have a very extensive operating experience that captures a 6 lot of different types of material and equipment information. Aging 7 management is captured in there. We= re going to strengthen how it= s 8 captured. But it is captured in there.
9 We= re concerned that we will be pushed to establish a 10 separate license renewal operating experience process. And so then 11 you have the question of well, which program is it in? And then it gets 12 confusing.
13 So yes, I think that potential absolutely exists out there.
14 And we are concerned with it. We think a better approach is to 15 integrate it into the existing processes as I mentioned earlier. We 16 believe the staff is pursuing that with the incorporation of aging 17 management into existent procedures.
18 COMMISSIONER SVINICKI: Well I mean at the end 19 of the day it= s going to be the resident inspector for all. So I don= t 20 want him or her walking around with their procedure for inspection on 21 the aging management side. And then you know, they go back on 22 Wednesday and they look at it for current operation.
23 So I find myself, I= ll let David, I know he wanted to add 24 a point here. But I find myself fundamentally, I think, in agreement with 25 Mr. Lochbaum in that if there= s some gap in license renewal, I= d like to 26 address it now. I don= t want to address it for 60 to 80.
53 1 I mean I think that if case can be made that something 2 needs to be looked at, I would be advocating that we look at it now.
3 Whereas a matter of fact, not just in the license renewal, the 40 to 60, I 4 would advocate that we look at it under the ROP.
5 So David did you want to add something?
6 MR. LOCHBAUM: Just on that, the last point about 7 there is a potential for redundancy. But one of the things I value in the 8 reactor oversight process, is the periodic reassessments.
9 So that if there was redundancy put in through this 10 process, at some point the overlap would be identified and either kept in 11 one place, or eliminated in the other to try to reduce it. Because the 12 base line inspection program tries to be a zero sum game. So if 13 there= s anything added, it has to be taken off somewhere else.
14 So there is a potential for being introduced, but there= s 15 also the safety net of it being caught and fixed whatever is most 16 appropriate down the road.
17 COMMISSIONER SVINICKI: Okay, thank you.
18 Thank you Chairman.
19 CHAIRMAN MACFARLANE: Commissioner 20 Apostolakis.
21 COMMISSIONER APOSTOLAKIS: Thank you 22 Chairman. The DOE program with others, that you talked about Mr.
23 Reister, on the slide something, nine, you talk about risk informed 24 safety margin characterization. Now I don= t know what these terms 25 mean, okay, let me start with that.
26 We hear about safety margins a lot. There was an
54 1 earthquake and North Anna survived. It was greater than the SSE 2 because of the margin that= s available.
3 And now we have the reevaluation project, the seismic 4 reevaluation, and again the margins are becoming important. We 5 have never quantified the margins.
6 Is this element of this project going to help me 7 understand what kinds of margins we have? What is it that you= re 8 characterizing? All I see here is computer programs that do 9 thermohydraulics integration and so on. But am I going to understand 10 how much margin I have at the plant if I use these tools?
11 MR. REISTER: Well, it= s geared toward a better 12 understanding of what the safety margin would be. And so the idea is 13 that the analysis gives you a probability distribution of what that 14 scenario was looking at compared to what it would be. It= s also a 15 probably of distribution of your ability to withstand that.
16 COMMISSIONER APOSTOLAKIS: So you would do 17 that? This program does this?
18 MR. REISTER: Yes. Yes. That= s the idea. And 19 so you would understand what those probability distributions look like 20 and how far apart they are. And that would be the safety margin.
21 Those -- the difference between those two probabilities of an outcome 22 and your ability to withstand that load.
23 COMMISSIONER APOSTOLAKIS: Well in PRA 24 space, we are really quantifying defense in depth. I mean you know, 25 redundancy. I have a system with two trains. I need only one, so I do 26 the calculations and so we develop the accident sequences that way.
55 1 We don= t take into account any margins there. We 2 make assumptions you know, if I lose one steam generator I= m done 3 and so on.
4 Am I understand that now I can take one accident 5 sequence and say well gee, even if I lose one train, I really have to ask 6 how much of the train have I lost. I mean what is the flow rate and so 7 on. I haven= t really lost it 100 percent.
8 So there is an additional probability that the thing -- that 9 the core will be saved. Is that something we can do with these results?
10 Or is something for the future?
11 MR. REISTER: That= s exactly what this 12 methodology would do. Is you would have -- RELAP-7 would be the 13 high fidelity plant simulator that you would run your scenario through.
14 And then what happens during that scenario, the events, like whether a 15 pump runs or not runs, would be based on probability distribution.
16 And you would run that scenario maybe ten thousand 17 times, and all the things that happen during that scenario, within the 18 bounds of that scenario would be driven by probability distributions.
19 And so you would get a probability distribution of the outcome.
20 COMMISSIONER APOSTOLAKIS: That= s extremely 21 ambitious. Probably will be irrelevant to the 80 to 100 subsequent, 22 subsequent license renewal. I don= t see anything.
23 Anyway, but there is a bigger issue here that bothers 24 some of us. The whole discussion today, and the license renewal 25 activities for 40 to 60 focused on aging.
26 Now it is likely that if we approve 60 to 80 extensions,
56 1 we may have designs that will be 90 years old during that period. And 2 I don= t know how we would explain to the public that these designs, 90 3 year old design, 100 year old design, are still safe to operate because 4 we licensed them back in the > 60s the first time around.
5 Don= t we need more convincing arguments then just 6 saying we= re managing aging effects? Some better holistic approach 7 perhaps that will convince some of the technical people, but maybe the 8 public, that indeed these designs deserve to be in operation.
9 Is that a bigger question? And why should we say 10 well gee, the Commission decided back in 1991 that these are the 11 principles. Well yeah, I mean they are not in the U.S. Constitution.
12 Principles can change.
13 So -- and I don= t know that the Commission at that 14 time was thinking in terms of 90 year old designs. Is anybody else 15 concerned about this? I mean if we just say no, we look at the aging 16 and we have a great oversight process. So you know these plants can 17 operate for 90, 100, 200 years?
18 I mean will you buy a car that was designed in > 64?
19 MR. GALLAGHER: I might. I might.
20 COMMISSIONER APOSTOLAKIS: Maybe you 21 would, maybe you would, okay. It= s an antique, okay.
22 MR. GALLAGHER: Well Commissioner, I mean my 23 response is that the license renewal rule is just one rule of a regulatory 24 framework. So I mean as you know, we have probably the most 25 rigorous safety standards of any industrial application. And we need to 26 meet those safety standards everyday.
57 1 So what we would be communicating to our 2 stakeholders, is that we you know, safety operate the plant. We 3 maintain it. And we have to meet very, very high safety standards.
4 And we will and we do.
5 The aging is just a piece of that.
6 COMMISSIONER APOSTOLAKIS: But Mr.
7 Gallagher, six years ago, you would have said the same thing. And 8 then Fukushima happens. And we find out, oh my God. We never 9 really looked at the flooding again.
10 We licensed them decades ago, and now we have to 11 go back and develop a methodology for doing flood analysis. So there 12 are certain things that maybe are done once. And then we don= t look 13 at them.
14 And I mean the rules you mentioned, yes sure. I 15 mean we have a very rigorous regulatory system. But I don= t know to 16 what the system is looking at the global picture.
17 MR. GALLAGHER: Well I guess what I= m saying is 18 that the global picture are all the safety standards. And that= s the 19 current licensing basis. That= s done on an ongoing basis.
20 So the aging, which we= re subject of depth, is you 21 know, a narrow --
22 COMMISSIONER APOSTOLAKIS: I appreciate that 23 point. And I appreciate --
24 MR. GALLAGHER: Also the thing with Fukushima, 25 then there= s different things that occur. And the safety standards 26 change. And we implement those.
58 1 COMMISSIONER APOSTOLAKIS: After an accident.
2 MR. GALLAGHER: In that particular case.
3 COMMISSIONER APOSTOLAKIS: Yeah, in that 4 case. So do you think that= s a convincing argument? You meet our 5 regulations, therefore you= re safe enough?
6 MR. EARLS: Well I think I would add that you know, 7 when you pose that question, you pose it in a macro prospective. If I 8 look at the silhouette of the plant, yes it is, it is -- looks like what was 9 designed back in whatever > 50, > 60, > 70.
10 But if you look at the components, the systems, we 11 learn. If you look at the materials that are in some of our key 12 components today, they are nowhere near the same design or type that 13 was installed originally.
14 So we learn. So there is an update of the design as 15 we learn. Again, this is an important aspect of our operating 16 experience. The Alloy 600 program, you know, there= s a recognition 17 that there= s an issue with that design. That= s upgrade.
18 So I think if you look at it not just at a macro 19 perspective, but at a micro, there have been upgrades. These are not 20 you know, old, 50 year old plants. That you walk into these plants, 21 you= ve all walked into the plants. They don= t look like a 50 year old 22 plant.
23 COMMISSIONER APOSTOLAKIS: And I don= t 24 dispute that fact. I= m not saying that there haven= t been upgrades 25 and so on. But again, I don= t know that we= re communicating very 26 well.
59 1 I was visiting a plant maybe three or four months ago.
2 And one of the things that really convinced me that they knew what they 3 were doing, is when they showed a curve of the core damage frequency 4 over the years.
5 And what actually physical changes they had done to 6 the plant. And how these were reflected in the year 2003 and the 7 curve goes down. That macro level, I think goes a long way towards 8 convincing somebody that something that was designed and built a 9 long time ago, does deserve to operate now, or ten years from now.
10 And I think that= s missing from this proposed 11 approach. Again, I appreciate that you know, if you meet our 12 regulations you= re safe enough sure. But I wonder how convincing 13 that is. And if you have a good aging management program, it= s great 14 even though the design was done in 1955. I guess I run out of time.
15 MR. LOCHBAUM: Well there= s also the silver lining 16 of there= s 20 more years to come into compliance with the fire 17 protection regulations to promote the Commission briefing of June 4th.
18 So increases the chances that you get there. So we= re in favor of that.
19 COMMISSIONER APOSTOLAKIS: Very positive Mr.
20 Lochbaum.
21 CHAIRMAN MACFARLANE: Any further questions?
22 COMMISSIONER SVINICKI: Could I respond to 23 George= s question? I just -- I was listening really, really closely. And 24 although the question appears to more -- to be about the science of 25 persuasion as opposed to the science of nuclear technology, I heard 26 you pose the question, I don= t know, we= ll see the transcript
60 1 eventually.
2 I think you said when the public says should something 3 80 years old be operating, and the answer is, well we= re managing 4 aging and aging phenomena, and if it isn= t safe we= ll close it down.
5 And you said is that the right response?
6 It= s hard for me to think of a more germane and 7 relevant answer to the question is, should this old thing be operating, to 8 say we= re looking very, very closely at aging and materials 9 degradation. And if we find something there, we= ll address it or it 10 won= t operate.
11 I don= t know what more relevant answer to that you 12 could give.
13 COMMISSIONER APOSTOLAKIS: We can= t turn 14 this into a debate here, right? So, I don= t find that a convincing 15 argument.
16 CHAIRMAN MACFARLANE: Any further comments?
17 No. All right, we will take a quick five minute break.
18 (Whereupon, the foregoing matter went 19 off the record at 10:38 a.m. and went 20 back on the record at 10:47 a.m.)
21 CHAIRMAN MACFARLANE: Okay. So we will now 22 start the second panel and hear from the NRC staff. And I= m going to 23 turn it over to our Executive Director for Operations, Mark Satorius.
24 MR. SATORIUS: Thank you Chairman. And good 25 morning Chairman, good morning Commissioners.
26 The staff today will be briefing you and provide us
61 1 overviews on it= s efforts to be prepared for the receipt of the first 2 subsequent license renewal application, which I did not hear any 3 specific dates for the arrival of that application from the first panel. Our 4 understanding is 2018 is what industry has led us to believe that we 5 could expect that first application.
6 Staff is working very diligently to insure that they= re 7 prepared for the receipt of that application. And just as diligently to 8 ensure that any potential applicant clearly understands the 9 requirements that need to be met.
10 So with that, I= ll ask John Lubinski to start the staff= s 11 presentation. John.
12 MR. LUBINSKI: Thank you Mark. As stated, I= m 13 John Lubinski, I= m the Director of the Division of License Renewal in 14 our Office of Nuclear Reactor Regulation.
15 With me for the briefing this morning I also have Bo 16 Pham to my left. He= s the Branch Chief in Division of License 17 Renewal in NRR, responsible for subsequent license renewal 18 regulations.
19 Also Dr. Mirela Gavrilas, who= s our Acting Deputy 20 Director of the Division of Engineering in our Office of Regulatory 21 Research.
22 This morning I will provide an overview of the licensing 23 and oversight during the first 60 years of operation, which includes the 24 first license renewal period. And how these processes support the 25 recommendations we= re making for the subsequent license renewal 26 period, that is beyond 60 years.
62 1 To do that, the staff reviewed the policies, regulations, 2 guidance and technical information to determine if there was any 3 changes needed to our regulatory framework or technical framework to 4 support the submission and review of the first subsequent license 5 renewal application.
6 The staff believes that number one is, the policies and 7 principles supporting license renewal are appropriate for subsequent 8 license renewal. We did review those again and determined that we 9 believe they= re appropriate.
10 Secondly, we believe based on those principles and 11 issues unique to subsequent license renewal, that regulatory changes 12 should be considered. And we included those in SECY-14-0016 and 13 provided that to the Commission in January. Bo Pham will talk about 14 that during his presentation.
15 We also believe we need to continue to review of the 16 technical issues that support aging management programs needed 17 beyond 60 years. Dr. Mirela Gavrilas will talk about during her 18 presentation this morning.
19 And then finally we believe both in the technical areas 20 as well as in the regulatory area, regulatory guidance needs to be 21 updated.
22 I note that as part of license renewal and subsequent 23 license renewal, we do both a safety review and environmental review.
24 Since we have recommended no changes to the environmental review 25 process, we= ll focus our presentation just on the safety side this 26 morning.
63 1 So in order to discuss license renewal in general, I 2 think we ought to talk about plant operations during the first 40 years.
3 And I believe right now to insure safety, the NRC= s current regulatory 4 framework and processes are appropriate and adequate.
5 This is due to the inner relationship and the feedback 6 between our regulations, our licensing, and our oversight activities.
7 And they basically feed each other to insure that we have adequate 8 protection of public health and safety every time during plant 9 operations.
10 We don= t just do it at a certain time frame. It= s 11 everyday we make sure we have safety at the plants.
12 Part of the premise for this is, when we identify a 13 potential safety or security issue, we address it when it= s identified.
14 We don= t wait until a certain time frame and only do it every five years, 15 ten years, 40 years, 20 years.
16 Instead we do it once identified. And we take care of 17 those issues either on a plant specific basis or a generic basis when we 18 believe they apply to more than one plant.
19 We also believe the licensing basis continues to be 20 enhanced over the years. There was a little bit of discussion about this 21 this morning. Licensees are required to maintain their licensing basis.
22 And they make changes to those licensing basis.
23 Some of them are voluntary, some of them are 24 mandatory. Some of the voluntary changes are done as part of 50.59 25 evaluations that do not require NRC prior approval. Examples, when 26 they replace pumps, valves, steam generators. When they put a new
64 1 one in, it is a more robust system.
2 And it becomes part of their new licensing basis. And 3 those changes would be subject to regulatory requirements when 4 changes are made to decrease, if they wanted to decrease back that 5 licensing basis.
6 Also, there= s voluntary programs that require our 7 review. Such as NFP 805 application reviews as well as power 8 uprates. Again, the safety profile of the plant gets better based on 9 these changes and enhancements that are made to the plant, and it 10 becomes part of their licensing basis.
11 And then finally, over the years when we identify issues 12 that need to be addressed based on safety issues, we may issue orders 13 and mandate those changes. We= ve done that in response to Three 14 Mile Island as well as Fukushima in requiring those enhancements.
15 And that becomes part of the licensing basis.
16 Aging management is not something unique to license 17 renewal. It occurs during the first 40 years. You heard this morning, it 18 started on day one. And that= s insured through our regulations, our 19 licensing and our oversight activities.
20 And the purpose of the aging management program is, 21 it requires plants to implement processes and techniques capable of 22 identifying the effects of aging before they impact safety. And to take 23 any necessary actions once this is identified. And that could include 24 mitigation of the effect, a repair or a natural replacement.
25 So what we look for is there an indicator that we= re 26 having a safety issue at the plant? And let= s identify the corrective
65 1 actions before it actually becomes a safety issue. Next slide.
2 For license renewal, that is the 40 to 60 year period, 3 this slide includes a -- the two fundamental safety principles. The first 4 is with the exception of the detrimental effects of aging, the existing 5 regulatory process is adequate for plants -- for safe plant operation.
6 And this includes the continued licensing and oversight 7 activities that I discussed. And it includes those programs identifying 8 and addressing any potential safety issues when they occur, not waiting 9 for license renewal.
10 We also look at aging management programs as I said.
11 And we determine from the standpoint of have -- what the programs 12 provided by licensees. Are they adequate to address aging?
13 That= s part of the first license renewal. Some of 14 those programs are identical to what they= ve done during the first 40 15 years, because it was very well known what the degradation 16 mechanism is and can continue. Others required enhancement 17 because of aging beyond 40. And then others required new programs 18 to be put in place for inspection and replacement activities.
19 The second principle is that each plant must maintain 20 it= s licensing basis. And as I discussed, this licensing basis at the time 21 of the license renewal is not the same as it was at initial licensing. The 22 plant has made enhancements and it= s made upgrades and that 23 becomes part of their new licensing basis.
24 These principles were established when we developed 25 10 CFR Part 54 for the application process for license renewal. We did 26 review those and we believe they= re adequate to support license
66 1 renewal today and continuing forward.
2 We note that plants enter the period of extended 3 operation that is beyond 40 years, starting in 2009 and collectively, we 4 have more than 56 reactor years of operations beyond 40 years.
5 So for subsequent license renewal, as Mark said, it 6 was not mentioned a time frame this morning. But the industry has 7 indicated to us that they plan to submit their first application in 2018.
8 Top rate beyond 60 years.
9 We believe that we need to be prepared for receipt of 10 that application with guidance and regulations. So to do that, we 11 reexamined the policies and principles for license renewal. We 12 determined that the main principles remain valid for subsequent license 13 renewal.
14 We then evaluated our regulatory frame work to 15 determine whether regulatory changes were needed to address these 16 principles. And what we determined is there were some changes 17 needed either because they met these principles, or they were unique 18 to the period beyond 60 years, or needed to maintain safety beyond 60 19 years.
20 We= ve included those in SECY-14-0016 for the 21 Commission= s consideration. And in that paper, we= re requesting 22 Commission approval that the principles for license renewal continue to 23 remain valid for subsequent license renewal.
24 And that in order to have a strong, clear alignment 25 between our regulations, guidance and implementation activities, that 26 the staff initiate a rulemaking process which would commence with the
67 1 development of a regulatory basis for those changes.
2 I will now turn to Bo Pham to discuss those regulatory 3 changes.
4 MR. PHAM: Thank you John. Good morning. The 5 SECY paper contains four options for the Commission to consider.
6 Option 4 includes the implementation of Options 2 and 3 with it. And 7 Option 1 offers no changes to the rule.
8 I am going to focus most of my comments on Option 4 9 because that= s the option that we have recommended in the SECY 10 paper. And as part of my presentation, I will also briefly talk about the 11 non-concurrence everybody was doing at the development of our 12 SECY paper. Next slide please.
13 The essence of what Option 4 proposes are two new 14 requirements. The first is a requirement for licensees to take actions 15 to insure the effectiveness of the aging management program during 16 the 60 to 80 year time frame. And the other is the limitation or 17 reduction of time prior to submittal of an application for subsequent 18 license renewal.
19 On this slide with respect the aging management 20 program effectiveness aspect of those two requirements, the staff is 21 asking that we consider a requirement for licensees to take specific 22 actions per the bullets in the slide here to insure effectiveness of the 23 aging management program.
24 And one of the drivers for this recommendation is the 25 result of our insight, the insights that we gain from conducting three of 26 the aging management program effectiveness audits at facilities that
68 1 were already in the period of extended operation.
2 And part of the findings that we found through those 3 audits is, in many cases, the documentation did not always lend itself 4 for the staff to get a good understanding or trace how aging 5 management programs were maintained, modified, changed over time 6 based on any implementation or operating experience that the industry 7 or the plants had undergone.
8 Therefore, the staff feels that the suggested rule 9 change to insure a consistent and a timely feedback to alert the NRC as 10 well as the industry regarding any changes to the aging effects or a 11 degradation mechanism.
12 It would also provide for reasonable assurance for safe 13 operation in the 60 to 80 year time frame in that it insures a continuing 14 focus on aging management and the safety impacts, as well as the 15 effectiveness and efficiency and ability for the NRC to provide oversight 16 and conduct inspection activities.
17 But most importantly, and I think this came up earlier, is 18 that it provides an enforcement mechanism to insure aging 19 management program effectiveness is maintained during the 60 to 80 20 year time frame. And without this, the staff is left to relay on volunteer 21 initiative by the industry.
22 So the -- for aging management effectiveness, there 23 are three components to this requirement that the staff is looking at.
24 The first is for the industry to, for the licensee to perform a self-25 assessment of the effectiveness of the aging management program.
26 This type of assessment is not unprecedented. We
69 1 currently require it for the maintenance rule, for fire protection program 2 and the emergency preparedness programs.
3 We believe that the self-assessment will provide 4 valuable information to the licensee, the industry as well as the NRC so 5 as to inform future changes to revisions of the programs to continue to 6 maintain effectiveness of the aging management programs.
7 The second component of the requirement is for the 8 licensees to report operating experience related to aging degradation to 9 the NRC. This change would insure that the licensee= s 10 self-assessment consider all the relevant aging concerns, whether 11 they= re generic or plant specific and would help the staff and the 12 industry stay abreast of all the relevant operating experience.
13 And the last component would require licensees to 14 report certain changes of subsequent license renewal activities.
15 Changes to the aging management programs today are managed 16 under the requirements in the 10 CFR 50.59.
17 The staff is currently looking at the effectiveness of the 18 use of 50.59 for this particular purpose. And identifying any needs to 19 ask for additional document -- licensing basis documentation for 20 subsequent license renewal as well.
21 So the specific details of what needs to be in the 22 specific requirements, the staff is hoping to develop further as we are 23 able to further engage with these stakeholders as part of the rulemaking 24 process. At this point we are asking for Commission approval for us to 25 go forth and initiate the rulemaking so that we can have this 26 engagement. Next slide please.
70 1 Option 4 also considers a change in the time frame 2 before an application for subsequent license renewal can be submitted.
3 The current requirement allows for an applicant to submit its application 4 the day it enters the period of extended operation for the first license 5 renewal.
6 And the situation may not allow for a sufficient time for 7 the licensee to gain sufficient knowledge and lessons learned from 8 implementing the aging management program for its first license 9 renewal. And therefore the staff believes that there should be 10 additional sufficient time for the licensees to implement these aging 11 management programs during the first license renewal in order to 12 demonstrate the effectiveness of the aging management programs.
13 And this information will be critical to the staff= s 14 assessment of the program effectiveness for subsequent license 15 renewal. So in order to address this, the staff is proposing that the rule 16 -- a rule change look at reducing the time frame from the current 20 year 17 that licensees are allowed to submit their application.
18 And as I indicated also, the details of specific time 19 frame, we= re looking at will be further developed as we are able to get 20 into the rulemaking process. Next slide please.
21 While it wasn= t a specific recommendation in the 22 SECY paper, Option 4 also had a discussion regarding the coordination 23 between subsequent license renewal activities with the current efforts 24 with Fukushima.
25 The reason this was included in the paper is that as 26 plants continue to operate further from their original license changes to
71 1 surrounding plant environments, such as the local water table, 2 meteorological patterns, or construction of nearby industrial facilities, 3 these changes could potentially differ from the plant= s currently 4 licensing basis without a requirement to assess the impacts on the plant 5 safe operation.
6 However, in developing the paper, the staff also 7 acknowledged and made a determination that validation or verification 8 of such changes would be more appropriately handled under a broader 9 effort by the agency to address it as part of the Fukushima activities.
10 Nevertheless, any resulting licensing basis change 11 that results that comes out of the Fukushima activities could have an 12 impact on the applicants that come in for subsequent license renewal.
13 And therefore we wanted to make the note and acknowledge that the 14 activities between subsequent license renewal and Fukushima needs 15 to be closely coordinated in the future.
16 As previously indicated, Option 4 also includes the 17 suggested rule revisions for implementing Options 2 and 3 in the paper.
18 The last three bullets on this slide summarizes and highlights the 19 recommendations of those options.
20 For the sake of time and because some of the 21 presenters this morning covered it already, I will go ahead and just not 22 rehash the descriptions of those. Next slide please.
23 As you know, a non-concurrence was filed as part of 24 the staff -- in the process of the staff developing this SECY paper. It 25 requests that the paper include an option for the Commission to 26 consider requiring applicants for subsequent license renewal to include
72 1 an upgraded probabilistic risk assessment, also known as a PRA in 2 subsequent license renewal application.
3 As part of the staff= s effort to review the current 4 regulatory frame work for license renewal, we considered many issues 5 as candidate issues for changes to Part 54, including this particular 6 issue of requiring PRA upgrades in subsequent renewal application.
7 We considered each of these issues against the 8 license renewal principles, whether the issue was unique to -- uniquely 9 relevant up to the period of extended operation from 60 to 80. And 10 whether the issue was needed to maintain safety for that period.
11 We then assess whether each of the issues could be 12 best addressed by the current regulatory process, by guidance 13 updates, or by actual changes to the current rule in Part 54 itself. And 14 while there may be benefits to the risk insights that can be provided by 15 an updated PRA in the application, the staff decided not to include this 16 option in the SECY paper for several reasons.
17 The first is that the PRA is not required to maintain 18 plant safety today. As currently intended, the PRA provides for risk 19 insights and identifying areas that may need more or less regulatory 20 focus and are used to supplement the staff= s current traditional 21 deterministic approach in license renewal.
22 Second the use of the PRA is not an issue that= s just 23 unique to license renewal. We believe that the benefits of using PRA 24 in identifying vulnerabilities or areas of additional inspection focus is 25 beneficial throughout the life of the plant and not just during the 26 operation beyond 60 years.
73 1 And finally, the license renewal applicants can use risk 2 insights into aging management programs activities today. The 3 statements of considerations from > 91 and > 95, as well as the 4 Commission= s policy on PRA use has always encouraged the use of 5 PRA in developing and implementing aging management activities.
6 As an example of that, you know, one program that we 7 often see is the risk informed version of the inspection -- in service 8 inspection program that are credited as aging management programs 9 for our applications right now.
10 So this concludes my remarks for the regulatory frame 11 work that we looked at for license renewal. I= ll now turn things over to 12 Dr. Mirela Gavrilas to discuss the ongoing research activities for 13 subsequent license renewal. Next slide please.
14 DR. GAVRILAS: Thank you Bo. The bulk of my 15 presentation is an overview of the important technical issues -- thank 16 you -- for which additional research is needed for subsequent license 17 renewal. I= d like to preface that discussion with a couple of comments 18 on the overarching staff efforts that led to the identification of these 19 issues. Next slide please.
20 While the industry has a responsibility for the resolution 21 of aging management issues, the staff has and will continue to perform 22 research to validate proposed industry solutions. This research is 23 primarily confirmatory in nature. And began with the nuclear plant 24 aging research program in the 1980s.
25 In 2008, the focus shifted on subsequent license 26 renewal. Specifically, we started accumulating and assimilating
74 1 information pertinent to light water reactors in their 60th through 80th 2 year of operation.
3 Technical staff throughout the agency has collated 4 domestic and international operating experience, laboratory work and 5 analytical methods. We participated in and hosted specialized 6 technical workshops in relevant disciplines. For example in 2012, the 7 staff, together with the Department of Energy, co-sponsored the Third 8 Nuclear Power Plant Life Management conference of the International 9 Atomic Energy Agency.
10 Also in the context of long term operations, we signed 11 memoranda of understanding with both the Department of Energy and 12 the Electric Power Research Institute to exchange mutually beneficial 13 information. We have been interacting regularly with both DOE and 14 EPRI on a broad range of technical issues relevant to subsequent 15 license renewal.
16 At the same time, the staff initiated specific activities to 17 ascertain what is needed to extend the technical basis beyond 60 18 years. One of the most important of these activities, and Bo 19 mentioned it already, was the recent evaluation of how aging 20 management programs were implemented at three plants. I= m going 21 to reiterate what Bo said.
22 The main conclusion of these effectiveness audits was 23 that while aging management programs have been incorporated in 24 plant procedures, the programs did not always document 25 enhancements. This suggests the need for a more systematic review 26 and assessment of the effectiveness of licensee aging management
75 1 programs as mentioned by Bo.
2 The effectiveness audits also identified the need to 3 better define what is meant by aging management program 4 effectiveness and inject more objective criteria into the definition. Next 5 slide please.
6 The summit of subsequent license renewal research to 7 date is the recently completed expanded materials degradation 8 assessment. The expanded assessment built on an earlier effort, 9 known as the proactive material degradation assessment, which was 10 documented first in 2007.
11 The word expanded refers to the fact that the current 12 work broadened the scope of work to inquiry beyond the reactor system 13 piping and vessel internals. The current work also extended a time 14 frame for the inquiry into examining material degradation scenarios up 15 to 80 years of operation.
16 The expanded materials degradation assessment was 17 cosponsored by the NRC and by the DOE under it= s Light Water 18 Reactor Sustainability Program as mentioned by Rich Reister this 19 morning.
20 The assessment was conducted by 28 internationally 21 renowned experts who populated four technical panels. One for piping 22 and internals. The second for reactor pressure vessel. A third for 23 electrical cables. And a fourth for concrete structures.
24 To capture the breadth of expertise and experience, 25 the panelists also had diverse affiliations. They came from the 26 industry, academia, national labs and regulatory bodies. The panelists
76 1 used phenomena identification and ranking techniques to ascertain the 2 susceptibility associated with know degradation mechanisms.
3 Their assessment considers specific materials, the 4 operating conditions during service, as well as the loads to which 5 components or structures are subjected. The assessment represents 6 a snapshot of the state of knowledge, domestic and international, on 7 technical issues relevant to subsequent license renewal.
8 It also identifies areas of additional research necessary 9 to support subsequent license renewal applications. Next slide 10 please.
11 In the next four slides, I= m going to highlight some of 12 the important conclusions from the expanded materials degradation 13 assessment. Specifically, I will focus on high susceptibility 14 degradation scenarios.
15 High susceptibility means that the panelists think there 16 is a strong likelihood that degradation will occur within 80 years. The 17 panelists base their conclusion on both plant operating experience as 18 well as laboratory data.
19 Panelists also classified scenarios according to level of 20 knowledge. High knowledge means that we understand and can 21 reasonably predict the progression of degradation over the operational 22 period. Conversely, lower knowledge indicates that additional data or 23 better models are necessary.
24 The panelists focused strictly on phenomenology and 25 did not examine anything related to managing the degradation. The 26 staff is therefore reviewing the report to determine where aging
77 1 management research is also needed.
2 The piping and core internals panel concluded that the 3 technical community has a good understanding of primary water stress 4 corrosion cracking. While testing continues in this area, it is primarily 5 motivated by the use of newer materials.
6 Similarly, the panel concluded that we have a thorough 7 understanding of how standing water and impurities cause pitting and 8 microbially induced corrosion in balance of plant systems. The panel 9 agreed that significant gaps exist with regard to irradiation induced 10 degradation of the internals.
11 The staff shares the panel concerns because 12 irradiation effects mechanical properties in many ways, including 13 reducing toughness as well as causing cracking and swelling.
14 Irradiation assisted degradation contributed to the failure of the baffle 15 bolt depicted on the slide.
16 In addition, both neutron fluence and temperature 17 effect material response. And it is not clear that the combined effect is 18 additive. Furthermore, the internals cover a variety of materials and 19 the responses of these materials to irradiation varies.
20 Of most concern is the fact that current data, only cover 21 a relatively low fluence range. And that testing can only be 22 accelerated by a limited factor.
23 The staff and industry are embarked on an effort to 24 harvest and test materials from the decommissioned Zorita plant in 25 Spain, which will provide much needed information about the irradiation 26 effects at significantly higher fluences. Next slide please.
78 1 The reactor pressure vessel had the benefit of 2 operating experience and targeted research that accumulated over four 3 decades. The panel thus concluded that while neutron embrittlement, 4 once the high susceptibility classification, is also a topic on which we 5 have high knowledge.
6 Therefore, the staff= s effort in this area are to maintain 7 a high degree of cognizance with regards to industry initiatives on 8 irrigation embrittlement surveillance at high exposure levels. The 9 picture on this slide shows an apparatus in a hot cell that was used for 10 testing surveillance specimens.
11 The staff is also engaged in consensus standard 12 activities that codify this large amount of technical information. Within 13 the reactor pressure vessel area, the only low knowledge scenario, is 14 that medium susceptibility and involves environmentally assisted 15 fatigue.
16 The staff is still studying what actions will need to be 17 resolved to address this gap. Next slide please.
18 A great deal of work has also been conducted in the 19 area of electrical cables. This work provided insights into how thermal 20 aging and irradiation effect long term cable performance.
21 Staff recognizes however, that additional work is 22 needed with regard to condition monitoring of cables. The staff is 23 conducting research at NIST and the University of Maryland on 24 indicators that can provide better confidence regarding performance of 25 cables under accident conditions.
26 To support this program, cables were harvested from
79 1 the decommissioning Zion plant, some of which are shown in the 2 picture on this slide. The industry is currently mapping service 3 conditions for the harvested cables.
4 Finally, less is known about the prolonged 5 submergence on low and medium voltage cables. The staff is working 6 with experts at the Sandia National Laboratories to strengthen it= s 7 understanding of this scenario. Next slide please.
8 The assessment of concrete structures including the 9 containment building, spent fuel pool and cooling tower, considered 10 degradation of the concrete itself as well as any metallic 11 re-enforcements. The panel concluded that sufficient knowledge 12 exists about degradation caused by outdoor conditions such as 13 freeze/thaw damage.
14 However, while we understand the chemistry of 15 alkali-silica reactions, as seen at Seabrook on the picture on the slide, 16 more information is needed on the progression and structural impact of 17 this degradation mechanism.
18 Similarly, more needs to be known about the effect of 19 long term irradiation exposure. The staff is working with NIST and 20 National Laboratory experts to address these gaps.
21 DOE and industry are harvesting concrete specimens 22 from commercial and test reactors to better understand the effects of 23 realistic service conditions. DOE and industry are also exploring more 24 effective, non-destructive examination technics for concrete structures.
25 I will conclude with a couple of summary thoughts. My 26 presentation covered some of the most important technical issues that
80 1 need to be addressed for renewing plant licenses beyond 60 years.
2 While significant research is underway, a lot still 3 remains to be done. The staff will continue to follow industry research.
4 As research results are provided to the staff by the industry, the staff will 5 scrutinize them for breadths and depths.
6 The industry results together with relevant 7 confirmatory staff research will be used to determine the completeness 8 and soundness of the technical basis for subsequent license renewal.
9 Thank you. And I= ll turn it back to John.
10 MR. LUBINSKI: Thank you Mirela. In summary, as 11 we= ve stated, we= ve reviewed the two principles for license renewal 12 and we believe they provide an effective basis to insure safety for the 13 subsequent license renewal period.
14 We request the Commission approve the 15 recommendations to initiate rulemaking to support subsequent license 16 renewal. And the staff will continue the research to support the 17 development of effective aging management programs and 18 confirmatory research on the activities that are being performed by the 19 industry.
20 MR. SATORIUS: Thank you John. And with that, 21 Chairman we= re a little over our time, so we= ll go right to your 22 questions or any clarifications that we need to make.
23 CHAIRMAN MACFARLANE: Great. Thank you.
24 Commissioner Magwood.
25 COMMISSIONER MAGWOOD: Thank you 26 Chairman. Always thank the staff or their presentations and for the
81 1 various conversations they= ve had about the SECY paper.
2 Before getting into that, I wanted to chat with Mark just 3 for a moment about slide 10. Because it was -- it sort of struck -- it 4 struck my office as a little different to see such an exhaustive discussion 5 about a non-concurrence.
6 I guess my reaction to this was that it seemed a bit 7 unfair. You know a person on the staff puts forward a 8 non-concurrence and then you spend a page talking about why it= s not 9 right. And I just felt that that was out of balance.
10 And I think it would have been better to give a very 11 short discussion about the fact that it was a non-concurrence and what 12 the staff= s response was. But if you= re going to provide such an 13 exhaustive discussion about it, I think it would have been fair to provide 14 the other side of the story.
15 So I -- it struck me as -- I don= t want to use the work 16 inappropriate, but certainly out of balance.
17 MR. SATORIUS: I understand what your position is, 18 and we= ll take for action as something we need to look at as we 19 prepare because we want to encourage the staff to feel free to come 20 forward with non-concurrences.
21 This one was a very carefully and well thought through.
22 And I studied it probably as much as I studied the Commission paper.
23 So I hear what you said, and will internalize that. And 24 do a better job next time.
25 COMMISSIONER MAGWOOD: I appreciate that.
26 So getting to the substance of the paper. Let me ask
82 1 -- let me start with a very broad question on this. Because you heard 2 the conversation with the previous panel and the industry 3 representatives put forward, very clearly their view that we don= t really 4 need to do anything in a rulemaking sense.
5 But offered, and this was a little bit of the different story 6 that I think I= ve heard in the past. Offered that they did recognize that 7 there are some lessons learned and need to be absorbed and that can 8 be reabsorbed in guidance.
9 What do you think, if you were -- if the Commission 10 were to approve Option 1, which is essentially take no rulemaking 11 action. But have a very comprehensive review of guidance.
12 What is the largest loss in that approach?
13 MR. LUBINSKI: Thank you for the question. You 14 know number one is if we= re putting Option 1 before the Commission, 15 we think it is something that could be viable and could work. What will 16 we lose?
17 I think what we would lose really is the transparency of 18 going forward with changes that are made in the regulatory processes.
19 We recommended going through to rulemaking so that we could get all 20 external stakeholder input and provide a reasonable basis for whether 21 or not to go forward with those changes or not.
22 So we= re asking for the initiation of that process go get 23 those external -- external input. As we go through guidance, we would 24 certainly seek external input on the guidance. But we believe the 25 process for rulemaking is a more established, more transparent, more 26 predictable for licensees.
83 1 As you= ve heard this morning from the industry, 2 they= re looking for some predictability so that they can plan whether to 3 come in for subsequent license renewal. So we think rulemaking gives 4 that predictability.
5 And then finally is, if we were to go through and 6 implement some of this through guidance, we would not have the clear 7 regulatory footprint, the regulatory hook to implement some of these 8 requirements if the industry did not voluntarily choose to implement 9 some of these activities.
10 If they did choose to implement this, these activities, 11 and they were done as we all agreed, everything would be fine. But 12 we would not have that assurance.
13 COMMISSIONER MAGWOOD: For example, the 14 reporting requirements, is that one?
15 MR. LUBINSKI: For reporting requirements, if I can 16 expand on that just for a minute, is that when we looked at the graph 17 and I= ll say the flow chart that Mr. Gallagher showed this morning from 18 the feedback mechanism, we do believe that works effectively.
19 And that is not voluntary. That is something that is 20 required by the regulations to have the aging management programs 21 under -- under their quality assurance program and to go through their 22 corrective action programs.
23 What we believe is missing from that is a proactive 24 effectiveness review of those programs. Not just reactionary based on 25 operating experience, but being proactive to determine whether or not 26 through conservatory research, those programs are continuing to be
84 1 effective.
2 And we think that= s important when you get beyond 60 3 years. So that would be the one additional requirement.
4 Secondly is the reporting. We do get information from 5 the industry either directly through INPO or through EPRI, sometimes 6 through our Office of Research. But it= s not a requirement for us to 7 get that information.
8 And we believe it= s important to have us get that 9 information to consider and any updates to the generic aging lessons 10 learned document. Or to take any specific actions we believe are 11 necessary.
12 COMMISSIONER MAGWOOD: Mark, did you want 13 to add something? It looked like you were -- oh, okay.
14 Let me also, let me ask you to follow up on, you heard a 15 conversation with David Lochbaum. I want to focus on the licensing 16 basis issue. And I think Mark, you and I have had this conversation at 17 some point in the past. It seems like we have.
18 Can you -- you heard the conversation, so I= ll just ask 19 you to react to that and see what the stats used are. I mean I think it is 20 not necessarily a license renewal issue, it= s really, I think it= s sort of in 21 the tenor of what Commissioner Svinicki mentioned.
22 This is sort of an issue right now. It= s not necessarily 23 an issue for license renewal. But it does come up on this context. So 24 I= d like to give you a chance to react to that.
25 MR. SATORIUS: Well as I look back at the history of 26 design based type issues and license reviews and how they= re all
85 1 linked, you know this -- the agency has a rich history of identifying when 2 we need to singularly focus on certain areas.
3 And I can remember back in the early > 90s when we 4 put together an engineering design safety functional inspection 5 program that was designed to do just that. To try to tie the licensing 6 basis together by looking closely at engineering issues within the plant.
7 And how they related to their licensing basis and 8 whether there were deviations from that or not. Because we were 9 seeing a number of these issues pop up, and one of the functions of this 10 inspection, and we= ve changed our inspection program even after we 11 put the old program away and went to the ROP.
12 We changed and added a component design basis 13 inspection that does similar sort of things, trying to tie the design basis 14 and the licensing basis together to get a firmer understanding of how 15 the plants operated, how it= s licensed.
16 COMMISSIONER MAGWOOD: Right, but -- and yet 17 you know Fort Calhoun for example, there= s still clearly plants that do 18 have some of these issues. Is it you= re suggesting that perhaps there 19 should be a separate consideration for an activity to try to capture 20 those, or --
21 MR. SATORIUS: Well I think -- I think that the reviews 22 we do on an annual basis, you know we just had the AARM, and we= re 23 scheduled I think to brief the Commission out on that annual meeting 24 here in the next month or so. We look hard at the ROP and are there 25 issues.
26 And by the way, we learn from Fort Calhoun so that we
86 1 can turn that around and make our inspection program better. And we 2 are making our inspection program better.
3 We= ve engaged in a review this year, and actually a 4 special review of the ROP where we= ve brought people that have a 5 history of inspection activities, former inspectors, that are now outside 6 of the ROP and outside of that.
7 Individuals that used to be inspectors and had 8 operated within the ROP so that they could take an independent view 9 as to is there anything within the ROP. And they came up with a 10 number of very, very thoughtful recommendations that we= re going to 11 need to get our arms around.
12 So I guess what I= m pointing to is that there seems to 13 be a bit of flexibility and we= re looking for -- always looking for areas 14 that we can change our inspection program so that we can be more 15 robust in being able to determine where our licensees are.
16 COMMISSIONER MAGWOOD: Here you, give 17 Jennifer a chance to add.
18 MS. UHLE: Thank you. I= m Jennifer Uhle, I= m the 19 Deputy Director of the Office of Nuclear Reactor Regulation. And just 20 to provide a specific example to compliment what Mark has stated.
21 In the case of Fort Calhoun as well as the seismic and 22 flooding walk downs, we do ask the question since we were looking at 23 design basis issues, why weren= t they caught under the Reactor 24 Oversight Program? So at this stage we= re going through and we= re 25 doing -- we= re looking at all of those actions on the restart checklist for 26 Fort Calhoun. We= re looking at the flooding information that was
87 1 determined -- that was found through the walk downs as well as the 2 seismic. And we= re looking to see which of those are safety 3 significant and therefore should have been caught under the ROP.
4 And then as Mark indicated, we= re taking that 5 information and we= ll be using that under our enhancement program 6 and our continuous improvement in the ROP. And looking to see 7 where we need to change the ROP.
8 COMMISSIONER MAGWOOD: Okay. Thank you.
9 Let me just ask one more question and wrap up. The staff 10 recommendation includes expanding the scope of regulation include 11 equipment under 10 CFR 50.54(hh2). Can you clarify that for me a bit 12 because the license renewal philosophy involves passive equipment.
13 So is it just the passive pieces of that equipment, or are 14 you expanding beyond passive equipment?
15 MR. PHAM: We -- I heard from the previous panel 16 discussion. We= re not looking to try to replicate what the existing 17 rules that are out there. The philosophy behind license renewal and 18 why we scoped in things that were safety related, non-safety related, 19 and then there= s the five regulated events.
20 We brought those things in not to replicate existing 21 regulations out there, but the intent of license renewal is to catch long 22 lived and passive components that are out there that are important to 23 safety, that we do need to have some aging management aspect in 24 order to maintain the intended function of those components.
25 At this point, and because of the nature of the plant 26 specific aspects of those equipment, to meet the requirements of 10
88 1 CFR 50.54(hh2), we were hoping to go forth and get the approval to go 2 forth and explore further in the rulemaking process to see you know, 3 what exactly, which of the equipment there are, the ones that should be 4 scoped in that are important to safety for aging management.
5 MR. LUBINSKI: But the short answer is yes, it is only 6 the passive aspects of those components. We= re not looking to scope 7 in any active components.
8 COMMISSIONER MAGWOOD: So for example?
9 MR. LUBINSKI: Well for example, if I start to look at 10 pumps and valves at the plants that are, you know the casing is a 11 passive part of a pump. So we would look at that under aging 12 management.
13 So we would have to look at other equipment. And 14 we= ve learned since we put the paper forward, that maybe just singling 15 out 54(hh) was not the best. And instead saying all those items that 16 are important to safety, and just looking at the passive components, 17 and the passive aspects of that. Not the active components.
18 COMMISSIONER MAGWOOD: Which I would think 19 was already captured by the license renewal rule.
20 MR. LUBINSKI: At this point the way it calls out the 21 issues, it had not called that out. And that would be something we= d 22 have to look at through the rulemaking.
23 COMMISSIONER MAGWOOD: Okay. Thank you.
24 Thank you Chairman.
25 CHAIRMAN MACFARLANE: Commissioner 26 Ostendorff.
89 1 COMMISSIONER OSTENDORFF: Thank you 2 Chairman. Thank you all for our presentations. I= m going to start off 3 with some comments before getting into any questions. One of the 4 beauties of having a Commission structure is we get a chance to talk in 5 public at these meetings about our viewpoints on certain things. And I 6 feel compelled to do that.
7 As Commissioner Magwood pointed out his concerns 8 on slide 10, and I respectfully had a different reaction to it then 9 Commissioner Magwood. And would suggest that the 10 non-concurrence was part of the public release -- public document that 11 is released.
12 I met in my office before this meeting a couple of weeks 13 ago with the non-concurrer. And rather than thinking this may be --
14 and I don= t think Commissioner Magwood intended for this to be a 15 criticism of the non-concurrence process, maybe just the balance as to 16 how it is presented in the slide.
17 So I think, I just want to go on record for saying that I 18 think we have a very strong non-concurrence process. I think the 19 individual had a very cogent argument. I= m not going to say I agree or 20 disagree with his comments in this forum.
21 But I think that it= s a strength of this organization. I 22 think he very respectfully presented his arguments to the Commission 23 in this paper. And I just want to make sure that that message was part 24 of -- added to Commissioner Magwood= s comments.
25 MR. SATORIUS: I appreciate that. And to 26 Commissioner Magwood= s comments. The way I took it was that we
90 1 should be thoughtful about the manner that we put our slides together.
2 COMMISSIONER OSTENDORFF: And I agree with 3 that comment. Yes.
4 Let me go on and piggyback on Commissioner Svinicki 5 and Commissioner Magwood= s comments on the current licensing 6 basis. I completely agree with that line of questioning and the 7 concerns.
8 And in particular, Commissioner Svinicki= s comments 9 on the first panel to Dave Lochbaum that we should not wait for 10 subsequent license renewal to rectify deficiencies or shortcomings in 11 the current licensing basis. So I completely agree with my colleagues 12 there, and that= s outside the context of subsequent license renewal.
13 I= m going to be -- just talking to myself. I don= t think I 14 have a good feel as a Commissioner, and I= ve been here now you 15 know, four years. I don= t think I have a really good feel for ongoing 16 licensing actions that our staff takes to update the licensing basis.
17 And I think perhaps in the SRM, I= d ask my colleagues 18 consideration of maybe framing some type of an Information Paper to 19 come to the Commission to give us a better education perspective on 20 what= s going on in the licensing basis. Because I don= t think I know 21 enough.
22 I= m going with another comment. Every now and 23 then we have issues before the Commission, and this may be one of 24 those where the entire regulatory holistic approach to deal with issues 25 is not fully brought to the Commission. And I -- again, I= m not an 26 expert on these issues.
91 1 And I know that the first panel= s discussed it, you 2 discussed it in your presentations, Commissioner Magwood raised one 3 of these issues. But when we look at the reporting requirements or the 4 report mechanisms, feedback loops that include such things as the 5 maintenance rule, Part 50, Appendix H and quality assurance, the 6 reports of in service inspections during outages, and Jennifer Uhle 7 talked about reactor oversight process and then the Fort Calhoun 8 situation, the generic aging lessons learned issues. I think there= s a 9 whole envelope very broadly drawn around various things that come 10 into the NRC staff that have a nexus to this operating experience in the 11 context of aging management.
12 And so I want to associate myself with Commissioner 13 Svinicki= s comments that we ought to be very careful about trying to 14 re-label, or create duplicate or redundant programs if those 15 mechanisms already exist, maybe under some other taxonomy?
16 And so I think understanding fully what the different 17 programs are, I don= t know if the SECY paper is considered by the staff 18 a full compendium, appendix of all the different programs that have a 19 nexus with this or not.
20 And that= s kind of my question, is do we have a full 21 summary of all the different NRC nexus touch-points for the industry to 22 look at in the context of this decision? John, do you want to take that 23 on?
24 MR. LUBINSKI: Yes, the paper was definitely 25 focused just on subsequent license renewal. And what we were trying 26 to do is not come to the Commission with a full overview of current
92 1 licensing basis, current programs, except to say that we believe those 2 programs were acceptable.
3 And that any issues that come up as you= ve said, 4 would be handled today. We many times refer to it as is this a today 5 issue, or is this a license renewal issue? Meaning from the standpoint 6 of what= s the scope.
7 And if it= s a today issue, we need to handle it today.
8 Whether it= s in the ROP process, the current licensing basis, 9 regulations that we put in place that we would consider back fitting on 10 folks.
11 So we didn= t get into that full discussion of all those 12 programs.
13 COMMISSIONER OSTENDORFF: So let me 14 comment. Because I= m going to ask you to follow up on this.
15 MR. LUBINSKI: Sure.
16 COMMISSIONER OSTENDORFF: So the first panel 17 we heard two witnesses clearly say we are already providing this 18 information to NRC. Perhaps outside the context of an aging 19 management program issue, but I don= t know why -- I have a question 20 that I= m asking about.
21 Are we missing something in this paper because we 22 don= t have this full view of all the existing ROP, GALL, ISI, fill in the 23 blank, those kinds of programs?
24 MR. LUBINSKI: Okay. I would say I would hope 25 we= re not missing anything in the paper, because that was certainly not 26 our intent.
93 1 COMMISSIONER OSTENDORFF: No, I understand 2 it wasn= t the intent.
3 MR. LUBINSKI: Right. So I don= t think we are. I 4 think from the higher level standpoint of looking at this, to be able to say 5 what really falls within the scope of subsequent license renewal, you 6 know what are those issues that are unique when you get into 7 subsequent license renewal that require those changes?
8 And that= s why when we look at Option 4, and we only 9 had two discreet issues listed there, because we felt that the rest of the 10 regulatory processes were robust enough to handle that.
11 Some of the items in Option 2 or 3 are ones that would 12 also apply to the current license renewal program. And that would 13 consider us to look at whether we would backfit those, or just put those 14 on licensees that are currently coming in.
15 So I think we made that assumption. Now from your 16 first comment of understanding the licensing basis and maybe a paper 17 to the Commission on that, I think that would be an area where maybe 18 more information could be provided.
19 COMMISSIONER OSTENDORFF: And I= m not 20 saying it= s directly related to subsequent license renewal. But I think 21 we have all of these things, and I= m using my hand intentionally over 22 here, in the subsequent license renewal, and I think there= s perhaps 23 more interconnectedness in feeding into the information flow for the 24 NRC, that perhaps we need to better understand.
25 MR. LUBINSKI: And if I could also add to that, one, 26 and the comments that we made of aging management programs, I
94 1 think that was an area that if you were to look back and if I were to say 2 put a different term on it, I would probably not call it aging management 3 programs for license renewal. Because the aging management 4 program started from day one.
5 There were components whether they were active or 6 passive that had aging management programs in place. What we just 7 determined is when you hit that 40 year mark, and then you hit that 60 8 year mark, is that= s when there may be new degradation mechanisms.
9 It= s a chance that you have to re-look at those 10 programs to determine, because the basis for those were based on the 11 40 years or based on the 60 years. And it= s do we look at those and 12 say are they robust enough to continue beyond 40 years, beyond 60 13 years.
14 And as plants put those aging management programs 15 in place, they don= t have a new procedure. They don= t have a new 16 system in place that said these are the aging management programs 17 for the first 40, these are the ones for the next 20. It= s all one aging 18 management program on that component that puts this together into 19 one program. And inspections are done that way as well.
20 COMMISSIONER OSTENDORFF: Okay, I got time I 21 think for one last question, and it= s a fairly significant question and I= m 22 going to use Mirela as one example from your presentation, which I 23 thought was very helpful.
24 But big picture, guidance -- changes to guidance 25 versus rulemaking. Did you consider, and one of the comments I think 26 Mirela from your slide 12, I think you made the comment that aging
95 1 management programs do not always document enhancements. I= m 2 just using that one example as a context.
3 Is that something that could be changed via guidance 4 document change, or does that requirement rulemaking?
5 DR. GAVRILAS: I= ll let Bo answer.
6 MR. PHAM: Sure, and that= s what I mentioned in 7 terms of the insights that we gained from actually being at the sites 8 doing the audits and trying to gain that information.
9 Trying to do it through guidance would continue to get 10 -- keep us in this loop of are we doing engagement -- we have been 11 engaging with individual licensees in the industry regarding what type of 12 information would demonstrate with objective evidence how aging 13 management programs are being maintained on a living basis 14 basically.
15 However, without a regulatory footprint, I think at best, 16 the staff would have to -- the oversight folks would have to go through a 17 pretty -- the burden would be a lot on the staff to really trace back the 18 lack of documentation in some cases, of what= s available at the site to 19 show that this particular failure or indication from an inspection result 20 was as a result of them not performing what they were supposed to do 21 in the aging management program.
22 COMMISSIONER OSTENDORFF: So your concern 23 would be the footprint, the enforcement tool, is that what I= m hearing 24 from you?
25 MR. PHAM: Yes sir.
26 COMMISSIONER OSTENDORFF: Okay. Mirela did
96 1 you want to say anything else?
2 DR. GAVRILAS: Yes, if I can elaborate on what the 3 problem is as I -- as I hear about it, it= s these aging management 4 procedures have some -- cover multiple plants of different types and 5 different vintages.
6 So if it= s not clear in the documentation, we see that 7 the AMP evolved. The aging management program has evolved. But 8 we don= t see why that evolution.
9 And sometimes there= s aging related degradation that 10 ought to be flagged so that we make sure that it= s not just that one 11 particular unit that= s effected by it. But that information is distributed 12 throughout the fleet.
13 So that= s the kind, and if we= re seeing that after you 14 know, five years, I think the staff is wondering how are they going to 15 look at, how intractable is that information going to be after 20 years?
16 COMMISSIONER OSTENDORFF: Okay.
17 DR. GAVRILAS: I hope that helps.
18 COMMISSIONER OSTENDORFF: That does help 19 very much. Thank you Chairman.
20 CHAIRMAN MACFARLANE: Thank you. Just to 21 weigh in on this issue of non-concurrences. I strongly encourage you 22 to air non-concurrences. I think debate is essential to good regulation.
23 And so I would just encourage you to continue to do that.
24 For Dr. Gavrilas. You mentioned that you integrated 25 international experience into your assessment. What countries 26 participated?
97 1 DR. GAVRILAS: I can -- I know right off the top of my 2 head that Sweden was one of the countries. And I have -- Rob 3 Tregoning might know more examples.
4 CHAIRMAN MACFARLANE: Well you don= t have to 5 give me an exact list, but I= m interested in knowing whether they had a 6 similar process for extending licenses, and whether they focused on 7 passive components. You know whether they had similarly thought 8 about this, or whether they were different. And whether you found the 9 differences useful.
10 DR. GAVRILAS: The items that people looked at 11 under the EMDA were very limited scope. The -- everybody was looking 12 at degradation mechanisms. What= s going to happen between 60 13 and 80 years that we haven= t seen so far. And how much do we know 14 about what= s going to happen between 60 and 80 years.
15 However the staff overall has taken a look at how 16 license renewal is accomplished internationally. And I can talk about 17 the small effort under that. We= ve looked at the periodic safety 18 reviews that were conducted in 14 plants in nine countries that have 19 reactors similar to ours.
20 And we only looked, what can we learn? What type of 21 OE, operation experience they have, that we haven= t caught by other 22 means and other interactions with the international community. And 23 we found few. There= s been a couple of examples, but we found few.
24 And to complement that effort, so that was a targeted 25 effort on strictly technical issues linked to operating experience. But I 26 think that NRR had a complimentary broader look, and I= ll let John or
98 1 Bo mention it.
2 MR. LUBINSKI: If I can answer that question from two 3 parts. One from I= ll call the regulatory perspective is, in looking at 4 what other countries do with respect to license renewal and long term 5 operation, it varies greatly. And whether licenses are issued for ten 6 years or have no expiration dates.
7 There= s also many countries in the world implement 8 periodic safety reviews. And again, the way those results are handled 9 and implemented vary as well. Whether or not it= s a pure compliance 10 review, small safety issues or large safety.
11 Where we= re seeing a lot of consistence, we= ve just 12 participated with the International Atomic Energy Agency in developing 13 an international generic aging lessons learned report that really goes 14 towards long term operations with the definition being again, depending 15 on the country whether your consider 20, 40, 60, 80 years to be long 16 term.
17 Where we= re sharing the technical information of what 18 kind of material degradation mechanisms are we seeing? What are 19 we seeing in concrete? What are we seeing in cables? So that we 20 can get a sharing of that.
21 But we were heavily involved in that. We expect the 22 first version of that to come out soon. And we expect that IAEA will 23 continue to develop additional revisions to that. And that= s the 24 information that we= ve seen used by many countries in determining 25 what type of aging management programs they use.
26 CHAIRMAN MACFARLANE: So how many countries
99 1 are considering going out to 80 years?
2 MR. LUBINSKI: At this point we haven= t done a poll, 3 but what we= ve got so far is that many of them have a -- as I said, it 4 varies. That they have no expiration date. And in some cases where 5 they have no expiration date, what they= re doing is relying on their 6 periodic safety reviews.
7 And as part of that, some are requiring additional 8 safety enhancements. Some are looking at 40 years to require those 9 additional safety enhancements. Some are looking at 60 years. I= m 10 not aware of any that made any decisions at this point as far as going 11 beyond 60.
12 CHAIRMAN MACFARLANE: Yes. Because the 13 feedback that I received at a recent international meeting was shock 14 and awe at going out to 80 basically. So I don= t know that the 15 international community is on board with that.
16 And I also heard a lot of input about you know we now 17 are having these, and I think this gets to some of the points made by --
18 in the non-concurrence.
19 We now have these plants, these Gen Three plants.
20 And they have, you know they= re safer. And there are additional 21 requirements on them like PRA for instances.
22 And so how do you reconcile allowing the existing 23 plants to go out to 80 years without putting some additional 24 requirements on them like that?
25 MR. LUBINSKI: I= ll answer that in two parts. And let 26 me start with when we hear that from the international community, we
100 1 were at a conference recently and as part of their periodic safety review 2 of 40 years, one country was requiring an analysis against a generation 3 three design reactors.
4 And what they said was that plants would need to 5 make any changes that they found reasonable and practical to meet 6 that design. But they had no clear definition of what reasonable and 7 practical meant.
8 And that= s what they were trying to determine. So 9 therefore it= s unclear when they say they= re going in that direction 10 what they= re doing.
11 From the standpoint of how we see it in U.S. today, and 12 our belief is, we look at the issues of whether you= re going to a new 13 reactor design, generation three design, additional safety 14 enhancements, we think that should be done as what again, I= m 15 referring to as a today issue, not a part of subsequent license renewal.
16 We believe all the reactor designs that are in place 17 today are safe today. Some of them have been operating 46 years. If 18 they were not safe, we would take action today. We believe they= re 19 safe.
20 We believe as you continue to move forward that 21 licensing basis has been enhanced to improve safety. There= s no 22 longer the 600 Alloy, they= re now going to different alloys. They= re 23 making changes, they= re more robust.
24 So the safety profile again, is enhanced today. So we 25 think that= s acceptable. If we felt there was an enhancement needed 26 across the board, we wouldn= t wait until 60 years to do that in the
101 1 process we would do it today especially given the age of the reactors.
2 Some reactors were licensed in the > 90s are we going to wait another 3 40 years to put those enhancements in place? If we felt they were 4 something that should be done, we would recommend doing it today 5 across the board, and not based on just the age of the plant.
6 We believe what= s important to age is the aging of the 7 components. And taking those actions with respect to aging of those 8 components to make sure they= re safe.
9 CHAIRMAN MACFARLANE: Right. It seems to me 10 that we do expect degradation to occur, correct?
11 MR. LUBINSKI: We know degradation will occur, yes.
12 CHAIRMAN MACFARLANE: Will occur, okay, good.
13 If that= s the case, there are significant uncertainties it seems to me as 14 we look out to 60 to 80 years in terms of the processes that occur, the 15 interactions among different processes and systems that make it 16 difficult, that make the uncertainties increase in terms of our ability to 17 really understand what will happen.
18 Shouldn= t we in that -- in the face of that, consider and 19 use all the tools available to us to make sure that we really understand 20 what will happen? And those tools will include PRA.
21 MR. LUBINSKI: We believe that if a licensee can 22 come to us and identify what those degradation mechanisms are, as I 23 said, we expect degradation, we know occurs. If they can identify what 24 the degradation mechanisms are, and have an adequate program in 25 place that identifies when they can identify it, that is the frequency of 26 inspections, the frequency of testing, so that it is identified before it
102 1 becomes a safety issue, then we believe that that= s an adequate 2 program and they can continue to operate.
3 So addressing those safety issues would be that once 4 they identify that degradation issue before it becomes a safety issue, 5 they would either have to mitigate or repair, or if they have not identified 6 a way to do that, then they would have to replace that component.
7 CHAIRMAN MACFARLANE: Yeah, I= m going 8 beyond the specific degradation mechanism on this specific you know 9 pipe here but trying to understand the interactions that might occur.
10 You know I think that that= s a piece of it that I= m not sure that we really 11 can get our hands around very well with the tools that you= re currently 12 using.
13 Let me ask another question. You know there are a 14 number of problems that are of course introduced by using new 15 materials, replacement materials that are not an exact match, 16 replacement systems that are not an exact match, replacement 17 equipment that= s not an exact match, have you considered that in 18 thinking out to 60 to 80 years? And how would you consider that?
19 MR. LUBINSKI: We do consider that. And maybe 20 Mirela can add to one of the examples. As we= re starting to look at 21 some of the new materials, again they= re looking at materials that you 22 put in place that aren= t going to have degradation mechanisms.
23 And of course as we said, at some point in time, 24 they= re going to have that. What we= re finding now is that as they= re 25 looking at some of these new materials, they= re so robust that they= re 26 even having trouble identifying what those degradation mechanisms
103 1 are, and how to get to it.
2 The number of cycles that they= ve put into it, the 3 temperature, the irradiation, so we= re seeing that the new materials are 4 very robust. So if they= re more robust than the current materials, and 5 they stick to the current programs of inspection, identification and 6 frequency, then that adds an additional margin of safety.
7 CHAIRMAN MACFARLANE: Yeah, I= m just thinking 8 about steam generators basically.
9 MR. LUBINSKI: And maybe Mirela can respond to 10 the steam generator issues.
11 CHAIRMAN MACFARLANE: You know, not just the 12 -- I= m thinking about the materials and I= m thinking about the structural 13 aspects. That= s what I= m thinking about. And you know, how -- and 14 there are going to be other things besides steam generators as 15 material.
16 And you know, and we= re not the only ones thinking 17 about this. The nuclear weapons complex is also thinking about 18 similar kinds of things, you know. Do we share knowledge?
19 MR. LUBINSKI: My answer was based on a materials 20 degradation mechanism there. And when you talk about design and 21 designs going in place, if someone is replacing the design, I believe we 22 have a robust program in place right now from the standpoint of our 23 regulations and our oversight programs.
24 When the issues are identified where there may be a 25 design issue, as Mark said, we look at our oversight program to 26 determine if there= s lessons learned from that. I think what has been
104 1 a success in many of these cases is we have identified these issues 2 before they= ve become a significant safety issue.
3 So the programs are working from the standpoint of the 4 oversight to identify before they become an issue, even in the current 5 processes today.
6 CHAIRMAN MACFARLANE: Okay, thank you.
7 DR. GAVRILAS: The only thing that I would add to 8 that, talking about the materials, the example that you= ve given, I was 9 thinking of the other part of the steam generator, the transition from 600 10 alloy to 690 alloy --
11 CHAIRMAN MACFARLANE: Yes, that= s what I was 12 thinking too.
13 DR. GAVRILAS: Which was a tremendous benefit in 14 terms of degradation of the tubes themselves. And I brought up in my 15 presentation for primary water stress corrosion and cracking. We 16 continue to have research programs.
17 We continue to research the tubes that have 690, and 18 we continue to look at the new replacement materials and how 19 susceptible they are to -- even though they= ve been designed to 20 withstand it much better.
21 CHAIRMAN MACFARLANE: Okay. Commissioner 22 Svinicki.
23 COMMISSIONER SVINICKI: Well thank you all. I 24 know there= s occasionally some impatience with my continually 25 passing myself off as an amateur historian. But I= ll begin by reflecting 26 back on the initial 40 year period for licenses issued in the United
105 1 States.
2 And I= ve tired to study the history of that. My 3 understanding of it is that 40 years had essentially little or nothing to do 4 with the aging of anything. It had to do with economic considerations.
5 And given this very young energy source, and young 6 industry in the United States, it was viewed that anyone embarking 7 upon building a plant would need some assurance of a period of time 8 within which they could recoup their investment. So it had -- was 9 almost entirely driven by economic considerations.
10 But you know, I think it= s also human nature to sit and 11 say, as I sit today, the uncertainties and the challenges and the 12 complexities of what= s in front of me, are so unprecedented and are so 13 much harder and more difficult then what people had to deal with.
14 But I think that probably AEC Commissioner sat and 15 looked at such a young technology and how little operational 16 experience there was about it. And had to decide to issue or not issue 17 these 40 year licenses.
18 So imagine that they struggled at least antidotally or in 19 an analog sense with some of the same things that we= re focused on 20 here. Also our colleagues a few decades ago had to look at the 40 to 21 60 year period and had to address some of these same challenges.
22 So I appreciate John= s acknowledgment that aging 23 management, if you just want to think about it in the English language 24 term, began on day one. There were a lot of technologists and 25 regulators having to think about this from the day that this country 26 embarked on a nuclear power program.
106 1 In light of that, I want to take a couple of the specific 2 things that were put forward as things that doing a rulemaking could 3 help us to better capture. John you mentioned -- first of all you 4 acknowledged that the flow chart that we saw from one of the external 5 panelists is not a voluntary system that is the formal mechanism for 6 feedback and OE collection and feeding that back through programs.
7 But you indicated that if we -- one of the things that we 8 would establish and could possibly benefit from is a proactive 9 effectiveness review of aging management. I would ask you if we 10 require in regulations, an effectiveness review for anything that would 11 be analogous, like maintenance programs, or engineering programs at 12 plants.
13 Do we have a parallel provision for operating reactors 14 right now that would be similar to the type of, you= re saying a proactive 15 effectiveness review. Do we have that in place for other things?
16 MR. LUBINSKI: Yeah, I would say from the 17 standpoint of -- and we have some people here who can talk about our 18 maintenance rule on the active programs.
19 But one of the differences there again, you= re talking 20 about active components replaced much sooner, more testing. So it= s 21 not as important in those areas.
22 I believe we do have similar type programs. When we 23 start to look at emergency preparedness, we do look at the 24 effectiveness of the emergency preparedness programs, and do those 25 types of reviews as well.
26 So it= s not totally unprecedented we would look at
107 1 having people go back and review their programs themselves. At this 2 point it just is a little bit different from the standpoint of it= s on a 3 component versus a process where most of ours I think are more 4 process oriented.
5 COMMISSIONER SVINICKI: I mean it= s clearly 6 something that one would benefit from. Do you think -- do you predict 7 now that we would have a strong basis for making this a compulsory 8 regulatory requirement or is that something you= d have to develop 9 through the rulemaking process?
10 MR. LUBINSKI: We would definitely have to develop 11 through the rulemaking process. That= s the first step.
12 COMMISSIONER SVINICKI: Not everything 13 beneficial can be compelled.
14 MR. LUBINSKI: That is correct. And when we 15 looked at what we propose forward is, the first step is to develop that 16 what is really the cost of the program? What are the benefits of the 17 program to do that analysis. And that= s what we= re seeking from the 18 Commission, is for just those specific items, to do that initial analysis 19 and do that reg analysis to determine whether or not we believe it= s 20 viable to go forward in these areas.
21 We may found out it= s not possible. We may find out 22 there= s not as much benefit as we= re thinking, or we may find out that 23 the cost is just extraordinary. But we want to start that first step in the 24 process.
25 We= ve been asked by the industry if we= ve done a 26 cost benefit analysis of all these recommendations, and the answer is
108 1 no, we have not done that yet. Because we don= t want to start down 2 that process until we get the Commission providing direction and 3 guidance on whether it= s even worth pursuing these as options.
4 COMMISSIONER SVINICKI: There was also a 5 response give by the staff that it would be beneficial for certain aging 6 degradation experiences to be flagged, that was the term used, and 7 reviewed for their applicability throughout the fleet. My understanding 8 of most of our, or our formal OE, or our operational experience 9 programs would be that that is one of the principal purposes, is to flag 10 things that may have potential applicability throughout the fleet.
11 Is there some reason why operational experience that 12 related to aging degradation would not be evaluated in that way under 13 our current system?
14 MR. LUBINSKI: If you look at the current regulations 15 on what= s reportable, some of the aging management programs, and 16 some of the effectiveness of the aging management programs may not 17 meet the threshold of being reported to the NRC. We may be getting 18 some of that voluntarily.
19 COMMISSIONER SVINICKI: It may be more the 20 benefit would be you= d have trending of lower significant items that are 21 currently not reported.
22 MR. LUBINSKI: Well they seem to be low significant 23 at this point because you= re early in the aging process. But I wouldn= t 24 want to call them low significance overall because just because we= re 25 seeing -- you know, seeing today it= s not an issue --
26 COMMISSIONER SVINICKI: Because we don= t
109 1 know.
2 MR. LUBINSKI: We don= t know. So that= s where 3 we want to be able to get that information. I wouldnt -- rather than call 4 it low significance, is early indicators to be able to get information on 5 what could be an early indicator of a problem.
6 COMMISSIONER SVINICKI: Yes, the gentleman at 7 the microphone.
8 MR. HOWE: Yes, good morning and thank you, I= m 9 Allen Howe, I= m in the Division of Operating Reactors -- Division of 10 Inspection and Regional Support, thank you.
11 COMMISSIONER SVINICKI: Well then I don= t feel 12 bad not knowing you. If you don= t know what division you work in.
13 MR. HOWE: I was going to the operating experience 14 piece of it. There= s a -- there= s a --
15 COMMISSIONER SVINICKI: Welcome to the NRC.
16 MR. HOWE: Yes thank you. There= s a lot of 17 different types of information, data streams that the operating 18 experience team looks at. One of them is the licensee event reports.
19 We also look at inspection reports. We also look at international 20 experience. And in addition to that, we also have -- we look at industry 21 information as well.
22 So there= s a lot of different things we look at and 23 assemble and accumulate to come up with are we seeing any issues or 24 any trends associated with equipment issues and you know, potential 25 trends and failure mechanisms.
26 And one thing that I would add, is that we= re looking at
110 1 everything in terms of component failures. Not just aging related 2 component failures. We= re neutral on what the cause is. We= re 3 looking at all those things. And assessing that and evaluating whether 4 or not we need to take any additional regulatory action.
5 COMMISSIONER SVINICKI: Okay, I appreciate that, 6 and particularly because it comports with the general understanding I 7 had of the robustness of our evaluation of that. But again, I think the 8 distinction that John is pointing out to me is that if things don= t make it 9 into that system, then you don= t know anything about them because 10 they didn= t make it into the system.
11 MR. HOWE: Correct.
12 COMMISSIONER SVINICKI: Okay, so at least I 13 understand now that OE is very thoroughly evaluated, but only the stuff 14 that= s reported, okay. So I appreciate that distinction.
15 The last item that I wanted to talk about was that one of 16 the elements, if the staff moved forward to rulemaking, that they would 17 at least examine is abbreviating potentially the period of time that a 18 licensee would have to come in in advance of license expiration for a 19 subsequent license renewal.
20 And again, I= ll put on my amateur historian hat, in the 21 history I= ve studied about the current frame work that we have, was 22 that the Commission and the staff at that time, evaluated, well gosh, if 23 you need to come in and get through this system, and if it= s a renewal 24 review, some applications will likely move quicker than others.
25 There= ll be issues flagged.
26 And then if applicants were to wash out of that system
111 1 and you found out that you couldn= t operate the asset, then that region 2 or state or whatever, you know transmission area, would need to look at 3 replacing that generating capacity, no matter what kind of capacity you 4 put in, you= d need to the time to do that. To do the permitting and get 5 it approved and get electricity installed.
6 Because generally, citizens don= t like to flip that switch 7 and not have electricity. So it is a matter of needing some advanced 8 notice on that.
9 So if I were to posit this to you, I= d like you -- any of you 10 to react to this, which is that so if at that time period where there was a 11 lot more rate regulated generation, where there was not, I don= t think 12 as many, or maybe even any, renewal portfolio standards in states.
13 You did not have under contemplation, changes to 14 carbon regulations under the Clean Air Act. You did not have 15 substantial changes to EPA requirements regarding cooling water and 16 other things like that.
17 If the Commission at that time felt like 20 years was 18 absolutely needed, if I were to say to you, that given the state of the 19 energy landscape in the United States right now, this seems like almost 20 the worst possible time for NRC to be potentially abbreviating the 21 planning period.
22 And then perhaps the replacement generating capacity 23 that you might need here. That this is, if anything 20 years, maybe 24 even need 30 years or 40 years.
25 And my second point is that the staff based this 26 potential change on the fact that we need perhaps more time for the
112 1 aging management programs, and for people to be operating in the 2 extended period of operations. We already have today 56 years of 3 reactor years of operating experience in the PEO, period of extended 4 operations.
5 And that grows really, really fast. Because the first 6 year of that 56 years happened while I was already on this Commission, 7 and I haven= t been on the Commission for 56 years. So, although it 8 might feel like it.
9 So that= s going to grow really, really quick, that body of 10 knowledge over time. Because we have a -- we= ve renewed 73 more 11 entering their period of extended operations.
12 So, how would you react to all of that saying that the 13 basis for abbreviating that period now is probably -- there= s even a 14 basis to keep it the same or have it long.
15 MR. LUBINSKI: Let me start with from the standpoint 16 of planning, and you heard this from Mike Gallagher this morning, is 17 that they= re looking from a planning, as you said from energy, and 18 looking a the energy, we do need to have that planning.
19 That would be something that we would look at in what 20 I= ll call the cost side of it. What would be the impacts, what would be 21 the costs if we were to do the regulatory analysis and then moving 22 forward in this area.
23 So we would consider that aspect. But what= s more 24 important though, going forward is, we= re not going to approve a 25 license, whether it= s for license renewal or subsequent license 26 renewal, unless we have a reasonable assurance that they can
113 1 manage the aging of the program.
2 What we= re trying to achiever here is more of the 3 predictability and the transparency in coming forward. If a licensee 4 were to come in today as an example, at year 40, and the licensees can 5 do this today. The rule does not prohibit subsequent license renewal.
6 They could come in today and ask for subsequent 7 license renewal. What would we do with that application?
8 If we didn= t have the information to be able to make a 9 determination that their aging management programs are effective, we 10 would basically be telling them go back and do more work. And we= d 11 have the application sit on the shelf for a few years.
12 What we= re tying to do is take that out of the process.
13 We= re trying to make sure that before the first application comes in, we 14 have an adequate basis that says, here= s what the needs are, here= s 15 what the information is. Here= s what we consider needed to make 16 sure we have an effective aging management program.
17 And we think when we look out to beyond 60 years, 18 again, when you hit day one of going into your period of extended 19 operations, and you= re already coming in and asking for another 20, 20 we think we need more information.
21 COMMISSIONER SVINICKI: Well, I mean all I want 22 to say to that is that the staff did not have experience by each licensee 23 of how they implemented an aging management program when you did 24 the first round of renewals, and you were still able to recommend that 25 those licenses be renewed.
26 So with that I yield back. Thank you.
114 1 MR. LUBINSKI: Thank you.
2 CHAIRMAN MACFARLANE: Okay, thank you.
3 Commissioner Apostolakis.
4 COMMISSIONER APOSTOLAKIS: Thank you. On 5 slide nine, which Mr. Pham you presented, under other rulemaking 6 considerations, you list licensing basis update. And in the notes, you 7 say the reason this is included in the SECY, is that as plants continue to 8 operate further out from their original license, changes to the 9 surrounding plant environment could potentially differ from the plant= s 10 current licensing basis.
11 Is that unique to license renewal? Why didn= t you do 12 it today?
13 MR. PHAM: Well at the time where we looked at 14 where we were developing the paper, by virtue of looking at the 15 possibility of operating beyond 60 years or so, that possibly wouldn= t 16 exist today. So because of that, we linked that to a potential issue that 17 is only unique to subsequent renewal itself.
18 COMMISSIONER APOSTOLAKIS: Why is it unique?
19 I mean if there are changes like the example you had mentioned here, 20 local water table, construction of nearby industrial facilities over time, I 21 should do that today.
22 MR. LUBINSKI: And I guess we= re both coming from 23 -- when we were making a determination whether it was unique to 24 license renewal, that was our first thought is this would be unique at the 25 60 year mark. And then we said really it= s not. And that= s why we 26 chose not to put it into the paper as a recommendation.
115 1 Instead we looked towards what= s being done in 2 response to the near term task force on Fukushima and said they= re 3 already looking at the flooding and the seismic issues. Under 4 recommendation 2.2, they= re going to consider rulemaking to include 5 additional environmental.
6 So what we= ve done, is we= ve asked the team that= s 7 looking at that to consider these today as current licensing issues and 8 how often those should be done rather than linking it just to the 60 year 9 mark.
10 But we felt that it was important to put into the paper to 11 the Commission to let you know that we did recognize that these are 12 time sensitive items. They will change over time.
13 One may consider that it= s done during license 14 renewal or subsequent license renewal, but instead we felt tying it to the 15 near term task force recommendations was a better pathway for 16 resolving the issue.
17 COMMISSIONER APOSTOLAKIS: So the licensing 18 basis update then will not be part of the other rulemaking 19 considerations, is that what you= re saying?
20 MR. LUBINSKI: Yes.
21 COMMISSIONER APOSTOLAKIS: Okay. That= s it 22 for me, thank you.
23 CHAIRMAN MACFARLANE: Okay. Any further 24 questions?
25 COMMISSIONER MAGWOOD: Just a couple of 26 quick comments rather than a question. First in listing to
116 1 Commissioner Svinicki= s historical analysis of the consideration of how 2 long the terms of licenses were, I= m reminded of Satchel Paige= s 3 famous comment upon people asking about his age, because when he 4 came to the major leagues, he was well into his 40s.
5 How old would you be if you didn= t know how old you 6 are. And I think that somehow in a weird way applies to what we= re 7 talking about here. Because it isn= t so much what the number of 8 years is, it= s really what is the physical condition and what are the 9 programs to assess that condition.
10 So the time doesn= t really matter that much. So, just 11 a gratuitous comment, but.
12 COMMISSIONER SVINICKI: Can I make a general --
13 COMMISSIONER MAGWOOD: If you must.
14 COMMISSIONER SVINICKI: I actually -- someone 15 said to me the other day, said Plant X entered their period of extended 16 operations. And I said does the plant know? Did anyone tell the 17 plant?
18 The plant does not know it is in it= s period of extended 19 operations.
20 COMMISSIONER MAGWOOD: Which makes 21 Satchel Paige= s comment even more appropriate. That actually I just 22 wanted to, I thought the conversation, I kind of think some of 23 Commissioner Ostendorff= s questions also brought this out. There 24 does seem to be a conversation we need to have about what can be in 25 guidance and what you lose if you go guidance versus rulemaking.
26 I think it would be useful to have a Commissioner
117 1 Assistance Briefing to talk this through a bit to make sure we have a 2 pretty full view of how this would work. And what we would lose if we 3 go down the rulemaking -- or excuse me the guidance path versus 4 rulemaking path. So I kind of --
5 MR. LUBINSKI: We can arrange that.
6 COMMISSIONER MAGWOOD: I= d like to have that 7 added to the consideration for the SRM. Thank you. Thank you 8 Chairman.
9 CHAIRMAN MACFARLANE: Anybody else?
10 COMMISSIONER APOSTOLAKIS: Yeah I do.
11 CHAIRMAN MACFARLANE: Okay.
12 COMMISSIONER APOSTOLAKIS: There is a 13 practical issue it seems to me here. And an issue of consistency. I 14 think the Chairman alluded to it a little earlier.
15 I can= t reconcile in my mind that we are demanding a 16 summary of a PRA from reactors that are much safer than the current 17 feet. And then we dismiss the opportunity to demand a similar 18 summary. This is an opportunity of 60 to 80 on the basis that it is not 19 unique to aging. Or to the license renewal.
20 I don= t know why that is. In the AP1000, of the 21 ASBWR and so on, they have all these passive systems and lessons 22 learned from past experience. And yet in Part 52, we ask them to give 23 us a summary of their PRA.
24 And here is an opportunity to do it for the operating 25 fleet which also would help with the issue I mentioned in the previous 26 panel of communication. And were just dismissing it as not being
118 1 unique to license renewal. I mean there are practical issues too.
2 We can= t -- my understanding of the regulations is that 3 today we cannot demand such a thing because of the backfit rule. But 4 this subsequent renewal rule gives us an opportunity to do it.
5 MR. LUBINSKI: If I could add two points to that is that 6 as you said, when we look at the benefits of a PRA, we look at that as 7 saying, again, it= s not unique, therefore if we= re going to do it, we 8 should consider it across the fleet today.
9 When you talk about backfit. From the standpoint, 10 could we backfit this on the existing 73 licenses that were issued?
11 We= d have to go through a backfit analysis and determine whether 12 that= s the case or not.
13 You can make an argument that maybe you could pass 14 the backfit because it= s only a reporting requirement and activities 15 Also you could make a decision today that it applies to the plants that 16 have not gone through the current license renewal. If you think it= s 17 that important, you can do that today.
18 Also, from the backfit rule, if we felt it was important 19 enough, we could choose to make that decision. I would turn to 20 Margie as far as the Commission= s authority to be able to do that.
21 But from the second standpoint as far as part of 22 subsequent license renewal. What we also need to understand is how 23 you= re using the PRA and the information. Currently we= re saying 24 that the current principles of license renewal are valid and should 25 continue to move forward.
26 If you used a PRA for subsequent license renewal, are
119 1 we now scoping in the active components into that as well, because 2 there= s a large benefit in your PRA to what you= re looking at as far as 3 the active components.
4 So the question would be, and we would need to 5 understand if the Commission went in that direction, are we changing 6 what we= re looking at as the underlying premise of license renewal, to 7 now expand it beyond passive components. Or only the use of PRA 8 for passive components, in which we would not see as much of a 9 benefit.
10 If we are expanding beyond the current premise where 11 we= re only looking at the passive components to active components, 12 then we= d have to look even broader to say are there other areas 13 where we should be making these kinds of changes.
14 So its that first premise of only focusing on the passive 15 components for the aging where we said this was not the right 16 opportunity to do that and should again be looked at across the board 17 consistently.
18 COMMISSIONER APOSTOLAKIS: First of all I don= t 19 think we can do it for the current fleet now because of the backfit rule.
20 So that= s what I= m saying was a practical opportunity to do it in the 21 license renewal 62.80.
22 But this inconsistency of demanding something from 23 plants that are safer, and the other thing is, how long do you think this 24 agency is going to have a two pronged regulatory system? The safe 25 plants will also have PRA. The safe plants, but not as safe -- will not?
26 So we go to 80, maybe we= ll go beyond that later. I
120 1 just don= t see how the regulatory system is self consistent that way.
2 MS. UHLE: This is Jennifer Uhle. Talking about 3 whether in fact a licensees do have PRAs, I mean part of a decision for 4 rulemaking is of course is something already in place voluntarily. And 5 in our recommendation one paper, we did highlight that voluntary 6 measures are acceptable provided they are updated.
7 And that we can make sure that these tools are being 8 used. And in the case of PRA, our regulatory system uses, for the 9 operating reactors, not the new plants, uses PRA throughout our 10 regulatory system in the reactor oversight process, in the industry 11 trends process, in the looking or accident sequence precursors, in our 12 backfit determinations, in our issue --
13 COMMISSIONER APOSTOLAKIS: And I agree with 14 all that.
15 MS. UHLE: in our generic issue program. So part of 16 the staff= s view is that we feel that PRAs are being used for today= s 17 plants.
18 COMMISSIONER APOSTOLAKIS: And I would like 19 to know the reasons the Commission made it a requirement of Part 52.
20 Because we would be doing those things also for the new reactors.
21 And yet the Commission felt that now it would be a requirement.
22 I= m bothered by this inconsistency, but I don= t think 23 we can resolve the issue today. Thank you.
24 CHAIRMAN MACFARLANE: Anybody else? No?
25 Okay. In that case, I will thank the panelists, both the external 26 panelists, and the staff very much for their presentations and for the
121 1 discussion. And we are now adjourned.
2 (Whereupon, the above-entitled proceeding was 3 concluded at 12:15 p.m.)