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Transcript of 930930 Meeting in Bethesda,Md Re License Renewal Workshop.Pp 1-120
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Issue date:	09/30/1993
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~. . -... ~. -. _ - -... 1 UNITED STATES 1

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i 3 i 4 5 LICENSE RENEWAL WORKSHOP 6 7 6 9 Thursday, September 30, 1993 j 10 11 I2 Versailles III & IV Holiday Inn Bethesda 13 8120 Wisconsin Avenue .14 Bethesda, Maryland 15 16 17

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19 20 21 ~ 22 23 24 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

I ~l 2 f i L 1 APPEARANCES: 2 3 Bill Travers, Chair, Deputy Associate Director, Advanced j 4 Reactors and License Renewal j Tom Murley, Director, Office of Nuclear Reactor Regulation l 5 I 6 Sterling Franks, Department of Energy 7 Bill Rasin, Vice President and Director, Technical Division, i I B NGh. i 9 Mike Tuckman, Exet'.itive Ad Hoc Advisory Committee 10 Debby Staudinger, Technical Ad Hoc Advisory Committee j Barth Doroshuk, Technical Ad Hoc Advisory Committee 11 ) . Terry Pickens, Technical Ad Hoc Advisory Committee, Northern i 12 13 States Power 14 Bill Russell, NRC Staff i Gary Mizuno, NRC Office of General Counsel 15 16 Don Edwards, Director of Industry Affairs, Yankee Atomic 17 Jim Taylor, B&W Nuclear Technologies Office of IB Scott Newberry, License Renewal Project Director, Nuclear Reactor Regulation j 19 20 Greg Gurican, GPU Nuclear 21 Steve Hale, Florida Power & Light 1 22 l P 23 24 l 25 ANN RILEY & ASSOCIATES, LTD. [ Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

- ~ ~. - 3 PROCEEDINGS 1 [8 :30 a.m.] 2 3 MR. TRAVERS: Good morning and welcome to the NRC-license renewal. sponsored workshop on nuclear power plant 4 My name is Bill Travers and I'm the Deputy Associate 5 i Director for Advanced Reactors and License Renewal. 6 7 Before I turn the meeting over to Dr. Murley, who 8 has some introductory remarks, I'd like to go over some First of all, it's good to see the 9 general announcements. 10 turnout at this meeting. We at NRC are clearly interested 11 and the purpose of this workshop, in largest measure, is to on where we need to go in our license renewal 12 .-receive input 13 activities. I 1 We've done a couple of things with the agenda 14 I ' 15 since it was published in the Federal Register and I just 16 want to highlight them. Ostensibly, they've been done to C facilitate in this meeting as much input as we can on what 17 i future activities we ought to be taking in license renewal. 18 l 19 Number one, we've moved up a number of l u presentations that were going to be given in the afternoon, I 20 f 21 presentations by the Department of Energy and by the nuclear e 22 industry, to this morning. Number two, even not reflected i on this agenda is that we've shortened some of our NRC staff 23 24 presentations, to an extent. 1 There are a couple of administrative announcements 25 i h 1 l IJCJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950 i

4 i i 1 I'd like to make. If you haven't registered at the desk a 2 outside, we wish you would do so. We'd like to have a 3 complete list of all of the attendees. If you are 4 interested and have not yet given us an indication that i you'd like to make some comments or a presentation today, l 5 6 could you do that, as well, at the desk? 7 I should point out a couple of things about l 8 today's meeting. First of all, we are making a transcribed [ 9 version of all the statements that are made today. If you are interested in receiving a copy of the transcript of 10 ~ at the back l 11 today's meeting, you can indicate your interest i 12 . desk. We have people who can tell you how you can get your 3 L i 13 hands on a copy of that relatively quickly. We are also videotaping today's meeting. If you t 14 i ~ 15 have to leave word as to where you can be reached, telephone messages will be posted outside the meeting hall and we have 16 17 a telephone number, which is (301) 652-3000, Extension 7161. f 1 18 Again, if you didn't copy that down, just check at the back i 19 desk, because we will have that available. 20 So at this time, to get things going, I would like to introduce Dr. Murley, who is the Director of the Office 21 22 of Nuclear Reactor Regulation, to provide an introduction. 23 MR. MURLEY: Thank you, Bill. I'd like to add my i 24 welcome to attendees. I hope that we are very productive 25 today. It looks like there will be a lot of important ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 7 c._.

5 I 1 papers. I The purpose of the workshop is for the NRC staff { 2 i to receive comments on how we should proceed with license n 3 4 renewal. We expect to place special emphasis on how we can l take advantage of the existing licensee programs -- for 5 best 6 example, maintenance programs -- for managing the effects of 7 aging of systems, structures and components. The staff will return to the Commission in late 8 i November with a summary of this workshop and a 9 recommendation for moving ahead with license renewal. l j 10 If there's a substantial consensus that a rule 11 change is needed in order to have a clearly defined and 12 stable regulatory basis for license renewal, then I intend 13 to take such a recommendation to the Commission. 14 I 15 To set the stage for the subsequent discussions, I c some histcry of how we arrived at this 16 would like to recount 1 The current 17 workshop today so we can understand the issues. 18 rule became effective on January 13, 1992, but a great deal of the rule 19 of background work had been done in support I 20 since 1988. i 21 In 1992, the staff turned heavily toward t finalizing the implementing guidance documents for this 22 23 rule; for example, the reg guides, standard review plan, 24 that sort of thing. But in the course of discussions with there were issues 25 potential licensees and industry groups, I ) TJW RILEY & ASSOCIATES, LTD. 1 Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950 l

i 6 I 1 of implementation that arose that took on great importance [ 2 to the industry. 3 By the fall of 1992, progress had effectively come 1 4 to an a halt. So last fall, particularly last November, the 5 staff undertook an intensive high-level review of the issues i 6 involved. Our goal was to find a path to make the current 7 rule workable. I think we were successful in meeting that S goal; that is, we found a path to make the rule workable. 9 We cleared up nearly all of the issues; for example, how to { 10 handle fatigue and equipment qualification. 11 We produced two Commission papers on how to make 12 . it workable, and those are in your notebooks that you have 13 handed out. But although the staff did find a workable 14 path, the price to be paid for going down that path was 15 judged to be too high by many of the potential applicants 16 for license renewal. 17 The objections that they had all seemed to center 18 around the definition of the term " age-related degradation 19 unique to license renewal." You will hear that over and 20 over and over today. ARDUTLR. 21 This is a concept that was introduced at the lith 22 hour under the rule, with almost no technical staff input. I 23 should say. The concept of age-related degradation unique 24 to license renewal is one that has the appearance of a nice, 25 clean legal concept, but, in practice, has been technically 1 IJW RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 j i _____._____._____,_.,_,..,_j

7 i ( 1 very difficult to implement. i 2 But the concept, nonetheless, is one of the t foundations of the current rule that we have and it appears 3 all through the statement of considerations. Let me just 4 read a few excerpts from the statement of considerations to I 5 ) this concept i give you an idea of the central roles that 6 7 plays in the rule. e Age-related degradation of plant systems, i 8 structures and components that is unique for the extended f 9 period of operation must be evaluated before a renewed 10 t 11 license is issued. This is a new safety issue'that has not i i 12 ..been treated in a comprehensive fashion in the Comm ss on s I i 13 ongoing oversight of operating reactors. l I age-related degradation will be critical 14

However, l

The to safety during the term of the renewed license. 15 assessment of age-discipline of a formal integrated plant t 16 related degradation unique to license renewal 'is necessary. 17 i 18 That except points out that we had not looked at ) 19 aging before. We didn't do it in the original review and, 4 the definition and management of aging was 20 therefore, t critical to license renewal. 21 r The Commission has determined i Another excerpt. 22 I 23 that it is unnecessary to review an operating plant's ) 24 licensing basis, except for age-related degradation concerns 25 unique to license renewal at the time of license renewal. j i i 1 MUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i l 1

I 8 I Another excerpt is the integrated plant assessment 1 i 2 that demonstrates that the facility's systems, structures / and components important to license renewal have been j 3 4 identified and that age-related degradation unique to the j license renewal will be managed as needed to insure that 5 l the facility's licensing basis will be maintained throughout 6 7 term of the renewed license. l This last excerpt shows that the IPE, the j e was selected as the vehicle for 9 integrated plant assessment, i lo assuring that age-related degradation unique to license l I 11 renewal would be managed. So those are the fundamental i i run all through the thinking behind the rule; f 12 .-concepts that 13 namely, to identify aging and to manage aging. There was a definition that was put into the rule, l 14 15 also at the lith hour, and the definition then of age-l and I related degradation unique to license renewal is, 4 16 17 quote, " degradation whose effects were not explicitly identified and evaluated by the licensee for the period of 1B i extended operation and the evaluation found acceptable by l 19 20 the NRC." 21 Well, with that definition, of course, the NRC has - t evaluated and found acceptable anything for operation 22 not J 23 beyond 40 years. So when you put together the fundamental i concepts of the importance of age-related degradation unique 24 to license renewal and its definition, then, in effect, you 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202).293-3950

( 9 4 e 1 have the rule that covers nearly everything important to 2 license renewal, most everything in the plant. So when we put these quotes together, we have i 3 4 something like a catch-54 that says, in effect, the ] 5 Commission has determined that it is unnecessary at the time of license renewal to review an operating plant's licensing 1 6 l I 7 basis, except for about two-thirds of the plant's systems, 8 structures and components. That's the net effect of the t 9 definitions in the rule. 10 So it comes as no surprise, then, and the staff 11 was not surprised, quite frankly, that potential applicants i 12 ..were concerned that a large amount of documentation on i a ef fective programs would be pulled into NRC's regulatory 13 system of formal documentation and change control. 14 During the intensive review that we undertook, the 15 4 for staff. proposed some interpretations whereby credit 16 structures 17 existing programs would remove certain systems, and components from the definition of age-related 18 degradation unique to license renewal from that category. 19 20 But we must acknowledge that it is not clear how well those staff interpretations would stand up to a legal change. 21 4 So that's the background. Bill Russell and his 22 f 23 staff will describe, again, for those of you who aren't familiar with some of the details perhaps, they will i 1 24 25 describe the current rule and how the staff proposed to t Id3J RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 { (202) 293-3950 l i

i ~1 E 10 i l interpret it and there are also several options that were in 1 I . o 2 the Federal Register notice that involved rule changes that i i I 3 the staff will also describe. We want I But mainly we're here today to listen. 4 With that, then we'll move on. 5 your ideas and comments. 6 Thank you. 7 MR. TRAVERS: Bill Russell told me he doesn't want 8 to do that, Tom. So I'm going to. As Tom indicated, the a purpose of today's workshop is clearly to obtain as much 9 10 information as we can on the best way to proceed with 11 license renewal activities. We expect that the information l i 12 . we get today is going to be useful in the staff e 13 considerations that are going to go into a Commission paper j 14 on recommended approaches, as well as the commission I deliberations and ultimate conclusions on where we need to j 15 16 go in license renewal. Since we've been - the staff has been directed to j 17 i together a set of proposals within 60 days of this i 18 put of I'd like to add a personal plea that we get out 19

workshop, l

this workshop and any written submittals that come 20 21 subsequent to it, I would like to urge that those come in 22 quickly. i 23 We've asked that any written submittals be l 24 provided to us by October 12. Certainly, I look at that as an outside date for pulling together a reasonable set of 25 IJUJ RILEY & ASSOCIATES, LTD. Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 i j (202) 293-3950 ,1

.~ i 11 l 1 proposals that the Commission can consider, including 2 potentially a rule. i So to help set the stage for presentations and 3 1 4 comments on future activities, I'd like to begin, as Tom mentioned, by elaborating a little bit more and providing an 5 overview on the status of license renewal, with a particular 6 focus on the construction of the existing Part 54 rule and a I 7 E summary of some of the recent staff recommendations for how 9 the rule could be implemented. 10 [ Slide.) 11 MR. TRAVERS: These are the key milestones which 12 ..have brought us to today's workshop. Although the focus 13 today is on Part 54 regulations which address plant 14 equipment, I'd like to point out that proposed amendments to R 51 of our regulations which deal with environmental ~ 15 Part requirements for license renewal have been proposed in 16 17 September of 1991. Comments on that proposed rulemaking are 18 being considered. Right now, a final rule is expected in j 19 mid to late 1994. 20 As Tom indicated, since issuance of the Part 54 t 21 rule, the focus of staff efforts have been on the 22 development of detailed implementation guidance. In ~ 23 carrying out this work, a number of concerns about the rule 24 have been identified, some of those concerns raised directly by representatives of the nuclear industry. I 25 t l 1 J ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 i (202) 293-3950 i i

12 i 1 To address these, the staff initiated an intensive 2 senior management review and that effort resulted in a j i number of staff proposals submitted in two Commission 3 4 papers, listed here on this slide, SECYs 93-049 and 113. 5 Those are in your workshop notebook. 6 For the next few minutes, I would like to describe l some of the key elements of the existing rule and highlight 7 t 8 how the staff proposals effect or how we think they would l 9 effect the implementation of the rule. i One of the things I would like to point out early 10 11 on is where we had, in developing our detailed technical 12 . guidance, expected the benefit of a couple of lead plant i 13 efforts, supported by the Department of Energy, those two i lead plant efforts were either cancelled or deferred. 14 15 So to some extent, we have been, in my view, 4 16 inhibited in our discussions with interested parties by the 17 lack of a lot of interaction on detailed technical matters. I f 18 I think it's fair to characterize most of the interactions 1 a we've had to date as focused on the rule and the procedure 19 20 that the rule establishes for carrying out technical l l 21 cvaluations. 22 [ Slide.] l 23 MR. TRAVERS: Part 54 is based on two key 24 principles, the first one being that except for the possible 25 effects of age-related degradation unique to the renewal l i l 70m RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l l i ) c ,, _... - -. - -.,. - - - -..... -.., -. ~ ~.. - - - -

13 the existing regulatory process provides and will 1

period, maintain an acceptable level of safety.

2 The practical result is that for license renewal, 3 4 most issues that are normally considered when a plant is 5 initially licensed would not be revisited for license 6 renewal. For example, rather than review an issue such as the rule credits emergency planning for license renewal, 7 8 ongoing NRC oversight programs and licensee activities as adequate through any renewal term. 9 The second principle states that the effects of 10 the aging in the renewal term must be managed so that 11 i 12 .. current licensing basis, the CLB, is maintained. 3 13 So this construct really set the stage for the way r the rule is constructed and for the very largest part of the 14 i issues that we normally consider, we are relying in this l 15 rule on the regulatory process continued into the renewal i 16 term to continue to deal with those issues, and they would 17 18 not be revisited as the subject of a license renewal 19 decision by the Commission. The CLB is defined in the rule as those NRC 20 i requirements and docketed licensee commitments applicable to 21 t 22 a specific plant and maintaining the safety envelope r i 23 embodied by the CLB by ensuring that the effects of aging in I as I the renewal term are managed is the sole focus, 24 25 mentioned, of license renewal and the review process and, i ANN RILEY & ASSOCIATES, LTD. Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l l 14 j 1 ultimately, the Commission decision and finding. 2 [ Slide.] The rule establishes a number of 3 MR. TRAVERS: requirements which govern a spectrum of activities, 4 including technical environmental information which must be 5 as well as the standards which the 6 submitted by applicants, Commission would use for the issuance of a renewed license. ( 1 7 -l 8 Importantly, the rule fundamentally is a process establish in the rule itself the 9 rule and it doesn't technical acceptance criteria which would need to be met. 10 11 Rather, it establishes this process, and Tom mentioned the as a fundamental aspect of how integrated plant assessment l 12 13 that is done. I'm going to talk about that in a little bit l 14 more detail. i [ Slide.] 15 16 MR. TRAVERS: An important aspect of the rule is specifically provides opportunities for public 17 that it 18 participation. Most importantly, it includes the l cpportunity for a public hearing when requested by a person 19 maybe affected by a plant-specific license 20 whose interest 21 renewal decision. In addition, an application for license renewal 22 i and all of the correspondence between the NRC and an 23 are made available in the NRC public document 24 applicant meetings rooms and consistent with standard NRC practice, 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

15 for license renewal would be held and'open I with an applicant 2 to the public. 3 [ Slide.] ) The rule also includes several key 4 MR. TRAVERS: concepts and defined terms which apply to the prescribed 5 I have already discussed i 6 license renewal review process. 7 the CLB. The integrated plant assessment, or IPA, is really f i 8 the heart of the rule. It's the process which is used r f within the rule and which is intended to accomplish a 9 focused evaluation of aging effects which could be unique to 10 l 11 the renewal period. the 12 I'll be saying a little bit more about 13 integrated plant assessment in a minute, but it can be viewed as a screening process which begins essentially with 14 4 15 the entire plant and provides mechanisms to quickly focus 16 the review. such mechanism is the identification of The first 17 which is important to license-renewal or 18 plant equipment 19 ITLR. Ultimately, the IPA requires a demonstration that equipment which is ITLR and which is also determined 20 plant to age-related degradation which is unique to 21 to be subject license renewal is addressed by effective programs for aging 22 23 management. 24 [ Slide.) 25 MR. TRAVERS: The rule defines important to ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 ~

l 16 license renewal equipment to include items that I've listed 1 2 here. First of-all, safety-related equipment is clearly secondly, non-safety-related equipment 3 within the scope; l whose failure could directly prevent the function of safety-4 t 5 related equipment. t f structures and components Thirdly, systems, 6 7 required to meet specific NRC regulations, including Whitman B qualification, pressurized thermal shock, anticipated l 9 transients without scram, fire protection, and station r 10 blackout are also included. Lastly, systems, structures and l ~ components which are subject to operability requirements and 11 dd the tech spec limiting conditions for operation are inclu e 12 1 within the initial scope of the rule. 13 concerns that There is currently no significant 14 I 15 I've heard recently about the scope of this rule. I should a number of the topics today will discuss the i 16 point out that applicability of maintenance rule and how we examine the l 17 should be examined for license renewal. 18 issues that i The scope of the maintenance rule is very similar, t 19 quite identical to the license renewal scope that's 20 but not l i 21 listed here. [ Slide.] 22 4 As Tom mentioned, one of the most 23 MR. TRAVERS: contentious issues - actually, the most contentious issue 24 with the current rule is the definition of the age-related 25 t ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950

l 1 17 1. degradation unique to license renewal. l 2 This is it. I'm not going to read it. But since r equipment which is not subject to ARDUTLR or which would not 3 4 be found to be subject to ARDUTLR requires no further 5 treatment within the IPA, the applicability and scope of 6 this definition is viewed as significant. t 7 As an example, the existing rule does not require B effective program demonstrations to be provided in the a 9 application for equipment which is not subject to ARDUTLR. 4 10 So as written, a large amount of plant equipment 11 could be subject to ARDUTLR. One of the things we've done t provided in the 'in addressing a number of proposals that mtc 12 13 SECY papers I have listed was to take on this issue directly 14 and to see how and if the interpretation of how the rule 15 would be implemented could be effected. 16 Basically, the staff recommended that equipment j t 17 which is replaced so as not to experience a service life greater than 40 years should not be considered subject to l 18 r 19 ARDUTLR. So that's the status of a proposal we've made as l 20 to how you might more efficiently implement the rule, and l 21 I'm going to be talking about some of those other proposals I, i 22 in a moment. / a Although this position results in a reduced scope 23 24 of equipment subject to ARDUTLR, there are concerns that it l 25 doesn't go far enough; specifically, far enough to e ANN RILEY & ASSOCIATES, LTD. 3 Court "eporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l

i t 18 -1 accomplish the Commission's intent of focusing on aging issues which are truly unique to the extended period of 2 i 3 operation. 4 Much of this workshop, I'm sure, is going to be i devoted to a discussion of the concept of age-related 5 degradation unique to license renewal and whether or not a 6 t new definition that more effectively implements the 7 I 8 Commission's intent in promulgating the rule can be devised. i t' 9 So we look forward to that. I 10 [ Slide.) 11 MR. TRAVERS: I mentioned and discussed briefly 12 - 'the required integrated plant assessment. This is a schematic view of how you might visualize the requirements 13 I 14 in the rule for carrying out such an integrated plant 15 assessment. It begins, as I mentioned, with a consideration r i of the entire plant to identify in the scope review those 16 t 17 SSCs which are important to license renewal. j 3 18 Roughly, we've estimated that about 30 percent of l 19 plant equipment would be identified as not important to i 20 license renewal and, as a result, would not receive any l 1 l 21 further treatment in carrying out the IPA. 22 In the functional review step, structures and i components - now we're out of systems and we've actually 23 level review -- which I 24 gotten into a structure and component 25 are part of an ITLR system or structure, but which are not I ANN RILEY & ASSOCIATES, LTD. Court Reporters ] 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 I (202) 293-3950 i

_- ~~ -._.._- 19 .t required to perform the function of the system or structure, i Only would be eliminated at the functional review step. 2 of plant equipment has been estimated to. 3 about five percent t 4 be dispositioned here. t structures and At the uniqueness review step, 5 to be subject to ARDUTLR l components which are determined not 6 would be dispositioned. As we've been mentioning, this is l 7 clearly one of the focuses of today's workshop on how we 8 need to carry on future activities. 9 Some alternative approaches for defining ARDUTLR 10 We've provided those will be discussed by Scott Newberry. 11 ..to scope out some possible alternatives in the Federal 12 Scott is going to be Register notice for this meeting. I 13 1 14 talking about the effect of the percentage of plant 4 15 equipment that might be dispositioned as a result of changing the definition of the ARDUTLR. 26 l In our staff proposals, we have estimated that 17 everything in the l going from the initial view that most 1 18 l 19 plant would be subject to ARDUTLR, that our proposals to the or so of Commission would result in as much as 15 percent 20 structures and components in the plant being dispositioned 21 t to age-related degradation unique to license 22 as not subject I 23 renewal. I should mention that in the last step, for 24 25 everything that has been identified as subject to age-i 1 r MG RILEY & ASSOCIATES, LTD. Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 I

^- P i t 20 i related degradation unique to license renewal, either an 1 effective program would be required, and we've estimated on l 2 the order of 30 percent of the total plant equipment would 3 require in the application a demonstration and description 4 5 of an effective program, but that 20 percent of the l 4 which is subject to ARDUTLR and which is important 6 equipment 7 to license renewal would not need to meet the specific requirements for a description of an effective program 6 i 9 review in the rule. We base that on a couple of things. One way you 10 + could demonstrate this lack of the need for an effective 11 a . program would be demonstrating that no action to manage 12 13 aging would be needed. The second way would be to 1 14 demonstrate that the equipment is not of fundamental safety and that's a new concept. lo importance, i the l We provided a proposal for how and what 16 i 17 criteria might be for identifying equipment that would not would be of fundamental safety importance and, as a result, le i l the specific requirements for an effective 19 not need to meet 20 program in the rule. [ Slide.] 21 slide is a summary and it 22 MR. TRAVERS: The next of i 23 presents the effect of what we view the complete set staff proposals for how the existing rule could be 24 The implantation focus of the rule is the 1 25 implemented. 4 1 i ANN RILEY & ASSOCIATES, LTD. Courc Reporters 1612 K Street, IL W., Suite 300 Washington, D.C. 20006 (202) 293-3950

.. ~ -. . _ - = - - =. 21 identification and management of aging effects on equipment 1 1 for detailed aging function rather than a requirement 2 3 mechanism evaluations. act to mitigate This recognizes that programs that 4 function or condition are the effects of aging on equipment 5 6 adequate and do not and should not require a detailed f So this is a bit evaluation of individual aging mechanisms. 7 8 of a shift from some of the language that exists in the l of consideration and it recognizes that for much i 9 statement o of the experience we've had in the nuclear industry, I 10 evaluate function or condition in the absence i 11 programs that f 12 - 'of a detailed evaluation of particular aging stressors can l be effective in managing the overall effects on a system or [ 13 I 14 component's function. f The staff also clarified that aging management i 15 programs which are required to be described in the 16 I application do not need to include detailed acceptance 17 criteria normally contained in plant implementing 18 i l 19 procedures. The staff expects that this kind of information i 1 20 would be reviewed in on-site audits during the renewal 21 i we specifically included a number 22 review. In SECY 93-113, 23 of examples, I think there are nine, which were taken in 24 which plant equipment, specific plant equipment was taken l through each step of an integrated plant assessment. 25 ) i ANN RILEY & ASSOCIATES, LTD. Court Reporters l h 1612 K Street, N.W., Suite 300 I Washington, D.C. 20006 l 4 (202) 293-3950 l l

J 22 of Perhaps even more interestingly, the amount 1 information that the staff expects would be needed in 2 to the application is also included in that attachment ) 3 i 4 Commission paper. l 5 The s aff's recent proposals also provide, we some additional flexibility for identifying SCs i 6

believe, 7

which are not subject to age-related degradation unique to 8 license renewal. As a result, as I have already mentioned, i more structures and components than previously expected j 9 \\ 10 could be dispositioned without a detailed evaluation of the ~ l l l 11 programs. I Number five on this list indicates our expectation l 12 13 that relatively few technical specifications, new technical specifications or new license conditions would result from 14 15 our license renewal review. There had been some concern i expressed early on that the way we were discussing 16 in a host of new implementing the rule would likely result 17 license conditions or technical specifications to manage j 18 19 aging. The SECY papers that are contained in your 20 21 workbook indicate that that is not the staff's intent. 22 In conclusion, six reiterates that the staff's approach includes an allowance for the use of safety 23 24 importance, as I've discussed just recently in the conduct 25 of the integrated plant assessment, for determining whether 7dCJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

23 structures and components need to be subject to 1 or not specific effective program requirements of the rule. 2 3 [ Slide.) 3 1 4 MR. TRAVERS: So that, in summary, is a little bit I 5 more detailed perspective on what the rule requires and 1 6 where we believe our most recent proposals to the Commission ( i 7 might influence how the rule, the existing rule, could be P B implemented. l Now we're going to move on in this workshop to 9 10 discuss some of the concerns. And I'm not going to 11 stipulate what I've got on the slideShere because I think a l 12 . number of the presentations upcoming will do that. f But more importantly, we're clearly in the receive 13 I 14 mode for constructive suggestions, including possible j i 15 rulemaking. We look forward to a thorough discussion and i r i 16 hopefully a lot of questions on the presentations to follow. i Unless there are some questions for Dr. Murley or 17 18 myself, and we'll be glad to take those at this point, I I i 19 would propose that we move into the presentation by the ) 20 Department of Energy on some of their thoughts as to where J 21 we need to proceed in the license renewal arena. 22 MR. FRANKS: Thank you, Bill, for the opportunity 23 and, Dr. Murley, for your introductory remarks with regard i 24 to some of the uncertainties about this language contained i 25 within the rule. I I MUJ RILEY & ASSOCIATES, LTD. l Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

-~ ~ I i l 24 l 1 I'd like to especially point out Dennis Harris, j 2 who has been a focal point for me in trying to put our 1 3 vision down of what we think we need to do with the rule. 1 4 He's been very active in taking our vision and implementing 5 that in some language that we should be in a position to i ] I 6 provide as a form of comments to this workshop. Basically, 7 that's the way I want to go through this and lead the tone j i 7 8 of that at the end of the discussion that we have, we hope, i 9 provided the simplification for the language and we offer 10 that to the Commission and to the staff for their i l l 11 considerations.

i 12

[ Slide.) I j 13 MR. FRANKS: The Department of Energy -- I want to ~ t 14 provide a little bit of background on that as far as our l r l 15 involvement and some of the activities we-'ve undertaken with s recard to this rule. Then I will nrovide you an overall d 16 17 assessment of the proposed draft addendum or amendment that i 4 1 18 we've developed in concert with some selective individuals ] I 19 that helped us pull this together. Then, in conclusion, I ) 20 will provide you a summary of the program. l t ) l ~ 21 [ Slide.] j 1 i 22 MR. FRANKS: For some of those that may not know t i j 23 the extent of the Department of Energy's involvement, I will l 24 refresh your minds. We were involved in cosponsoring or i 4 't i 25 providing some cost-shared funding with various programs s i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

25 t i to include providing i that have been going on since 1985, 1 2 funding and support, technical support to lead plants that 3 were mentioned earlier, Northern States and Yankee. We've been involved in providing our input to the 4 NUMARC working groups with regard to license renewal through 5 We've cosponsored several industry reports that 6 to date. specific that went straight to the point of trying to I 7 were would need to be evaluated beyond 8 address components that the 40-year period and we've developed some of those reports i. 9 i with EPRI and NUMARC. 10 in collaboratic.n We've provided comments on occasions to the staff a 11 comments on ..in the form of advanced notices of rulemaking, t 12 and comments with regard to the format and j 13 the final rule, i we've had a fairly extensive i 14 centent. So as you can see, J 8 15 background in this program. ~ [ Slide.] 16 17 MR. FRANKS: Some of our current activities 1 s interacting with NUMARC and trying to provide some 1 18 include b insights from the Department's standpoint on the O 19 implementation of the rule and to assure that the knowledge 1 l 20 we've developed over the last ten years was l 21 base that maintained and provided to the industry for their benefit. 22 We took an initiative back, I guess, in March of 4 23 i 24 this year as a result of a lot of documentation and i was going on between the staff to the 25 correspondence that MUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 I Washington, D.C. 20006 j (202) 293-3950 l 9

i 26 There was to the industry, to the Commissioners. 1 utilities, 2 a lot of dialogue going on. f We took an approach that said let's get it -- it j 1 3 l because of the complexity and the mixed appeared to us that 4 that everybody signals within the definitions of this issue, 5 was pretty much fairly close in agreement other than how to t 6 f 7 implement the rule. What we did was try to take some of the f e Bill Russell had provided as implementation knowledge that 9 to the Commissioners and take that l 10 far as insight l ~ information and take the utility information and coalesce a i 11 we could then use as a baseline to work from. t document that 12 i [ Slide.) 13 One of the things in our vision that MR. FRANKS: 14 we wanted to make sure of was to maintain the integrity of 1 l f 15 and we of the rule is a valid concept 16 the rule. The concept Another part 4 wanted to make sure that we maintained that. 17 was to make sure that we tried to clarify and simplify the 1 18 19 process. As a result of that, we assessed a lot of a 20 information and concluded that there were several issues 4 21 we may be cross-talking or miscommunicating with regard 22 that One was obviously the definition and because of its 23 to. Then the term of effects versus mechanisms, 24 complexity. whether you had to do deterministic evaluations of the 25 4 IJE RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 -- i

27 l effects of degradation or you could simply take care of it 1 from a mechanistic standpoint and simply replace it or a 2 3 refurbish it or whatever. Then the other one was to assure that we 4 maintained the integrity of the regulatory commitments 5 within the existing licensing base and then the other issue 6 was to simplify the level of detail that would be required P 7 in the submittal of the application. B ISlide.] 9 As I mentioned briefly, we wanted to 10 MR. FRANKS. 4 --withthoseguidingprinciplesandthoseissues,wewanted 11 to provide our vision of maintaining or incorporating into i 12 i for the existing the rule the opportunity to take credit i 13 t licensing base and to take credit for existing rules and ? i 14 i 15 regulations, specifically the maintenance rule, l The other information that we considered in 16 r deliberations of how to resolve some of these issues was t 17 l various SECYs and Commission papers, the memo from Mr. 18 the staff requirements memo back from 19 Sniezek to Dr. Murley, and some the Commissioners on considerations for the rule, l 20 EPRI had underway with life cycle 21 of the efforts that and NUMARC and its efforts in trying to address l 22 management, the conf usions or misinterpretations, as people may see i 23 i with regard to the language and terminology of the I 24

them, 25 rule.

7JE RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 3

28 1 [ Slide.] 2 MR. FRANKS-We wanted to -- the concern we had at time when we took this approach was we were concerned 3 that d that we had gotten to a fever pitch on how to resolve the 4 Whether the rule was required to be modified or not 5 rule. 6 was a question and we felt rather strongly that due to the 7 language in the rule, that some clarifications in the rule 6 were in order. As a result of that, we undertook the opportunity 9 to rewrite or draft up proposed language that would simplify 10 11 and provide credit for the maintenance rule, effect of the and still maintain the integrity 12 use of effective programs, 13 of the rule. 14 [ Slide.) 15 MR. FRANKS: As I mentioned, on a couple of occasions, we have drafted an amendment that we think has 16 17 formed at least a catalyst to talk from with the industry. We've had numerous dialogues with NUMARC and EPRI and the 18 As we worked through that language, 19 various owners groups. 20 we started to find that there was a close correlation 21 between our independent interpretation and the utility's 22 and, from what I heard from Mr. Travers, a comparable correlation between the staff and the Commissioners and 23 their insights into where the rule should be. 24 25 We have, as I mentioned, received input from the ANN R: LEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

_x.. .x w.. ..~. x. -- - - - =w t i 29 utilities through NUMARC and we will provide our. proposed l 1 1 language as a result of this workshop in the form of formal 2 3 comments. 4 [ Slide.) 5 MR. FRANKS: In summary, I think, and I don't i i 1 6 believe there was ever any doubt by the staff or the i as i Commissioners or the utilities that we weren't going to, f 7 we embarked on the license renewal extended life process, 8 9 that we weren't going to rely on the existing plant 10 licensing basis. It's clear we're going to have to do that. l 11 That forms the basis of the safety case we've made to the f ~ 'publiv, 12 We feel strong to maintain that safety base, we've s 13 i 14 got to maintain the licensing base. So the fundamental i principle was to simply try to clarify the language within 15 1 the rule and to provide a mechanism to simplify the l 16 i submittal ?.pplication for the rule so that we could get on ) j 17 18 and art .aluating the actual components hat may have an i . the post-40 year life of the plant. ) i 19 effe 20 with that, I'd like to conclude my remarks. Thank ) 21 you for the opportunity. Questions? J l 22 MR. TRAVERS: We're a bit ahead of schedule, but the next presentation by the nuclear industry is scheduled 23 24 to last for a couple of hours. So I suggest we take a break for ten minutes or so and then follow up with the industry 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l 1 l 30 i 1 1 presentation. 2 [ Recess.) i 3 MR. TRAVERS: The next presentation is an important one and it's being sponsored by NUMARC for the 4 5 nuclear industry and Bill Rasin, who is Vice President and j 6 Director of the Technical Division for NUMARC, is going to 7 lead off. He's just asked me to make sure that he gets lots 8 of questions for all of his speakers. So feel free. 9 MR. RASIN: Thank you, Bill.. It's a pleasure to be with you this morning and to have this opportunity to 10 ~ bring the appropriate industry representatives together to 11 12 . provide the views of the industry on this important topic. 13 Tom Murley pointed out that the staff has been e 14 working hard on this issue and, indeed, from the industry's 15 viewpoint, they really have. So has the industry been r i 16 working very hard on this issue. I think that is indicative C of the realization on everyone's part of just what an 17 i 18 important topic this is. The industry, to address the implementation of 19 20 License Renewal Rule Part 54, assembled two groups. These ] groups include representatives from those in the industry 21 r involved in real programs pursuing license renewal with the 22 l of proceeding to actual applications for license l 23 intent 1 24 renewal. 25 They are, indeed, the people with the immediate i ANN RILEY & ASSOCIATES, LTD. Court Reporters i 4 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 31 the ones willing to kind of put the 1 stake in the issue, money where their mouth is and, felt by the industry, the t 9 2 right groups to put together to find the right path through 3 ^ 4 this difficult issue for the industry. The two groups we formed was a Technical Ad Hoc I 5 e Bill Travers noted that many of our 6 Advisory Committee. i have been process-oriented and 7 discussions to date, in fact, it philosophical and that's true and we felt t e somewhat l some people together and really take a hard l 9 necessary to get t ? look at the technical implication. 10 This Technical Ad Hoc Advisory Committee includes 11 12 - ' representatives from Northern States Power, Baltimore Gas & the Westinghouse Owner's l 13 Electric, the B&W Owner's Group, f and also has representation l 14 Group, the BWR Owner's Group, i from the Electric Power Research Institute and the 15 16 Department of Energy. t' In addition, we put together an Executive Ad Hoc 17 Advisory Committee of senior executive leadership from each 18 of these utilities and utility organizations to provide 19 overall guidance and policy and to consider the general J i 20 principles upon which industry needed to proceed with this t l 21 E i 22 effort. 1 The individuals here today are representing those 23 two groups and will be providing the industry's viewpoints i 24 25 on this important subject. We will have Mike Tuckman, .l .s IJW RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 4 (202) 293-3950 i

32 followed representing the Executive Ad Hoc Advisory Group, 1_ by some more technical work presentations by members of the 2 Technical Ad Hoc Advisory Committee, by Debbie Staudinger, 3 4 Barth Doroshuk, and Terry Pickens. We would like to ask that we go through our 5 We think they coherently follow one another 6 presentations. Then we will be happy to answer and build upon one another. 7 your questions as a panel afterwards. B l let me turn it over to Mike. t With that, 9 10 MR. TUCKMAN: Thank you very much, Bill. I really [ l ~ to express my appreciation at the opportunity to 11 want l provide the industry perspective on this m . important I 12 13 issue. j our nuclear power plants present a As you know, f 14 i for the United States very, very sound resource and asset 15 and this issue is absolutely critical to the success of this f 16 17 industry. l Our industry has been working on license renewal l 18 19 for quite some time. Many of us would say since the very features have been designed into 20 inception of our plants, j the plants to allow them to continue to operate for almost 21 an indefinite period of time. 22 Our goal, obviously, is to have a stable and j 23 l predictable regulatory process in place so that as our t 24 facilities approach the end of the licensed life of 40 25 i ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

{ i 33-l those of us responsible for these businesses can make l 1

years, a sound business decision relative to their continued

{ 2 J' 3 operation. Our plants are operating safely today and we know i of no technical reason whatsoever that they cannot continue l 4 5 to do so in the future for periods of extended operation. l 6 Our confidence that nuclear power plants can be I 7 operated for an additional 20 years or more is founded on 8 the results of several detailed technical studies on life 9 l extension and the industry's operating experience to date. 10 l Life extension studies have been cosponsored by 11 as Sterling Indicated, and the l i 12 the Department of Energy, Those studies concluded l Electric Power Research Institute. I 13 that extending the service life of a nuclear power plant was t 14 technically feasible and was perhaps a cost beneficial way 15 of providing electrical power service even moreso than 16 building new plants or new fossil plants. i 17 as Sterling mentioned, two pilot programs In 1985, 18 were initiated to examine in-depth the technical limitations 19 and to define l of nuclear power plant equipment, structures, i 20 the useful l the degradation parameters and attempt to project 21 life of individual plant structures and components. l 22 l These pilot programs again confirmed that nuclear l 23 In power plants could operate safely well beyond 40 years. I 24 l the Electric Power Research Institute and Department 25

1988, i

l ANN RILEY & ASSOCIATES, LTD. 1 Court Reporters 1612 K Street, N -. W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i i t

i 1 34 I of Energy again initiated a lead plant demonstration 1 the Yankee Rowe plant and Northern 2 program. Two plants, i States Power's Monticello plant, were participants to serve 3 [ as pathfinders for those of us to follow in weighing the 4 license renewal option. I 5 I Today, Baltimore Gas & Electric is actively 6 t Calvert engaged in a life cycle management program at 7 the 8 Cliffs. The Babcock & Wilcox Owner's Group, i l Westinghouse Owner's Group and the BWR Owner's Group all 9 r All of these-have generic license programs in place. l 10 insights into the projects have generated important l 11 54, 12 - implementation of Part Pilot Today, we also have the maintenance rule. 13 i 14 studies and lead plant programs were well underway before ) the maintenance rule came into being. The regulatory 15 for license t 2 16 oversight that this rule provides is important i 17 renewal. i we've learned a As we think about what's gone on, 18 i i The first is three principal lessons from these activities. 19 the two principles of license renewal are sound; 20 that the the regulatory oversight process ensures that 21

namely, licensing basis licensing basis -- and the current 4

22 current can be maintained during the renewal term. 23 i The second, the language of the rule is unduly 24 meaning that the f burdensome and impractical to implement, 25 i i I i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 a (202) 293-395;f e a yn,- -e g g

35 process requires many more industry and NRC resources than 1 j 2 are necessary to meet the basic principles of the rule. i 3 In particular, the current definition of age-related degradation unique to license renewal is unclear and 4 5 subject to interpretations that our own experience 6 demonstrates is inconsistent. link this very similar to the definition of 7 I E chronography. All of us understand, in our mind, what 9 chronography is. We have a devil of a time defending it in 10 the court system. It's just a very complicated thing to 11 deal with. 12 The third lesson learned is that assuring the 13 functional performance of our equipment provides reasonable 14 assurance of effective management of any deterioration due 15 to aging. We found that implementing Part 54, with the 16 strict interpretation of the definition of age-related one can continue to degradation unique to license renewal, 27 le say that term coherently, as it's presently written, 19 unnecessarily will result in almost every plant structure 20 und component being subjected to a rigoroun technical 21 evaluation of aging mechanisms. Going to this level of detail is not necessary. 22 Eased en the extensive efforts by Northern States Power, 23 the B&W Owner's Group and Baltimore Gas & 24 Yankee Ecwe, 25 Electric, in working through the existing rule, we've IJN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l i 36 i 1 learned that imposing this type of evaluation currently required by 54 on plant structures and thousands of j 2 3 components is inefficient and unwarranted, because we have 4 not found an added safety benefit. Regardless of how the review was structured, each 5 f 6 one ended up concluding that existing programs are adequately managing equipment performance and, further, that 7 assuring functional performance ensures effective aging 8 9 management. We credit the staff's same conclusion in the 10 4 5 11 latter point in SECY 93-113. The existence of the maintenance rule now creates the regulatory basis for the 12 t 13 acceptance of this conclusion. .i 14 Through NUMARC, we brought the industry together, 15 the license renewal activities. Taking into account the 4 lessons learned in the promulgation of the maintenance rule, j 16 1 we focused on the development of the industry license 17 18 renewal process that does not compromise plant safety and retains these two fundamental renewal principles and is l

9 technically sound and reasonably predictable.

J You will hear more about that from our panel 21 1 22 members in this process. 23 The industry agrees on the process. Our lawyers I 24 have reviewed it to determine if we comported with the 25 existing rule. It's their opinion that we do not fully j

l ANN RILEY & ASSOCIATES, LTD.

Court Reporters 4 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

~ 37 i some minor l comport with the rule in our process and that i 2 changes to Part 54 will be necessary. i The industry approach for license renewal casts a 'i 3 it provides a more efficient and l but broad evaluation net, 4 l effective process to the disposition of structures and f 5 the same time, we believe that the approach t 6 components. At t l provides an acceptable regulatory basis and a technically i f 7 rigorous process to identify the smaller subset of equipment 8 l and structures that really do deserve a more rigid aging 9 10 review process. j structures and Our approach scopes systems, i 11 i h the .~ components important to license renewal consistent w t l 12 quickly focuses on the scope of those 13 current rule, but l This is accomplished by revising the i 14 long-lived items. l definition of age-related degradation unique to license l 15 renewal to give maximum credit to the maintenance rule, to 16 17 replacement and refurbishment activities, and other existing t 18 programs. This is consistent with the two licensing renewal 19 existing 20 principles in that the approach recognizes that i i i programs will carry forward into the renewal term and the regulatory oversight process will ensure the adequacy of f 21 22 f j 23 these programs. The industry supports minor adjustments to the i 24 We acknowledge existing programs and focus the rule I 25 rule. f k i LTD. ANN RILEY & ASSOCIATES, Court Reporters l 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950 i [ I

38 on those long-lived items which may need that examination for the renewal term and clarify the level of detail f 1 2 necessary in the renewal application and the FSAR j 3 + l 4 supplement. Timely promulgation of these changes will go a 5 l long way to creating a stable, predictable renewal process. 6 into the license Bill, we would like very much to get 7 We need to have the rule renewal application process. 8 be able to do l changed in this minor way such that we might r 9 i 10 that. ~ l ~ In summary, while the fundamental principles of 11 l as we have all said, are sound, 12 - 'the license renewal rule, I l the regulatory language is cumbersome and impractical to 13 I especially this definition of age-related i 14 implement, I degradation unique to license renewal. i [ 15 This conclusion is based on a lot of work that i 16 l we've done and our experience to date and the resulting 17 18 lessons learned. What we'll do now is I'll introduce Debby 19 Debby will share some of the lessons that we ~ 20 Staudinger. if you have learned in going through the practicalities, 21 f Debby? of trying to implement the rule. 22

will, MS STAUDINGER:

Thank you, Mike. Good morning. l f 23 I'd like to spend a few moments going over with you the i 24 collective experience from the industry. 25 i' 1 ANN RILEY & ASSOCIATES, LTD. 7 Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

39 i [ Slide.) 1 There's been a considerable MS. STAUDINGER: 2 of work completed by the industry, which has tested 3 amount l the basic concept of the existing license renewal rul. I 4 { Monticello has completed a full application, althougn act 5 i 6 yet submitted. Calvert Cliffs and the B&W Owner's Group have t 7 provided numerous topical reports and we have all had, as an 8 In interaction with the NRC staff. 9 industry, significant our implementation process has differed 10 some cases, ~ l the lessons that we learned were all very I 11 slightly, but ) 'similar. 12 i [ Slide.) 13 l We did learn and establish that, MS. STAUDINGER: 14 the license renewal principles are sound. 15 as Mike said, Specifically, that with the exception of age-related i } 16 the regulatory degradation unique to license renewal, i 17 oversight process assures the adequacy of the CLB and that 18 the CLB will be carried forward and maintained throughout 19 i 20 the renewal term. The definition of age-related degradation, 21 The concept is sound f however, requires some modification. 22 and should be used to focus evaluations on the appropriate f 23 Aging can be effectively managed by 24 plant equipment. l ensuring ITLR function and existing activities were found to 25 ANN RILEY & ASSOCIATES, LTD. I Court Reporters i 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950

i 40 i adequately. manage aging. 1 it's reasonable to keep these evaluations

Finally, 2

a fairly high level-f 3 at L [ Slide.) 4 to the concept of ARDUTLR. MS. STAUDINGER:

Now, 6

The concept is, again, sound. However, the definition l 5 i because it's difficult to apply and requires some revision, 7 Literal application results in yields inconsistent results. 8 l all SSCs which have been identified as important to 9 almost I thus providing license renewal be deemed as having ARDUTLR, 10 virtually no focus on truly unique aging. 11 i As far as aging management, age-related t 12 degradation manifests itself in decreased performance l 13 14 characteristics. Therefore, by monitoring performance f it's an effective way to identify 15 against goals or criteria, l and mitigate the effects of aging. 16 Performance tests, inspections, condition 17 Can monitoring programs have elements which -- I'm sorry. 18 Great. 19 you hear me now? Second bullet, performance test and inspection, 20 condition monitoring programs have elements which cause 21 action when the SSC is not performing with its acceptable 22 there's a history of performance on the 23 limits.

Finally, of the industry and the NRC to solve new technical 24 part issues as they arise.

25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l 41 This demonstrates the adequacy of the diversity l 1

notices, process through such vehicles as generic letters, 2

bulletins and certainly inspections. 3 Nearly all active and certainly many passive 4 components are currently subject to significant maintenance 5 activities which may or may not be specifically identified 6 7 within the CLB. These activities, either independently or will continue to reasonably assure the ITLR B

together, 9

function of the equipment. rule Much of the implementation of the current 10 process became an exercise in paperwork for us and yielded 11 12 . little or no additional benefit. There was benefit in 13 identifying those important functions and programs whose the functions activities provide reasonable assurance that 14 will be available when called upon. 15 Our activities demonstrated that reasonable l 16 assurance of function can be provided by evaluations at a 17 system level or by evaluating groups of components that 18 19 perform similar functions. We feel that this collection of industry lessons 20 learned was extremely useful in creating a proposed industry 21 22 approach for license renewal. I'd like to turn the presentation over to Barth 23 24 Doroshuk, who will describe that process. 25 MR. DOROSHUK: Good morning. I can say age-MUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

b 42 related degradation unique to license renewal and I'll say 1 e 2 it that way, so you know I know how to say it. It's a i We t complex definition and it's equally hard to say. i 3 like really probably could have come up with an easier term, t 4 5 important aging. 6 Good morning. On behalf of the nuclear industry, t to express my appreciation and the appreciation of 7 I want the Ad Hoc Advisory Committee for the opportunity to present i 8 4 and discuss the results of many years of dedicated work by 9 the industry and, more recently, over the last several i t 10 the untiring work in the development of an approach 11

months, to assess nuclear power plants for license renewal.

12 We believe that this approach, the industry 13 i 14 approach, is technically sound, thorough, and assures continued safe operation of nuclear plants during the l 15 16 renewal period. The industry approach that I will present j 4 fully exercises the two fundamental principles of the f 17 18 current rule, 10 CFR Part 54. and intent of The approach relies on the concept 19 The age-related degradation unique to license renewal. d 20 f I 21 concept and the intent. As stated earlier, the industry has f rule definition is not workable or 22 found that the current i 23 acceptable. The approach recognizes licensees' existing 24 25 maintenance strategies, activities and/or practices and i i i, ANN.RILEY & ASSOCIATES, LTD. l Court Reporters t 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 . - -,. ~. ,-,n,

43 degraded performance due to their capability to detect 1 1 l The industry approach also provides the NRC with 2 aging. reasonable assurance that the activities credited to either 3 could occur, or assure no unique aging would be occurring, f 4 any aging attributed to be unique is adequately managed 5 that and continued into the renewal term. 6 But I want to stress that this is reasonable 7 The approach these activities will continue. assurance that 8 and content of the license proposes a more effective format e Although the same l 9 renewal application and FSAR supplement. t l 10 information would be presented for IkRC review and approval, 11 lessons learned through all of 12 . it would take into account i have been discussed today. the activities that 13 [ Slide.) 14 My presentation and supporting MR. DOROSHUK: 15 I will give you our conclusions i discussion is shown here. i 16 I will then briefly review the primary concerns that H 17 first. he the industry has been attempting to address in t 18 of their approach. l 19 development I will discuss the Based on these concerns, r 20 h guiding principles given to the Ad Hoc Advisory Group by t e 21 d out executives to assure that we had established and stake i 22' I will then discuss the territory we were going to cover. 23 assessment and in some detail the industry integrated plant I i 24 54. the necessary adjustments to Part 1 25 l ] j LTD. ANN RILEY & ASSOCIATES, f s Court Reporters [ 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950

. - ~ - t I + 1 44 [ Slide.] 1 The industry has concluded, through MR. DORDSHUK: 2 l 54 are necessary. 3 its work, that adjustments to 10 CFR Part are necessary to truly in our opinion, f 4 These changes, f execute the intent behind the two fundamental principles o f 5 and the intent of age-related the rule and the concept f 6 degradation unique to license renewal. i 7 These principles, as stated earlier, are that the j 8 with the exception of age-related i 9 regulatory oversight, i degradation unique to license renewal, will adequately I 10 l assure the CLB is carried forward and the second princip e 11 4 the licensees will carry forward the CLB. 'i 12 . is that In addition to the conclusions surrounding the ? 13 oversight and maintenance of the current licensing basis i 14 l the industry has found that the structure of 15 during renewal, f As stated by the the license renewal rule is a good one. i 16 l i.e., to was to cast a broad net; 17 commission, the intent and then effectively focus our 18 scope the right equipment structures and components that i resources on those systems, t 19 need to be assessed for the renewal term. 20 the industry does not take issue with t Therefore, 21 Secondly, this is important 22 the scope laid out in Part 54. i if everything is because if everything is important, l 23 then and everything is unique, 24 important in the plant to say that the broad net catch 25 nothing is. That is not l LTD. j JJUJ RILEY & ASSOCIATES, Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i i

[ 45 it is through the process that would not be assessed.

Yet, i

1 the industry has proposed of determining what truly requires 2 l assessment that the plant performance and safety will be 3 s 4 assured. i in the f Assuring continued safety is paramount 5 1 6 industry's approach. This assurance, however, is a f combination of giving credit to existing maintenance 7 8 strategies, activities or practices, such as the maintenance 3 9 rule, replacement and refurbishment, or other maintenance t 10 practices. f Factoring in the principles of the rule and our 11 i ' perceived intent of the definition of what unique aging is, 12 the industry has concluded that the existing rule requires l l 13 l changes to the definition of age-related degradation unique l 2 14 15 to license renewal. l After several years of work regarding what i 16 to the NRC, the information would be needed to submit i 17 the in the form of a license renewal application, t 18

industry, 19 industry has found that the current rule requires every i

20 list, every interim step, every result, every procedure to This, in our view, is be included in the FSAR supplement. 21 an unintended feature of the rule and should be changed. 22 In addition, the industry recognizes that in order 23 to assure that no 24 to allow credit for existing programs, certain unique aging could occur or will be managed, 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K' Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 _ _ ~

m l i 1 46 f t commitments may be necessary in the FSAR supplement that 1 I l will carry forward these activities during the period of 2 ? extended operation. I 3 Now let me discuss how r These are our conclusions. 4 5 we got here. ) Islide.) f 6 the Since December of 1992, MR. DOROSHUK: 7 the industry has Commission briefings by the NRC staff, 8 attempted to develop its approach by addressing several key 9 These areas are shown here. t 10 areas of concern. i structures and components important The systems, 11 d.it to license renewal; was the scoping appropriate; shoul 12 The definition of i be harmonized with the maintenance rule. l 13 age-related degradation unique to license renewal, how was 14 supposed to be implemented? and the concept i 15 the intent J An effect of the problems with the definition of 16 he age-related degradation unique to license renewal is t 17 for existing maintenance inability to take credit 18 such as the maintenance rule, without a detailed 19 strategies, mechanistic evaluation for a 60-year period. 20 Over the last nine months, we have seen various 21 take credit for these proposals on how a licensee might 22 assurance does NRC have that existing activities; i.e., what 23 dited in the licensee would continue these activities cre 24 would structure or component, 25 saying that an SSC, a system, LTD. s ANN RILEY & ASSOCIATES, Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 1 - -A

s 47 t not be subject to unique aging. 1 i one is how much information should be in i ' Y The last 2 be in the license renewal application and how much should 3 the FSAR supplement. 4 [ Slide.] i 5 Those were our primary areas that l MR. DOROSHUK: 6 over the last nine months to come up with our 7 we looked at I The issues of fatigue and EQ that were part of 8 approach. he l the Commission briefings in December have been put into t 9 t generic issues evaluation. l 10 ~ The executives established these guiding 11 the Ad Hoc Advisory Committee, ' principles to assure that i 12 The which was made up by the industry, had a clear vision. 13 the industry asked itself who was Ad Hoc Advisory Committee, 14 who are we serving, who are going to produce 15 our customer, 16 this product for. The industry license renewal Ad Hoc' Advisory i 17 our customer was the public and Committee found that 18 There are others. The continued safety of the plants. l 19 the ratepayer, the operators. Nuclear Regulatory Commission, 20 Our' deliverable, although a complex one to 21 is a simple one -- continued safe and cost-22

produce, The second principle was effective operation of the plants.

23 are good. the fundamental principles of 10 CFR Part 54 24 that of age-related degradation unique 25 The concept and the intent i 4 LTD. i ANN RILEY & ASSOCIATES, Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 t i

1 i 48 I to license renewal, we found, was also a good one. 1 The framework that was built around these concepts i l 2 and these principles within the rule was also a good one. 3 provides a logical flow as to where a licensee applies 4 It to licensee _ maintenance its resources and gives credit 5 6 activities, as it should. The question we then asked was with the exception 7 d of age-related degradation, what would happen if we foun 8 our plants are maintained in a good working condition 9 that The answer is that is the standard. 1 and a safe condition. 10 the last principle As we developed this process, 11 develop yet another box was to ensure that we did not 12 We have a significant amount diagram that was not tested. 13 through Calvert of results produced through the lead plants, 14 through the B&W Owner's Group and others that 15

Cliffs, it against allowed us to take our proposed approach and put 16 against plant maintenance practices to 17 plant data, put it We were not going to come up with an 18 see if it made sense.

We're still working on it. approach that we didn't test. } 19 These guiding principles are not a significant 20 ~ That is why the departure from the intent of the rule. 21 the following approach can be industry believes that 22 starting over. 23 implemented without The adjustments to the definition and how the 24 license renewal application is structured are both 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 49 reasonable and justified. 1 [ Slide.) l 2 the As you can see from this slide, l MR. DOROSHUK: 3 industry approach for conducting the integrated plant i' 4 has retained the framework of the existing rule. i 5 assessment l in parallel, have been We have developed this approach and, 6 as discussed before working on the adjustments to the rule, t I 7 This approach is based on our perceived intent on what age-8 d related degradation unique to license renewal was suppose 9 a broad net and focus your to have accomplished - cast 10 resources effectively on the right part of the plant. the approach will require. a licensee to f 11

Briefly, l

12 structures and then run those systems, b " screen the plant," 13 components, make a determination of which ones could or I ~I 14 have age-related degradation unique to license ~ 15 could not l renewal for those SSCs that we deem that possibly could have l l 16 unique aging, the effective program evaluations and the 17 s level of detail in the application. i 18 ISlide.] 19 l Age-related degradation unique to s MR. DOROSHUK: I 20 license renewal in the industry approach is age-related l' 21 currently managed, may i if not degradation whose effects, l 22 in the loss of an ITLR function of a system, t 23 result l during the period of extended structure or component 24 25 cperation. i LTD. 7d04 RILEY & ASSOCIATES, Court Reporters 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 (202) 293-3950

~ T i 50 At the heart of this approach is the recognition 1 such as the that our maintenance strategies and activities, 2 currently-monitor, test and inspect maintenance rule, that l 3 in a manner that assures the function could not be 4 4 equipment subject to age-related degradation unique to license l 5 6 renewal. We do, however, agree that certain long-lived l 7 structures and components may require an assessment l 8

systems, ted.

to determine if additional licensee actions are warran 9 [ Slide.] For the purposes of the overview of f 10 MR. DOROSHUK: 11 since the industry did not the integrated plant assessment, f 12 I will not go take exception to the screening of the SSCs, 13 nor did we i over the industry approach with regard to that, l 14 of the effective program evaluations. take exception to most i 15 I will discuss in the level of detail one concern. i 16 We have attempted to develop a method in our i 4 17 l allows the licensee to identify and to conduct 4 18 approach that We follow-on evaluations of structures and components. 19 structures or s believe that these long-lived systems, 20 components might or could experience unique aging. i 21 for example, this In this method, we feel, 22 component might have a service life of greater than 40 years f 23 and we've defined passive in our working i ~ 24 and it is passive, l from the NUREG on risk-based 25 definition. We took it 1 i ANN RILEY & ASSOCIATES, LTD. i Court Reporters l i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i I

51 i 1 maintenance. A passive component is a component that cannot 4 2 or should not change state during normal or accident i 3 conditions. l 4 The Ad Hoc Advisory Group believes that this.is a t 5 first step in trying to determine what part of the plant is t 6 the right plant to evaluate for the renewal period. There 7 are other criteria that we are working on in assuring that t I 8 the passive part of the plant is correctly identified. 9 As I discussed before, we're working extensively i 10 to test this approach. It's not final, but, at this i 11 juncture, it appears that at least it's a working step that i 12 'does identify those long-lived SSCs I 13 The second part of our process that would identify 14 systems, structures and components that could be subject to i l i 15 age-related degradation unique to license renewal are those 16 SSCs that are not addressed by the maintenance rule, they 1 17 are not replaced or refurbished, or they are not addressed 18 by existing maintenance strategies. 19 These SSCs that are either long-lived or not J 20 covered by existing licensee programs would be evaluated in 21 accordance with the existing rule requirements, in 22 Paragraphs A-3 through A-6, the mechanistic aging analysis 23 and effective program reviews. 24 ISlide.) 25 MR. DORCSHUK: The industry approach does credit, IJM RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

52 'I however, properly -- the industry approach gives credit l 2 where credit is due. The standards that current operating i 3 plants live to today is safe operation. That's the 4 standard. It's a collective result of sound design, i 5 analyzed conditions, operator adherence to procedures, and i 6 good solid maintenance. 7 We believe the ability to rely on our maintenance, ) B the ability to carry forward this standard is also embraced i 9 by the second principle of the rule. Therefore, for those l l 10 systems, structures or components which have been determined 11 not to be long-lived and who are covered by one of the next ) 12 three criteria, we don't believe that they could be subject ~ 13 to unique aging. i 14 The fundamental objective of the maintenance rule i I 15 is to provide reasonable assurance that systems, structures i 16 and components will remain capable of performing their 17 function, combined with the fact that timely and appropriate 18 corrective action will be taken by licensees should 19 performance degrade, gives us the confidence that this set 20 of equipment will continue to operate as intended and to the 21 standard during the extended period of operation. 22 [ Slide.) 23 MR. DOROSHUK: For those systems, structures or 24 components who are not long-lived and are not subject to the 25 provisions of the maintenance rule, we believe that the 1 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W, Suite 300 Washington, D.C. 20006 (202) 293-3950

53 1 replacement or refurbishment activities, either based on i 2 time or conditions, wil.1 prevent a system, structure or 3 component from being subject to unique aging, or if there is 4 an existing program, a maintenance activity at the site that 1 ] 5 does ensure the performance of the function will continue in 6 the renewal period, that, too, could not be subject to age-7 related degradation unique to license renewal. l 8 [ Slide.] 1 1 9 MR. DOROSHUK: As I mentioned earlier, in order to l 4 10 provide assurance that activities credited to either prevent f 11 age-related degradation unique to license renewal from a r 12 occurring or ensure it is adequately managed, the industry 13 approach would make commitments on these activities to carry s 14 them forward consistent with the fundamental principles of l 15 the rule. 1 l l 16 These commitments, however, must remain consistent i 17 and to the same extent as in the original license period. i 18 What this means is if I have a set of safety-related pumps { 19 that are subject to a condition monitoring program, such as 20 a vibration monitoring program that is not a current 1 21 licensing basis program right now, and I was going to rely l ] 22 on that to assure that there was no unique aging, I would { i g 23 perhaps discuss this in the FSAR supplement and state that 24 the condition monitoring program that these pumps or motors are subject to would continue. 25 J i ? i i 3 ANN RILEY & ASSOCIATES, LTD. i Court Reporters ) 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 54 1 But I would not go into a line-by-line PM-by-PM 2 listing of activities with acceptance criteria in crediting 3 these existing programs. The level of commitment that we 4 make must remain consistent and not overly burdensome. i 5 [ Slide.) 6 MR..DOROSHUK: With regard to the level of detail 9 7 in the license renewal application, we have found that the 8 current rule requires the licensee to include all of the 9 lists, all of the interim steps, all of the interim findings l 10 that you would come up with in performing the integrated i 11 . plant assessment. l 1 12 We feel that although the integrated plant 13 assessment is an important evaluation that should be l 4 14 submitted, it should not be incorporated into the FSAR. We l 15 believe that only pertinent results and findings should be j 16 in the FSAR supplement. i i 17 [ Slide. ] 18 MR. DOROSHUK: What is our product? Continued i 19 safe operation. The industry approach, in our view, does 20 this. The need for adjustments are reasonable and do not l l 21 represent starting over. I 22 We appreciate this opportunity to discuss where we l 23 stand. We have a 1ot of work to do still and hope that our 24 work is helpful to the NRC in coming to close on this 25 important issue. IJU4 RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

55 1 At.this point, I'd like to turn it over to Terry 2 Pickens from Northern States Power, - will give you some i -- 3 examples that we've used to benchmark our approach. i 4 MR. PICKENS: Thanks, Barth. 5 [ Slide.] 6 MR. PICKENS: As we prepared for the workshop here 7 and went through the process and came up with things, we had 8 a great deal of discussion on what would be the appropriate c 9 examples to put up and discuss with you here today. c 10 I'd like to express my appreciation to the NRC for 11 cutting off those discussions by providing the examples in i '113, which we said that's the best way to go. We'll use the 12 13 NRC's examples and we'll provide a comparison. What I 14 intend to do as I go through this is provide a comparison of 15 the approach that they've taken in 113 and show you how, in [ 16 our process, what steps we would take out, consistent with i 'I 17 Barth's discussion. 18 Before I go through the specific examples, I guess 19 I'd like to make the point that as I went through them, I j f 20 was encouraged. The reason that I was encouraged was 21 because what I saw and I think you will see, too, is that in 22 many cases, as we go through regulator-licensee activities, 23 we are in violent agreement. I 24 What you will see is that the actions that are 25 necessary to ensure safe operation in the extended period of { i i ANN RILEY & ASSOCIATES, LTD. t Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 [ (202) 293-3950 l t ., _.... - _. _ ~,

. ~ 56 1 operation, I think we're in agreement. I.think what we're 2 finding, though, is, as we go through it, we think that that i 3 precludes or says age-related degradation unique to license 4 renewal is not present. 5 I think on the other side what we're saying is 6 that's the basis for the technical content of effective i i 7 programs that we need to deal with age-related degradation 8 unique to license renewal. So we're on one side. We don't 9 think it's unique because we've had these existing actions i 10 and we know what we need to do. On the other side, it's 11 let's just make those effective programs. I think we need 12 to work that out. \\ 13 The examples that I'm going to run through, the 14 first two deal with (a) (1) and (a) (2), primarily the t 15 scoping. They're in there primarily for completeness. The i 16 other examples that go down will take a look at the IPA i i 17 process, age-related degradation. unique to license renewal i 18 and effective programs. 19 The last bullet that appears down there was not in i 20 93-113. What that is is in additional discussion of other 21 non-safety-related components not under the maintenance 22 rule, kind of down in the noise level, if you will, and.what i 23 our approach is to those. 24 [ Slide.] 25 MR. PICKENS: As I mentioned, the first two i k ANN RILEY & ASSOCIATES, LTD. l 1 Court Reporters 5 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 f

57 l 1 examples take a look at (a) (1) and (a) (2). I always like to 2 start off with something easy.. We are in agreement with'the 3 conclusion that the NRC came to in SECY 93-113, that, j 4 indeed, the feedwater pump is not important to license j 5 renevral and how they came up with that and the basis 6 provided; and, second, the safety-related feedwater system j 7 vent and drain valves, how it tested (a) (2), concluded that 1 8 it did not contribute to the performance of a safety 9 function nor would its failure preclude the system's safety l 10 function from being performed, we agreed with that. l 11 So we can move on to the other examples now and .i 12 ' see if we remain in agreement as we go through. 1 13 The first one that I'd like to take a look at is t 14 the Class I piping. Under our process, this is one that we l i 15 would categorize as.a long-lived passive system, structure 16 or component. Under SECY 93-113, thT staff concluded that j 4 17 it was important to license renewal, that it was l 18 functionally required under (a) (2), it could be subject to I 19 age-related degradation unique to license renewal. They d l 20 took it down and dispositioned it on the basis of having an l 21 effective program. l l 22 Going through the elements of what's in that i 23 effective program, you see that it's primarily existing i 24 regulatory processes and programs and the codes, through 25 ASME Section 11 inspection and testing, through other i I I IJ3J RILEY & ASSOCIATES, LTD. Court Reporters l 1612 K Street, N.W., Suite 300 j Washington, D.C. 20006 (202) 293-3950 t 't y mm. .~_-_,.,m.

.- _ ~ ~ i ? 58 1 elements of the regulatory oversight process that are being i 2 credited as an effective program. 3 Under the industry approach, we agree it's f I 4 important to license renewal, it's functionally required, it .j 5 could be subject to age-related degradation unique to 6 license renewal, and since it is a long-lived passive i 7 component, that we have to go through the process even l 8 though it's under existing programs of reviewing those and i 9 concluding that it is, indeed, adequate for addressing I 10 aging. 4 11 It is possible under our review that we would J 12 conclude there is no age-related degradation unique to i 13 license renewal for some of the specific mechanisms that i 14 we're going through, if, under current code, processes and 15 things, we can prove on an analytical basis that for 60 i 16 years it will stay under those regulatory limits that are l i 17 contained in the current licensing basis. l 18 Many of the elements of the effective program that i 19 the staff came up with in terms of inspection and those l 20 types of things we would agree with. We would capture those 21 and put them into the appropriate programmatic review. 22 [ Slide.] l 23 MR. PICKENS: Likewise, the second example for the I 24 detailed ones, the intake structure is also a long-lived 1 25 passive system, structure and component. The NRC went 1 IJN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

59 1 through. They said it could be subject to age-related 2 degradation unique to license renewal. They once again 3 dispositioned it on the basis of having an effective j J 4 program, as outlined in NRC Reg Guide 1.127, combined with 5 the maintenance rule controls. 6 Under the industry approach, we would, again, 7 assume that it could be subject to ARDUTLR and we would l l 8 process remaining IPA steps. Again, we may go through and 9 find that elements or mechanisms that were addressed there i 10 are not subject to ARDUTLR. We would disposition them based l 11 on our results. ] d 12 An important point on both of these first two is i 13 that the staff will be involved in reviewing the IPA i 14 process, the conclusion that it's adequate, that it's 15 exercised things, and that it has come to the appropriate i 16 conclusion, and that all of the elements that are necessary q i 17 are there. J -18 I guess in these first two examples, I'd like to 19 say that the technical elements which are contained in the 20 resolution under 113, we may not be in complete agreement 21 with them and that's the part that we would probably go back 22 and forth with on the staff right now, but we would need to i 23 go through that type of process on long-lived passive j 24 structures, systems or components. i 25 [ Slide.) 1 ) t i ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 ,,y g ~

60 1 MR. PICKENS: The next example had to do with 2 safety-related station batteries. The NRC approach said 3 that there was nc age-related degradation unique to license 4 renewal on the basis that it was a short-li-d component. 5 As part of that evaluation, they've looked at the programs 6 that are in place under tech specs and those types of things 7 which require replacement when your capacity gets down to a 8 certain level. 9 Under the industry approach, we agree we would 10 have no age-related degradation unique to license renewal. 11 In implementing our philosophy that systems, structures and 12 ' components should be dispositioned at the highest possible 13 level, however, we would not go down and do a review of the 14 specific programs associated with that. 15 We would credit, at that point, the maintenance 16 rule and the fact that the station batteries are under the 1 17 maintenance rule and that that review that has been l 18 accomplished as part of the CLB under the maintenance rule i 19 has concluded or precludes the possibility of age-related 20 degradation unique to license renewal. 21 It is important to remember then that the 22 maintenance rule assures acceptable functional performance 23 and that on a periodic basis, the effectiveness of that, of 24 the performance levels or of the specific preventative 25 maintenance, programs if performance degrades would be looked ANN RILEY & ASSOCIATEf., LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

..a.. -.u- ~. s .or s -s- .w-- e a ....... >.s. 61 1 at. That whole process continues through the extended I '2 period of operation. That's why we feel we can disposition t 3 it on the basis of the maintenance rule as having no age-i 4 related degradation unique to license renewal. 5 [ Slide.) 6 MR. PICKENS: The refueling water storage tank. f i 7 Again, this is one that we have put into the category of our 8 long-lived passive systems, structures or components. The j 9 NRC identified that it could have age-related degradation 10 unique to license renewal. We, again, would assume the same j 11 thing, that it could have. t 12 They said based on a one-time inspection, they j t 13 confirmed no age-related degradation unique to license 14 renewal. In terms of approaching it for us, we would, j i 15 again, process it through the IPA process. It may be that i 1 16 we conclude that a one-time inspection is what is required i i 17 to assure that there is no age-related degradation unique to i i 18 license renewal. l 19 However, if the tank was already subject to an 20 existing program under ASME and'was already going under l i 21 current inspections and those types of programs, we would 22 look at that program and see if we had enough data to 23 conclude that that was precluding age-related degradation r 24 unique to license renewal, and rather than coming in with 25 the one-time inspection to confirm it, we may come in with i ANN RILEY & ASSOCIATES, LTD. Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 { (202) 293-3950

1 62 ) 1 an analytical basis, based on operating-history or something i 1 2 like that, that provides the basis of this point. i 3 We also believe that we would conclude at the end, i 4 like the staff did under the one-time inspection, that there 5 is no age-related degradation unique to license renewal. i 6 [ Slide.] I 7 MR. PICKENS: Safety-related cable to the RHR i 8 pump. We have credited this or we would, in our process, l 9 credit this as a system, structure or component under an l l 10 existing program. The NRC, in theit approach, said that it I i 11 could have age-related degradation unique to license renewal 12 and then an effective program was required. 13 We would not go down to the extent of saying that 14 an effective program is required underneath the license 15 renewal rule. We would say that the current existing l i 16 program, as captured, as required by 10 CFR 50.49, requires 17 a qualified life at all times. It specifies the acceptable i 18 methodologies for determining that qualified life and it 19 also requires that if we do not have it under a qualified 20 life, that we would be required to replace it. 21 That qualified life and the methods can come up 22 with a life that's ten years, 20 years, 40 years or 60 years [ 23 under already approved methods that are being looked at 24 under the regulatory oversight process even as we speak and j i 25 that by that, that's a completely effective program and we j i l h ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 63 i 1 would not consider these potentially subject to age-related 4 2 degradation unique to license renewal. 3 [ Slide.] 4 MR. PICKENS: Safety-related motor-operated 5 valves. Under 113, the staff approached it and said that it 6 could have age-related degradation unique to license renewal i 7 and that an effective program was required. Again, this is j 8 one where, if you look at the details of the effective 4 9 program requirements, it's primarily a citing back of many l 10 of the existing programs that alread,y exist under the il current licensing basis today, such that we would take it I 12 ' down and under the maintenance rule, we would say that it's 13 the active elements, the actuator, the shafts, the seats, J 14 the seals, those active components that are tested by the 15 functional -- are appropriate for being watched under a i 16 functional performance criteria were covered by the i 1 17 maintenance rule. l 18 They preclude age-related degradation unique to l 19 license renewal. The similar process that I talked about for the station batteries where the maintenance Imle assures 20 1 i 21 acceptable functional performance. If that performance is 22 observed to degrade, modifications and corrective actions { 23 would be made to that program is what allows us to say that 24 there's no -- it precludes the possibility of age-related 25 degradation unique to license renewal. i IJUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.. W., Suite 300 Washington, D.C. 20006 (202) 293-3950 a o

l 1 64 1 The valve bodies would be treated as a different 2 animal and they would be treated similar to the criteria 3 that we're developing to address system' piping and other 4 passive components. l 5 [ Slide.] 6 MR. PICKENS: The next example that the staff gave 'f 7 in 113 dealt with internal flood mitigation components that-i 8 could possibly -- their failure could possibly keep a j f 9 safety-related function from being performed. They 10 concluded, however, that while it could have age-related 11 degradation unique to license renewal, they implemented 12 their concept of fundamental safety importance, concluded 4 13 that it was not of fundamental safety importance, and no i 14 effective program was necessary. 15 Under the industry approach, we would say that it 16 is not subject to age-related degradation unique to license 17 renewal. We would do that on the basis of existing programs l 18 that either result in replacement, refurbishment or I i 19 monitoring and maintenance being done on these systems. r i j 20 The water level indicators, as other q instrumentation and control in the plant is done, is 21 22 replaced or refurbished based on condition monitoring l i 23 through the calibration program. When you can't calibrate 24 it or you're drifting too much, then you take actions, 25 usually of going and replace or refurbish or take some l 1 l 7JUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 1 (202) 293-3950 v i i

j' l 1 2 65 ( 1 action on those indicators to get them back. i The flood drains would be covered under existing 2 3 plant programs, similar to the extent that they're covered today to ensure that they're there and available to take the 4 5 water away when they need to, that those existing programs 6 would be adequate, As Barth discussed, we would commit to continue those into the extended period of operation and 7 that the same manner and same extent that they are being 8 9 done under the current licensing basis is the appropriate l level for them to be treated under License renewal. 10 11 The last area that I promised to talk about was a l t ' little bit more on other non-safety-related components. 12 I are those This group of components that you're talking about 13 things that would not be underneath the scope of the j 14 15 maintenance rule J By definition and looking at how they scoped out l 16 I 17 the maintenance rule and things, these are things that are 18 starting and, in my words, getting down into the noise level j in terms of safety significance and how should we treat 19 20 them. I 21 When you look at things in the plant, you see l things like fire protection piping being replaced based on a ] 22 condition monitoring on a regular basis throughout our 23 J 24 plants. You see things like the instrumentation and control i i components being replaced and refurbished, as I discussed, 25 I 1 JJRJ RILEY & ASSOCIATES, LTD. Court Reporters I 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

.1 66 1 based on condition monitoring through our calibration 2 programs. ) 3 We send breakers out on a regular basis to the 4 electrical side of the house to refurbish them. Motors are 5 taken out, rewound. A number of those types of things are 6 being done as necessary on these types of things. Some of i 7 these it's possible may remain in life for longer than 40 8 years. 9 There is no specific lifetime defined. There's no j l ] 10 specific requirement to go in and replace those now at ten 11 years or 20 years or 40 years. Aging is occurring on those 12 components under the current license, with no specified 13 actions necessary to look or monitor or do anything about 14 that aging. W 6 15 From that, we have not seen any safety concerns 16 coming up. The regulatory oversight process is there should 17 it happen, but we have not been seeing that under the e 18 current license. It's our position that the existing 4 19 programs, to the extent and the same way that we deal with ? 20 them, are appropriate to monitor and correct. And like it 21 assures adequate operation, acceptable safe operation today, i 22 it will continue to be adequate through the poriod of 1 i 23 extended operation for these lesser systems, and that's how l 24 we think they should be appropriately treated. l i 25 With that, that concludes the examples. Bill, was ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950

.i i t 67 i i I somebody going to do some concluding remarks? I'll turn it i 2 back over to Bill for some summary remarks. 3 MR. RASIN: At this time, we would_be happy to j 4 entertain questions for any of the panel members on the 5 presentations. Tom? 6 MR. MURLEY: I have two questions or comments. l T 7 Maybe somebody on the panel could address them. One is the 8 apparent very, very strong dependence on the maintenance 9 rule in your approach. In fact, the slides actually simply 10 make assertions that because of the maintenance rule, you 11 could not have age-related degradation and so forth. 12 As you know, the maintenance rule isn't even 13 effective and won't be effective for a few years. So aside 14 from the legal question of depending on a rule that's not 15 effective yet, I have to say I think there's a technical I 16 question, too, as to whether once we get into implementing i 17 the rule and the staff starts discussing with licensees how j 18 they're setting these performance goals and how they're 19 actually demonstrating that these performance goals are met, l 20 we could, I think, very easily get into the kind of quagmire i 21 that we got into under the license renewal rule. 1 \\ 22 So I think you have to acknowledge that the 23 maintenance rule is not a proven thing yet. So when you 24 make your proposal, my suggestion is you really address that 25 possibility. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 9

68 1 The second question is the nature of commitments. 2 I think Barth mentioned an example of a pump vibration 3 program that they have. It seems that under your proposal,- j 4 commitments that you describe in the FSAR and that you rely 5 on would take on a bigger hat in the renewal period-than 6 they do in the current period. 7 I think that's kind of our conclusion, as well, 8 but I'd be interested in if that's how you see it and if 9 that's what your thoughts are. 10 Then at some stage, a practical question, I don't r 11 know that you have to address it here, but I guess my staff-l 12 ~ and I would like to know if we were to change this rule, { t 13 it's going to take some time, what parallel activities would q 14 be -- could be undertaken during this period when the rule 15 is being changed. i 16 Are there fruitful activities, do you think, that l 17 could go on? t 18 MR. RASIN: Let's address those in parts. I'd i 19 like to save the maintenance rule discussion for last. j t J 20 Barth, do you want to address the question on the I 21 commitments, Example 5, like the pump vibration program? j r 22 MR. DOROSHUK: Yes, sir. Dr. Murley, committing f I 23 to a program in the FSAR supplement on a set of equipment 'I 24 that we would be concluding unique aging was occurring, our 25 concern is that we would not find that these programs turn l 1 l l t JJG RILEY & ASSOCIATES, LTD. l Court Reporters l 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950 t

l 1 l 69 into tech specs or license conditions on each activity. ) 1 2 The commitment in the FSAR supplement to, for 3 example, have a condition monitoring program, that would 4 make it inspectable by the NRC, but it would also allow the licensee to implement that program as it's required based on 5 6 the plant history and plant performance. 7 So it wouldn't handcuff us, so to speak, on every 8 PM with that condition monitoring program. It would give 9 the assurance it would continue, but it would allow the 10 licensees to manage that program. h;e would not want to see 11 that in the form of a tech spec or a license condition. 12 MR. RASIN: With respect to what can we do in the 13 interim, Mike, do you want to say a few words on that? 14 MR. TUCKMAN: Dr. Marley, obviously, we're not 15 going to sit still and wait for the rule, because sometimes 16 those take a month or two to finalize. We believe that 17 there's some significant work that the industry can do that 18 we would continue, like the IPA process, developing the 19 screening, doing the technical evaluations of those long-20 lived components that we think need to be looked at. ~ So there's work that we can do, meaningful work 21 22 that will not be wasted, assuming that the rule comes out in 23 a way that we will be able to pursue license renewal. We will continue forward with the IPA process of screening and 24 25 those evaluations of long-lived components, as best we NnJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

1 70 I 1 understand they need to be done. 2 MR. RASIN: Let me say a few words about the 3 industry view of the maintenance rule and then Terry Pickens i 4 will add some thoughts from that, coupled with the practical l 5 regulatory oversight that he experiences all the time at his 6 plant. 7 The industry has put a lot of effort into the 8 maintenance rule and looking at how to implement it as it 9 was intended, in a meaningful manner, to put the resources 10 in to do it right. In return, the industry is taking it s 11 very seriously and we expect, therefore, to take maximum 12 advantage of that effort.that we are putting into it. 13 The maintenance rule, it's true, it's not ~ i 14 implemented today, but, in fact, the implementation process i 15 is proceeding. It will be implemented by 1996 and we do not f i 16 envision license renewal applications coming in and being 17 approved before that time. 18 So we think it is important that we take maximum 19 credit with all the effort we put into that maintenance 1 20 rule, both the industry and the staff, and not put the 21 needless same duplicative effort into the license renewal i ) l 22 rule. 1 23 Terry, would you say a few words about the 24 maintenance rule coupled with regulatory oversight? 25 MR. PICKENS: I guess I'd start by saying that as ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

I 71 1 good as we are, and in we I will include the industry and 2 the NRC staff, that probably there's not many perfect 3 programs that we have out there at this time. That's the 4 purpose of the regulatory oversight process. 5 I think that there are certain expectations that 6 have been laid out by the Commissioners with regards to the 7 maintenance rule and that through the regulatory oversight 8 process and the tools that the NRC staff has, that I'm sure 9 that you will continue working on the maintenance rule until 10 we get that right. 11 In that manner, as we approach operation for year 12 ~30 or year 40 or for year 60, we will get to that point and 13 it will continue in whatever appropriate way that it needs 14 to be. So I guess my response is although it may not be 15 perfect the first time we get through, we may go through 16 some quagmire. As we go through operation through the 17 regulatory oversight process, it will be improved and it is will be in place and be effective, or else the Commissioners 19 and yourselves would go back and look at what changes you 20 need to make to that. 21 That, I think, is inherent in the principles of ~ 22 how we ensure the current licensing basis is not stagnant 23 and is not a set thing, but it continues to evolve and 24 change as it needs to all through the license period of our 25 plants, whether it's 40 or 60 years. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i i f 72 1 MR. RASIN: Bill? 2 MR. RUSSELL: I've got two questions for Terry. I 3 Bill Russell from the staff. The first comment is that I'm i 4 very encouraged by the results of the technical screening t 5 that you did to see that you came out in close agreement i i 6 with the examples that the staff had identified and would l 7 suggest that this is an area for additional dialogue to make 8 sure that there is a sound understanding of what you're 9 proposing by way of a process, and that we would illustrate 10 through many more examples how a proposed definition of age-l t 11 related degradation important to license renewal could be 12 used. 13 I find that when you talk in the abstract, without 14 hard examples of how something is applied, that different l 15 words have different meanings and it really needs to be l l l 16 explicitly illustrated. i 17 with respect to your examples, I just want to j 18 illustrate why I think this dialogue is important. Your one i 19 example on cabling, you said that basically you would i 20 replace, under a current equipment qualification program at I 21 the end of qualified life, I would submit that plants which l I 22 are under the DOR guidelines do not have a qualified life, i i 23 They did not test to establish a lifetime for j 24 cables. That was waived. So for the bulk of the plants, j 25 that approach would appear to not be sufficient since there ) i s e Idai RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 j (202) 293-3950 j _m,

i 73 t I was not a pre-aging to demonstrate cable qualification in I P 2 the manner that it's done for new plants. 3 Now, that's exactly the generic issue that we're 4 looking at. So all I'm saying is that here is an area where 5 there's a known open issue or a hole in the current process 6 for a number of plants. So using that as an example to say, i 7 ergo, we can dismiss this issue, it's not clear yet that j 8 we're that far along. 9 The other is your last examples where you talked 10 about passive and active components,in the same example. 11 You included fire protection piping, which is long-tcrm 12 passive, which, as I understood it, would be things you'd be -~ t 13 looking at as potentially within the definition of age-14 related degradation unique to license renewal, and then you 1 15 included instrumentation and control components, breakers, 1 16 motors, things which are generally active, which are covered 17 within the scope of the maintenance rule. 18 So while I'm generally encouraged, I think we need 19 many more examples to work through to see how this would, in 20 fact, be implemented. I do think this is an area that we 21 would need to pursue in parallel with rulemaking and 22 potentially provide some of those kinds of examples in such 1 23 a package. j 24 MR. RASIN: Other questions? Terry, did you have 25 any response to that? JJUJ RILEY & ASSOCIATES, LTD. 1 Court Reporters j 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i i

I 74 l 1 MR. PICKENS: 'I guess I'm not sure if there were { I 2 specific questions contained in there. 3 MR. RUSSELL: A few observations. f 4 MR. RASIN: That's the way Bill usually. asks 5 questions. He tells you the answer and you listen. 6 MR. PICKENS: I agree we need dialogue. l 7 MR. RASIN: Barth? t 8 MR. DOROSHUK: I have a comment on the example 9 with regard to the EQ cable. Recognizing that the issue is [ t 10 undergoing generic review and that's the appropriate forum j 11 to have those issues resolved, there will be other issues 12 that are unresolved in the generic issues review when we 13 apply for license renewal. l 14 My observation is that that's the proper way to { 15 handle it and when those are resolved, the activities and i 16 requirements will be implemented. I would not expect that l ) 17 if I had a DOR cable to bypass the generic issues review, a 18 safety issue review alone and propose a solution and 19 renewal, I would rely on that process to work through, 20 regardless of renewal. S 21 MR. MIZUNO: This is Gary Mizuno in the Office of 22 General Counsel for the NRC. I noticed that there aren't 23 any attorneys on the industry panel, so I'll be making some 24 observations, but I will not be expecting any kind of 25 response at this time. I would expect that I would see some ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

75 ) 1 response in your written comments. 2 First, with respect to your Slide 6, your second l 3 bullet there, it would be uh '1 if the industry were to l 4 identify in their written c' knts what portions of the 5 license renewal rule or the statement of considerations they 6 view would preclude an applicant from using or trying to 7 evaluate current activities using component types or e ccrmodity groups. This is on your Slide 6, level of detail. 9 My next comment is on your Slide No. 10 under 10 industry approach, which is also a 1,evel of detail and I 11 guess a statement of principle with respect to licensee 12 ' cormitments or the principle that the industry would like l 13 the NRC to adopt. 14 I guess the question or the observation I would 15 like to make is I would like to have an explanation from 16 both a technical or policy and a legal standpoint that 17 provides the basis for this principle. For what reason can 1 18 the NRC adopt this principle consistent with the two 19 principles of license renewal? 2D Third, and this is not necessarily related to any 21 specific slide, but it's a followup on the point that Bill 22 Russell was making with respect to the maintenance rule. I 23 guess it's been OGC's observation that although compliance 24 with the maintenance rule can be relied upon as a basis for 25 showing an effective program under the renewal rule, the i i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i i 76 I maintenance rule has no specific requirement for setting 2 your gceis and objectives consistent with maintaining the l 3 CLB. I 4 So it would be useful for the industry to address 5 at least this particular point, whether they agree with this { 6 observation and, if not, what in the language of the l 7 maintenance rule would require the licensee to establish l 8 goals and objectives, performance objectives consistent with 9 the CLB. 10 Then the final question I have deals with the i 11 hearing issue. I guess there are several facets of that. i 12 ' First of all, what is the industry's concept of acceptable 13 contentions or issues that could be raised under the 14 industry's or NUMARC's approach to license rennwal? How 15 does it differ from the contentions that could be raised 16 under the existing Part 54 rule? 17 Second of all, whether they could address at least-18 my observation that the implications of the industry's 19 approach to relying upon existing programs is different from 20 the implications under the -- or for purposes of litigation 21 in the existing Part 54. 22 The reason why I see this difference is because 23 under the existing Part 54, if the industry decides to 24 choose to rely upon existing programs as an effective 25 program, the hearing issues fall into the area of saying ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W,, Suite 300 Washington, D.C. 20006-(202) 293-3950 I

77 i i does the existing program, in fact, address age-related j i 2 degradation unique to license renewal. 3 Therefore, if an existing program is determined in l 4 litigation and the hearing process to be not sufficient for 1 l 1 5 addressing age-related degradation unique to license 6 renewal, its implications for the licensee are only that it r 7 has to do something additional. It has failed in the 8 hearing process and has to show something else to meet age-9 related degradation unique to license renewal. 10 However, in contrast with'that, under the NUMARC 11 approach, as I understand it, you are going to be using. 12 existing programs as a basis for saying that there is i 13 ARDUTLR at all. I think the implications of that in the i 14 hearing process.is that if you fail to show that your l 15 existing program demonstrates that there is no ARDUTLR, you 16 may also have unintended implication of saying that your ] 17 existing program is not even good for addressing aging i i 18 currently, because I think the underlying argument that is j 19 being made in the industry approach is that our existing 20 programs are sufficient. 1 i 3 21 If you fail in litigation and license renewal to l 1 22 show that your existing programs are sufficient, you have an l 23 implication there not simply for license renewal, but for 24 current operations. I think that that, at least from my j 25 perspective, is a significant negative aspect of the i 1

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Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 .,m m

l 1 78 I 'l 1 approach that NUMARC-is proposing here. 2 If I am misinterpreting or I have not considered a 3 particular legal aspect that would remove this kind of 4 implication in the hearing, then that would be useful to be i i t 5 addressed in your written comments. i i 6 MR. RASIN: Thanks very much, Gary. We will j i 7 certainly consider all of those remarks. I'd like to j 8 comment on a couple things that I think get to the heart of j i 9 demonstrating why we feel that some adjustments to this rule 10 are necessary and that, in fact, what we have done here is 11 constructed a process that has created problems. 12 I would submit that licensees are today 13 responsible for maintaining and operating within their CLB. 14 It's been pointed out that we do not have a maintenance rule 15 in effect today. Somehow we must be doing this. 16 Why now is it all of a sudden a whole new issue 17 with is the maintenance rule good enough when we start 18 talking about license renewal? I think, intellectually, 19 that just does not make any sense. I think it makes sense 20 legally because of the way the rule is written and because l 21 of the process the rule requires and the findings that are t 22 required to serve the process, not to serve any technical i i 23 basis, nor to serve reactor safety. j 24 Finally, I think I'd just like to, I think, l 25 summarize what we have seen in our discussions to date and 1 l ANN RILEY & ASSOCIATES, LTD. -l Court Reporters { 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 ) (202) 293-3950' e

79 1 1 in our presentations today. What you have seen in technical j i 2 conclusions have been great similarities with what the staff l r 3 has concluded. 4 The industry is intent on getting full credit for 5 the maintenance rule. We are putting a lot of effort into l 6 it. We think that the Commission intended it to be a step i i 7 forward in implementing performance-based regulation. I 8 The current rule requires a process that, in fact, 4 9 is countered to perform its base regulations, whereby l 10 additional requirements must be placed on equipment simply ) t ) 11 to bolster the findings required by the rule, not to assure 12 the adequate performance or safety performance of that l t 13 equipment. 14 We are encouraged by the Commission's move to a i 15 performance-based rule. We are serious about pursuing how i 16. we can do that, because from what we have seen at least are 17 tremendous efficiencies for both the industry and the NRC. t I d 18 The Commission has stated that the rule should j 4 19 cast a broad net and we have considered this because you I 20 will remember at one time, that industry thought that that j ~ 0 21 net was a little too broad. But we've taken a careful look l 22 at that and what we believe is that the intent is to cast 4 i 23 that broad net, to make sure that all the important i 24 equipment is captured and not forgotten. 4 2 25 But the Commission further stated that having cast i IJHJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 (202) 293-3950 =

4 4 80 I that broad net, we should look for a process that quickly ti 2 gets us down to those important systems, structures and j i 3 equipment that really could have an impact on the safety for i e 4 longer-term operation of the plant. 5 What we have been involved in with the staff over iy 6 some time now is really a discussion of what is that process l l 7 that gets us from one place to the other. We do not have a j 8 lot of disagreements on the starting point, nor do I think 9 we have a lot of disagreements on the end point. i 4 10 The equipment that is going to be there, that is u 11 going to be in existence and that you're counting on for i 12 safety once you go beyond 40 years are such things as the 1 j 13 primary pressure boundary, the reactor vessel, the reactor 14 internals, the containment basemat, the containment l l t 15 boundary. Those things are going to be in place. They are f i j 16 not replaced every five years, like a solenoid valve or some 17 other expendable component. They do deserve special J 18 attention. 19 The whole argument in place is how do we get down 20 and take a hard close technical look at that piece of l 21 equipment. We intend to follow up our ccmments here with j 22 written submittals and with carefully considered language } 23 with the consultation of our industry lawyers on how to I l 24 modify the rule to create that process, so that, in fact, we 25 are not submitting tons of paper, the NRC is not having to ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 d

h l i 81 l 1 review tons of paper, to serve no other purpose than to get 2 us from the starting point to the final set of important j 3 equipment that should be considered. J 4 Thank you very much, l 5 [ Applause.] 6 MR. TRAVERS: I don't know if you intended to 7 close off the session, but I didn't see any further 8 questions. If there are, we are going to have some 9 additional opportunities this afternoon to further explore i 10 questions you may have. ~ 11 The next presentation on our agenda wasn't i ' scheduled to occur until after lunch, but perhaps Don l 12 13 Edwards, if he's in the audience, might, after a break, 4 r 14 agree to do his presentation this morning. I would suggest 15 that if he is, and it sounds like he is, we do that. So 4 16 let's break, if we can, for 15 minutes. i 17 [ Recess.] 18 MR. TRAVERS: The next presentation, which isn't, e 19 on our agenda at least, scheduled to occur until after l t 20 lunch, is going to be given before lunch. It's being given 1 21 by Don Edwards, who is Director of Industry Affairs for l 22 Yankee Atomic. As everyone continues to get seated, Don, I i t t 23 will turn it over to you. 1 24 MR. EDWARDS: Good morning instead of good i I 25 afternoon. I'm very pleased to be here and I thank you for I I 1 i ANN RILEY & ASSOCIATES, LTD. Court Reporters I 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

. ~ _. -. t 82-l i s 1 the opportunity to participate. I must start out with an j 2 apology, however, because this presentation, which j 3 represents Yankee's views of the situation, was f*irly carefully developed by our Chief Executive Officer, Andy 4 5 Kadak. Unfortunately, there was a conflict that came up at l 6 the last minute and Andy is unable to be here and you got me 7 instead. 8 I'm sorry because you're not going to get quite f i 9 'the intensity that probably would have come across. Those i i 10 of you that know Dr. Kadak would probably agree. I will ~ 4 11 try. 12 The other thing I learned as I came down here is + 13 maybe the fact that I had to carry 250 copies at 14 pages 14 might have had an effect, but I think Andy really did have a l 15 conflict. 16 The slides that you see will attempt to address 17 the questions that were posed for the workshop in the course I 3 18 of the discussions. So I will try to go through that. i 4 l 19 [ Slide.] i 20 MR. EDWARDS: Bill, you're not going to be very 21 happy because this isn't going to be a nuts-and-bolts, hard-a 22 core, material-oriented sort of thing. It's going to be a 23 little bit of a concept, but I think it's important because 24 there are some things that we see that really ought to be ) 4 25 addressed. t a 1 v IJRJ RILEY & ASSOCIATES, LTD. Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 i (202) 293-3950

i i 83 1 One of our key points 'fus that a renewal license is 2 not a new license. I was trying to understand what that l 3 meant and I looked up renewal and the best definition I 4 could get that would apply in this situation from Webster's i 5 is to arrange for continuation of, as in a contract. 6 The second point is that aging is continuous. 7 It's not unique to license renewal. Somehow I think this is 8 the situation where the king has a cold and he's going to 9 get sicker if we don't start to realize that we're dealing j 10 with a thing that doesn't exist. f 11 The third is the enactment of the maintenance rule 12 provides the basis and a clear basis for revision of the i 13 rule. And when we end up, we need to have clarity and i 14 simplicity in order to have stability. I don't think i 15 there's too many people that would disagree. 16 I know there's been a magnificent job undertaken 17 by the industry, but the current interpretations of the rule 18 are neither simple and they're not at all clear. 19 [ Slide.] 20 MR. EDWARDS: License renewal has its basis, as do 21 all the other rules, in the Atomic Energy Act, which says 4 22 that after the 40-year period, upon expiration, the license 23 can be renewed. 24 [ Slide.) i 25 MR. EDWARDS: If you take a look at the statement IJRJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 )

_~. 84 i 1 of considerations,-there is a thread of this intent for 2 renewal that says the regulatory process and the licensing 3 basis of the plants provide and maintain an adequate level i 4 of safety, that if that process continues, the adequate i 5 level of safety would continue and a formal license renewal j i 6 review of any full scope wouldn't add materially to safety. l 7 Now, there's other language in the SOC that could j 8 be used to argue other points. In fact, you could argue l l 9 about any point you wanted to out of that document, and 10 that's part of the problem. i ~ i 11 [ Slide.] j i 12 MR. EDWARDS: Our point is and our position, and l 13 this is really crucial that we start to think about this, a 24 renewal license is not a new license, it's a continuation of f 15 operation at the facilities. 16 That was, we believe, what was contemplated by the j i 17 Atomic Energy Act and by the Commission when they tried to j 18 enact the rule. So the rule that we use ultimately and the } 19 implementation guidance that we employ have got to be built { 20 around that understanding of the adequacy of the current 21 license or the licensing basis, licensee programs and the l t 22 oversight of those things. i 23 It can be an increment on that, but all of those i ? 24 activities go forward not statically, but dynamically, l 25 because the process for the licensing basis and the j i t ANN RILEY & ASSOCIATES, LTD. j Court Reporters l 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 (202) 293-3950

85 1 oversight is a process that incorporates improvement, that 1 2 incorporates change. 3 [ Slide.] l 4 MR. EDWARDS: I want to talk for a moment about 5 the lead plants. We found some things -- we found some 6 other things, too, but we found some things about license { r 7 renewal. Aging is a continuous process. It's not a special 8 phenomenon. In our aging mechanism review -- remember, at 9 that time, the lead plants were really working with some 10 written draft guidance and our effort was to look for 11 mechanisms and then address those mechanisms. i f 12 But the addressing of the mechanisms turned out to f 13 be plant programs. The lead plants and the subsequent j 14 programs, I think, showed that the aging of plant equipment j 15 is well managed now by programs that monitor performance, j l 16 that maintain equipment and refurbish or replace as 17 necessary. ) 18 That's happening now, as Bill Rasin pointed out 19 very eloquently a few moments ago, and it's going to ) 20 continue to happen. What we're talking about is what j i 21 incrementally do we have to do. l 4 22 There are some passive components, long-lived, \\ '3 because they're acina to remain installed in the facility 24 for the entire operational life of the facility, and we need i i i. ) 25 to probably make an evaluation of those. j IJCJ RILEY & ASSOCIATES, LTD. I Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 i (202) 293-3950 0 l

~. .= i 86 1 [ Slide.) l 2 MR. EDWARDS: Instead, we have the current rule, 3 which has definitions that don't have much physical or i 4 regulatory meaning. We've got the dreaded age-related 5 degradation unique to license renewal. See, I can say it, l 6 too. That doesn't define anything that's real. And we've 7 got this artificial creation of a new group of compunents j 8 that creates a distinction of the renewal period from the 9 present licensing period and starts this whole idea that i t 10 we've got something special we've got to deal with. ~ 11 If a piece of equipment is important in the current license term, then it's important in the next one i 12 13 and the next one after that. Why don't we have the i 14 continuity of that if we have a continuation of operation? f 15 We now have a maintenance rule. It's not credited l 16 or mentioned, as has been stated before. It was enacted e 17 after the license renewal rule, but it's certainly a reason 18 to take another look at the IPA and the entire license j 19 renewal rule. 20 It's interesting to note the staff said they 21 didn't need a maintenance rule. They said that maintenance 22 was adequate right now in the industry and we all got told, j 23 oh, yes, you do, because we want to institutionalize that 24 good performance, but we also want to talk about performance 25 in e performance-based rule. r ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l v n

e 87 l l 1 [ Slide.] j 2 MR. EDWARDS: Instead, we've got a rule that I ? 3 think treats the license renewal process as almost a new 4 license; start out with everything under the sun and you j 5 come up with reasons for not looking at it, because we t 6 already know what the answer is. 7 Yet, the rule doesn't really acknowledge or accept 8 -- it doesn't really accept the existence of regulatory 9 oversight in licensee programs, either by the required ~ ) 10 review or the safety findings that it impores. 11 We ought to have reasonable asrarance that systems F 12 will perform their required safety function. That's about 13 it. That's what we're trying to make sure of right now and 14 that's going to continue and that's all we need to find. 15 Lack of clarity in the ruling was not the basic .{ 16 intent, at least the one I outlined to you in typ Act and in 17 the statement of consideration, creates uncertainty and, 4 18 therefore process instability. 19 The fact that we've had a lot of different i I i programs all trying to prove how to do it and they all look 20 21 different I would hold up as an example of the problem with l 22 understanding it. 23 However, they all end up at about the same point. i 24 Existing programs are the answer to managing aging. l 25 [ Slide.) l ANN RILEY & ASSOCIATES, LTD. i Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 J (202) 293-3950 l

J 88 1 MR. EDWARDS: So how do we make the rule better? 2 I agree we don't need to throw it out. We just need to make i 3 it better. I think, and this is going to be an attitude i exercise for a few minutes, we need to accept that r 4 continuation of the licensing basis really is appropriate to 5 safety and that's kind of shorthand for all the things we're 6 doing now to get performance out of facilities and all the 7 8 things you are monitoring, NRC, to make sure we're doing 9 what we should be doing are appropriate, and accept that combination of licensee programs and regulatory oversight i 10 that's now enhanced by the maintenance rule as the assurance 11 i i 12 . 'of adequate safety. There's another provision in the maintenance rule l 13 14 that says corrective action results -- excuse me -- that [ I corrective actions have to be taken in the case where there l 15 are problems and not only at your own facility, but that an 16 17 industry-wide experience base is used for that improvement. So we really have a mechanism for dealing with new 16 19 aging issues. Certainly if we were to have the license 20 renewal process in place now, and the rule is, and people 21 were going through it and so forth and we all of a sudden l 22 came up with erosion-corrosion as a problem, we wouldn't 23 say, oh, gosh, there's an aging mechanism that's unique to I 24 license renewal. We found one, let's put it in the -- no. i 25 What we do is we deal with it right now under the k a ) ANN RILEY & ASSOCIATES, LTD. t Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

= - =. .. ~ I 89 1 1 current process and that's what's going to happen every [ 2 time. The example that we talked about before is cables. l 4 j 3 That's got to be dealt with now. 1 i 4 One thing that I think we've all finally agreed on is the equipment performance approach which is presently 4 5 managing aging is the preferable alternative to the i 6 ana3ytical age degradation mechanism approach of the past. 7 I 6 I think we all agree to that. i 9 So the question is what's really needed for 10 safety. We've all hit around the edges of it today -- l 11 assessment of the non-montu; red long-lived equipment, I i 12 structures, piping, confirmation of performance of prominent 13 plant features or those fundamental safety importance type 14 equipment that are going to be there and represent defense-1 l 15 in-depth, identification and reconciliation of exemptions to l 16 relief that have a time dependency or reconciliation of 40-and year assumptions or dependencies are in the license., 17 4 documentation of the -- we said lead plant experience, but 18 8 19 there's a lot more experience out there. 20 Aging is a continuous process. Why don't we just l 1 21 write it down? Aging of plant equipment is managed right l i 22 now by monitoring, maintenance, refurbishing and l l 23 replacement. Let's recognize that. i l 24 I have something else I want to say here in just a 25 second. This sounds and is a lot different than the sorting i i 4 I ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 { (202) 293-3950 4 l t m

90 1 process we have, which starts out with everything and sorts i i 2 right down to what-we know we've got to g# to on.long-3 lived components. What this does is say let's go get the 4 long-lived components. Hey, that's what we're going to work Why are we doing all this other stuff? l j 5 on. i 6 We don't have to do it that way. How would you j r 7 formulate something like this? j 8 [ Slide.) 9 MR. EDWARDS: Identify the long-lived passive 10 components -- I mean equipment or structures when I say t 11 components -- for the safety functions that aren't now q ' monitored in a performance monitoring program or whose 12 13 analyses don't really bound them for the renewal period, and l 14 youve got to redo that. 15 And for those, provide performance monitoring or 4 16 reanalyze them or test them or a combination of that or l 17 provide for that component failure in an acceptable way. 28 What else? 19 { Slide.) 20 MR. EDWARDS: Look at those important components. 21 Certainly, the vessel and containment. Look at the time { 1 22 dependencies and the exemptions reliefs in the license 23 itself and describe proposed modifications to the facility j f 24 that result from that review. 25 That's it. That's what the license renewal review M m RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950 o ~.

T ( 91 1 ought to be, because it's only an increment on continuation. 2 And you say, gosh, there's a lot of industry programs out t 3 there that sound a lot bigger than that and I say, yes, 4 there ought to be, because besides getting the permit to j 5 continue to operate the facility, the owners of these j 6 facilities have got to decide whether or not they can stay i 7 in business. i 8 There's a tremendous amount of economic i 9 justification and detailed evaluation that's really [ i 10 necessary. Component lifetime assessment, replacement l ~ 11 requirements of major components comparable to a capital 12 plan, forecasts of power costs, life cycle management 23 programs that try to optimize your return on investment. i i 14 Those are things that have to be done, but they're 15 not necessarily the things that have to be done for license l 16 renewal in renewal space and licensing space. They're 17 things that have to be done for economic justification. l t 18 Somehow we've got the two kind of all bollixed l l 19 together here and we've got a much more complicated process t 20 than it needs to be. i 21 [ Slide.) i 22 MR. EDWARDS: What don't we need? We don't need l l 23 some artificial distinctions that prevent us from thinking i l 24 in terms of a continuation. Let me ask you. Suppose we had [ i 25 ten years, that little statement on Slide 2, 40, suppose it e ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

92 ~ I was ten. Then would you have age-related degradation unique l 2 to license renewal for period two or would you have j i 3 important to license renewal in period four? i 4 Let's just think about this a minute. This j 5 doesn't have to be such a complicated thing. We don't have Let's 6 to go through all this paper shuffling for a process. have the application focus on the important things; long-7 e lived passive equipment, is it monitored correctly or is an 9 analysis incorrect; are there time dependencies that we need 10 to deal with and are there things we need to modify. j f 11 [ Slide.] 12 MR. EDWARDS: So what are the actions? Let's 13 treat renewals as renewals. That's a tremendous I 14 psychological step, but I think it's an important one and we i 15 ought to try to think about this in this context. Accept l l 16 the licensing basis and the regulatory oversight as the t hasis for reasonable assurance and revise the statement of 17 18 considerations so you can get that sense out of it instead 19 of any sense you want, and modify the rule to reflect the i l 20 existence of the maintenance rule and these principles. l 21 It doesn't have to take a long time. We've got at - 22 least eight years experience trying to put together a 23 process. We've got a number of people that have come up 24 with attempts at it. We've got 20 years of aging research. 25 This is not a new adventure. Here's probably one of the ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 ~,,

i 1 1 i 93 t 1 best researched basis to go around and change a rule that j i i 2 we've ever had. i That's pretty _much the end of Andy's presentation. l 3 4 I have one other thing, though. There was a question about 5 replacement practices and I didn't really deal with that in J 6 the context of the presentation. I'd just like to address i 7 that as an example of why this whole thing is wrong. It's t B off track. 9 We're talking about license renewal and you want i ~ 10 to talk about replacement practices. Replacement practices ~ are maintenance and we're doing maintenance and we have to l 11 i 12 - because now, soon, people are implementing it now, but soon j 13 there's going to be a rule that says you have to and you have to get performance and you have to meet your goals. l 14 I 15 That's not an issue for license renewal, I don't i 16 think, Andy doesn't think. That's kind of indicative of l J 17 where we've gotten tangled up and we don't need to be. 18 That's it. Thank you very much. l 19 [ Applause.) l t j 20 MR. EDWARDS: I understand I have to take i 21 questions, too. Like I say, I'll do the best I can or I'll ~ i 22 have him write you. 23 MR. TAYLOR: I'm Jim Taylor from B&W Nuclear 1 4 24 Technologies. Don Edwards knows that over the last 25 there have been many issues that we have agreed on 25

years, ANN RILEY & ASSOCIATES, LTD.

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l 94 1 and many issues I've disagreed with you on, Don, but it's 2 always been in a fair way. l 3 I just want you to know that -- I want you to 4 carry a message back to Andy Kadak that I agree, and I l t suspect you had some input to Andy's talk, 100 percent with 5 6 what you said. I think the part that I agree with most 7 strongly is the part about advocating the elimination of the definition and the phrase age-related degradation unique to 8 i 9 license renewal. I I think that the points you make are very good and 10 i 11 I think if we perpetuate that, we're going to get into the kind of problems that were mentioned earlier. I believe j 12 13 that we ought to get rid of that. I think it was a flaky 14 concept in the beginning and it's going to continue to cause l l 15 us trouble. i 16 We ought to admit that it was flaky and just { 17 banish it from our vocabulary as far as license renewal is 18 concerned. 19 So I just wanted you to know that on this one i 20 occasion, I agree with both you and Andy. 21 [Applau se. ] 22 MR. EDWARDS: If I could add just a thing. You 23 know, license renewal rule is going to be around for a long 24 time and what we want to think about is the plants ten, 15, 20 years from now using a process that we tried to put 25 I AJW RILEY & ASSOCIATES, LTD. Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 =

i ~ 95 together for some in-the-next-couple-of-months kinds of 1 a ? 2 considerations. I think we need to be careful. l b 3 MR. TRAVERS: Thanks, Don. What we would like to l i 4 do now is break for lunch. Again, I'd like just to make one l 5 announcement. That is if anyone has yet to express an i 6 interest in addressing this group, please do it and we'll 7 make some' arrangements to provide some time, whatever it is, 8 five, ten, whatever it is. One o' clock we'll begin again. 9 Thank you. 10 [Whereupon, at 11:42 a.m., the workshop was i i ~ 11 recessed, to reconvene this same day at 1:00 p.m.] t 12 13 l 14 15 ) 16 l 17 18 1 19 l 20 21 I 22 23 24 4 25 i l l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 (202) 293-3950 ...-.a

96 f, 1 AFTERNOON SESSION 2 [1:08 p.m.] 3 MR. TRAVERS: Let's go ahead and get started. 4 This afternoon, having heard of no additional requests from 5 other parties who may be interested in our license renewal 6 workshop, we're going to kick off this afternoon session 7 with a presentation by Scott Newberry, who is the Project B Director, the License Renewal Project Director in the Office 9 of Nuclear Reactor Regulation. i 10 Scott is going to be briefly characterizing a 11 number of alternative approaches that were listed in the 12 - Federal Register notice for this meeting. These are 13 approaches that the staff identified in trying to put 14 together something that could serve as the template for some 15 of the discussions that have already taken place and for 16 which we may have some additional discussions after Scott 17 gets through with his presentation. 18 MR. NEWBERRY: Thank you, Bill. I'm glad to see 19 so many people decided to come back after lunch to continue 20 cur discussion on license renewal. 21 As Bill said, the purpose of my presentation is to 22 briefly describe a range of alte 2atives for taking 23 advantage of existing licensee programs and the maintenance 24 rule in the license renewal process. 25 These alternatives were outlined in some detail in ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

I 97 1 our Federal Register notice of August 12, but my intent here i t e 2 today is to use this range of alternatives.to facilitate any l r 3 additional discussion we might have here this afternoon in l 4 the time remaining and also gather input from you as you l 5 think about what you heard today and perhaps provide i 6 scmething in writing to us in the next couple weeks. 4 7 Of course, the staff will be considering these f f 5 6 alternatives, along with input we receive from the workshop. 9 I should emphasize we have not chosen a specific alternative l l l 10 or developed specific recommendations at this time. 11 [ Slide.] 12 MR. NEWBERRY: Dr. Murley and Dr. Travers have l [ 13 already described the staff proposals in our SECY papers 14 from last spring SECY-049 and 113, and I'm not going to 15 dwell on those approaches at all in my remarks here. l 16 I plan on outlining four other possibilities for j 17 increased reliance on existing activities, including 18 programs implemented to meet the maintenance rule. I'll go 19 through them quite briefly, emphasizing their key elements, \\ l 20 and then offer what I would think that the IPA steps would i i 21 look like, what the results would look like using the \\ 22 diagrams that appear in SECY 93-049. I i 23 After hearing the previous oiscussion and j 24 questions this morning, I think you will be able to see some i 25 similarities to the approaches identified or perhaps some ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i -..y. r v...

I I 98 1 combinations of things discussed already today. 2 Each approach would likely result in a need to j 3 change the rule, especially the definition of ARDUTLR, to 4 further credit existing programs. On this slide, I'm going j 5 to focus on former Commissioner Curtiss' approach that would i 6 give additional credit to replacement and refurbishment { i 7 programs and, of course, would require rulemaking, as I've I 8 stated. 9 Second, I will go through an approach that would 10 require significant revision to the definition of ARDUTLR to 11 further tredit existing programs. Third, an approach that 12 .would rely to a great extent on the current regulatory i 13 process, particularly the maintenance rule. This approach 14 would require substantive rulemaking. 15 Lastly, an approach we haven't really talked at r 16 all about today is an approach proposed by the Deputy EDO, 17 Jim Sniezek, that is intended to simplify the rule. He i t 18 deletes the definition of ARDUTLR all together and would l 19 make the scope of the license renewal rule identical to the 20 scope of the maintenance rule, and he would also revise 21 particular application reporting aspects of the rule. Of 22 course, that approach would require rulemaking, as well. 23 [ Slide.] 24 MR. NEWBERRY: Option 2, the approach suggested by l 25 Commissioner Curtiss. In his vote sheet on COMSECY 93-029, l l v f a ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 w r

. ~.. 99 1 Commissioner Curtiss proposed an approach for taking 2 advantage of existing programs in license renewal. The r 3 approach, in general endorses virtually all the staff proposals contained in the SECY papers 049 and 113, but 4 5 would result in rulemaking to ensure that the language in 6 the rule and the statement of considerations is entirely 7 consistent. i 8 The approach includes specific language changes to l 9 the rule to actually codify each of the staff proposals in -l t 10 the SECY papers. To give greater credit to existing 11 programs, the proposal would recognize that replacement and i 12 - refurbishment of some structures and components could serve 13 as a basis for concluding that such structures and 4 i 14 ccmponents would not be subject to ARDUTLR. 15 [ Slide 3 16 MR. NEWBERRY: This slide shows the definition l 17 suggested by Commissioner Curtiss. The first three parts of i i 18 the existing definition would be maintained, but the t proposal would also explicitly in the definition permit 19 20 existing programs that involve like-kind replacement before 21 40 years or existing programs that involve replacement or l 22 refurbishment based on established time or performance s 23 criteria to be the basis for determining that the structures 24 or components would not be subject to ARDUTLR. 25 Included, however, is the assumption that the SSC f IJUJ RILEY & ASSOCIATES, LTD. ) Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 4 -7 g n --q--

100 could have ARDUTLR as proposed by the staff in SECY-049. In I 4 2 fact, a new paragraph would explicitly be added to the rule 3 to say so. 4 [ Slide.) 5 MR. NEWBERRY: You've seen this illustration t i 6 before. Here, I'm indicating an expectation that more SSCs i would be dispositioned as not unique because they are in a j 7 i program with specific time or performance criteria that B 9 would require, if exceeded, replacement or refurbishment. l 10 You see an increased percentage that is-judged to increase l 11 to perhaps 30 percent. I Commissioner Curtiss discusses in his vote sheet 12 13 that for many short-lived components, current activities j ^ would continue to be adequate through the extended period. 14 other short-Perhaps components like instrumentation relays, 15 l lived components are examples of what would be screened out 16 } 17 at this step. i 18 [ Slide.] 19 MR. NEWBERRY: Option 3, a rule revision to ) That's what we call it l 20 replace the definition of ARDUTLR. l 21 in the Federal Register notice. This approach builds on the l previous approach, with the existing license renewal } 22 t 23 remaining largely intact. The significant difference 24 between this approach and the one I just discussed would be 25 the increased emphasis and more credit for existing licensee } } ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 } (202) 293-3950

101 1 programs, including the maintenance rule, as a basis for 2 determining that structures and components are not subject 3 to ARDUTLR. These programs would need to specify corrective j 4 5 action, including replacement, based on monitoring performance or condition of the structure or component. 6 l 7 Such programs could, if continued into the renewal. period, serve as the basis for concluding that the effects of age-e 9 related degradation are being managed. The conclusion would be supported by an evaluation 10 l 11 performed by the license renewal applicant. t 12- [ Slide.] i 13 MR. NEWBERRY: The most important revision to the rule would be to replace the existing definition, again, of 14 1 15 ARDUTLR. This slide offers one approach to specify that structures or components would not be considered subject to 1 16 i 17 ARDUTLR if they are included in existing documented programs 18 that either specify replacement intervals or monitor 19 performance or conditions such that the corrective action e i i i will be taken to maintain the CLB during the renewal term. 20 f 4 21 [ Slide.] 22 MR. NEWBERRY: Again, using the same illustration, 23 you can see that a significant result could be that many f more SCs would be dispositioned as not unique because i 24 1 25 they're included in existing programs that specify I IJRJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 j e e - -- e

102 i 1 performance or' condition, that provide for a demonstration l 2 that the CLB would be maintained through the renewal term. 3 Compared to the previous approach, this proposal 4 would go beyond replacement and refurbishment programs and l 5 crediting existing programs. Perhaps plant equipment such 6 as reactor protection systems, emergency diesel generators, 7 other active systems and components would be examples that i 8 would be screened out in this approach. + 9 [ Slide.] 10 MR. NEWBERRY: Option 4, reliance on the t 11 maintenance rule in current regulatory process is the name 12 - of this approach. This approach represents a more l 4 13 significant change than the previous approaches that I've 14 discussed. 15 Fundamentally, quite a change. The approach would 16 rely primarily on the current regulatory process to assure 17 that an adequate level of safety, including the management 1 18 of effects of age-related degradation during the current 19 license term, and relies on the current regulatory process l 20 to continue to provide an adequate level of safety ~ i 21 throughout the renewal period. a 22 Existing licensee programs in the regulatory 23 process which include NRC inspection programs, consideration i 24 of operating experience, identification of new generic 25 issues, agency research programs, and now, of course, the i TJE RILEY & ASSOCIATES, LTD. j Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 4' (202) 293-3950 l

i 103 i 1 ' enhancement of the process by adding the requirements of the 2 maintenance rule, would assure that the performance or 3 condition of important structures and components would not 4 degrade below an acceptable level of safety at any time 5 during plant operation, including the renewal term. j b 6 Existing programs would, therefore, under this 7 approach, not be examined in the license renewal process. 8 The license renewal process would focus on time-limited 9 analyses and issues cnly. Time-limited analyses would be { 10 those analyses which were specifically evaluated for the 40-i 11 year license term and incorporated into the licensing basis 'or used as a basis for any current licensing basis safety 12 i 13 determination by the NRC. 14 These time-limited analyses would be the focus of 15 the license renewal review and would be specifically l 16 evaluated for the renewal term. f 17 [ Slide.] 18 MR. NEWBERRY: One way to implement an approach 19 like this would be to modify the ARDUTLR definition to 20 reflect a need to consider only those pertinent time-limited 21 analyses. Although not shown here, perhaps another approach - r 22 could be for the term ARDUTLR to be eliminated all together i 23 and substituting something else in the rule representing the 24 approach. I 25 Aging concerns, as they arise, but not f i l Adai RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l 104 I specifically associated with the 40-year analysis or l 2 envelope, would then be considered in the current regulatory 3 process generically. l 4 [ Slide.] I 5 MR. NEWBERRY: Using the same ipa illustration, i I 6 you can see how the process is greatly simplified for this 7 approach. You can also see that in this example I have not l 8 included a separate screening step for ITLR screening since ) i 9 the scope is simply-the time-limited issues. i 10 Considerably more SSCs would be screened out l 11 because they do not have time-dependent elements, thus i 12 giving maximum credit for existing programs. 13 [ Slide.) 14 MR. NEWBERRY: This is the approach suggested by 1 15 Jim Sniezek, the Deputy EDO, in response to particular 16 implementation questions and problems that he had observed 17 pertaining to Part 54. The approach uses the same rule f 18 structure, but would make several important changes to i 19 clarify and simplify the rule. 20 The concept of ARDUTLR would be deleted all 1 21 together and the scope of the license renewal and i 22 maintenance rules made to be the same. Deletion of ARDUTLR 22 definition is intended, according to this approach, to J 24 remove one of the most difficult aspects, as we've discussed 25 today, of the current rule, to implement it in practice. J IJUI RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 j (202) 293-3950

105 1 The definition of an effective program would also 2 be clarified and the contents of the application redefined 3 for describing elements and programs in place at the plant. 4 The program descriptions would focus primarily on 5 maintaining the function of all structures and components 6 imporr. ant to license renewal as set forth in the CLB. 7 Also described in this approach is an aspect that 8 would rely on 10 CFR 50.59 for controlling changes to 9 programs rather than the controls now in Part 54. 10 [ Slide.] ~ 11 MR. NEWBERRY: Again, I show how the IPA is effected. In this case, there is no uniqueness review at 12 13 all. After the scope review, which is now identical to the i 14 maintenance rule scope, the effective program review is 15 performed for all ITLR structures and components. 16 So you do end up with a much higher percentage of 17 structures and components down in the effective program i 18 review, but this approach would, I would say, streamline and j 19 change the level of detail of that part of the review. 20 In summary, I've tried to present this range of 21 alternatives, as described in the Federal Register notice, 22 that could be proposed for modifying Part 54 to give credit l 23 to -- greater credit to existing programs, including those j I 24 implemented to meet the maintenance rule. I 25 I'm sure there are others. We've tried to present l i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

l ) 106 j the range and there could even be combinations of these 1 2 approaches. All do require rulemaking and, of course, there 3 would be opportunity for comment on the particular rule j i 4 proposed. We've discussed how long rulemaking would take. j 5 6 It would certainly take longer than a few months, as 7 suggested earlier. Really the intent of this presentation 8 is to generate additional discussion, if you have any, 9 additional questions. I can take them at this time or 10 perhaps we could wait for a panel later in the agenda. l 11 That concludes my presentation. [ Applause.] 12 i 13 MR. TRAVERS: Unless there is someone who would 14 like to make a comment at this point, what I would propose l 15 to do is take five minutes and we're going to bring up a ) panel of some of the previous presenters and have additional l 16 I 17 discussion, as appropriate. So five minutes. i 18 [ Recess.) l i 19 MR. TRAVERS: I think we've had an informative t i 20 session this morning and this afternoon and we've got an l 21 opportunity for some additional discussion, both by a number -t s 22 of the industry presenters, as well as Dr. Murley, Bill i i 23 Russell and myself. 24 In a moment, we'd like to open it up once again 4 25 for some questions, comments and discussion. Let me turn r i I ANN RILEY & ASSOCIATES, LTD. i Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

~. I j 107 i - 1 first, if I may, to Dr. Murley, who is going to give us a-j sense of where he sees us going now that we have, for the 2 traveled through this workshop and discussed some j 3 most part, l of the fundamental ideas that we need to decide on how to 4 .l 5 further approach license renewal. f 6 MR. MURLEY: Perhaps if I describe a little bit l 7 about the process of where we go from here, it might clarify I B some things and stimulate some questions. We're committed q 9 to ga back to the Commission with what I've called a i recommendation on how we proceed, but that's going to be a 10 i 11 two-part recommendation. I One is a recommendation on do we change the rule 12 13 and then the second part is if so, what form should the rule 14 take, the change in the rule. I sense a consensus here that j 15 a rule change is needed. I think, as I said, if that is l 3 16 indeed the consensus from all the material that we get, then i 17 I intend to go back to the Commission with that j i l 18 recommendation. So that seems to be where we're heading. l I have also told my boss that there is no way we 19 20 can have a complete rule package, rule change package by the i 21 end of November. So they're not expecting a complete I j i 22 package. i We've tentatively scheduled a meeting with the 23 i 24 Commission to discuss this on December 12, which, backing ] 1 means we have to have our recommendations to the j 25 up, ) 4 I I i ANN RILEY & ASSOCIATES, LTD. Court Reporters j i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950

1 1 1 108 i 1 Commission by the end of November. 2 I think we can do that. We need to get the 3 comments from-interested parties as soon as we can, but I i 4 think the order of priority would be, first of all, is a 5 rule change needed, and, second, what is the form, if not 6 the exact words that the rule change you would propose, what i 7 should it say. B Then third is there's a great deal of supporting i 9 information and justification that has to be done for any 10 rule change. The more drastic the change in direction, it i seems to me the more material that's going to be needed, 11 12 - because we have to go back and modify not only the statement 13 of considerations, but all the background material that the l l staff worked up in support of the statement of 14 15 considerations. 16 It may not have to be changed, but it has to be j 17 taken into account, We have to explain to the public why i ) 18 we're making this change in tne rule. 19 I would expect then that we would get some 20 guidance from the Commission by the end of December, in 21 which case we would undertake -- we wouldn't wait for that. ~ 22 We'd sense how things would be going, but we would, with j 23 that guidance then, prepare a rule documentation and a Commission paper that would include the regulatory analysis, ) 24 25 the resolution of comments from this meeting, any i ANN RILEY & ASSOCIATES, LTD. j Court Reporters 1612 K Street, N.W., Suite 300 l l Washington, D.C. 20006 (202) 293-3950 i ~

109 environmental assessment that's needed, as well as modified 1 2 statement of considerations and the precise rule change 3 language. 4 That could take a minimum of three months up to 5 six months. If it's a relatively -- if we don't change the 6 fundamental concepts that we've been talking about namely, management of aging -- then it's probably closer to 7 6 three months, although I hate to make all these commitments. 9 But that gets us into March, let's say, of 1994 when we would then go to the Commission again with proposed 10 11 final rule language and all the justifications. Then we would enter - once they agreed to that, then we would enter 22 13 the rulemaking process, where we'd have to publish for 14 comments, evaluate those comments, and then go back with the 15 final rule. 16 In addition, we have our own internal procedures 17 where we have to go to the Advisory Committee on Reactor Safeguards and the Committee to Review Generic Requirements. 18 19 That, in a nutshell, is the process that I see that we'll be 20 taking. In the near term, as I said, what we need is your q 21 comments on the direction and any precise language that you ~ 22 have for the rule change. 23 Why don't we take comments for either Bill Rasin 24 and the industry folks or NRC? Questions, comments, 25 anything? ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

~_ i 110 1 (No response.] 2 MR. MURLEY: It can't have been that clear. I 3 should mention that if you've got questions of DOE, I'm sure i j 4 Sterling would be glad to address those, as well. 5 MR. GURICAN: Good afternoon. My name is Greg 'l 6 Gurican from GPU Nuclear. I'd just like to voice two l 1 concerns regarding Scott Newberry's presentation just now 7 8 before the panel stepped up. That is with regard to options j 9 four and five. 10 My first concern with option four is the possible f consideration of calling age-related degradation unique to 11 12 . license renewal equal to or defined as degradation or, in l l 13 other words, in the inspector's manual, when one has to i j 14 consider degraded conditions, this brings into play the l l 15 whole consideration of whether or not one then has to do an l 1 16 operability determination, possibly a reportability l i 1 17 determination, possibly a justification for continued 18 cperation. 19 So every time that you call age-related degradation unique to license renewal degradation by itself, 20 do you have a new degraded condition that has to be then 21 22 addressed in accordance with the guidance given to the 23 inspectors, I guess, in Regulatory Guide 90.218. That's l 24 condition one or concern one. Concern number two is with option number five. 25 1 i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 j washington, D.C. 20006 i i (202) 293-3950 4

=. 111 ) 1 With respect to option number five, the concern there is do you change the rule and eliminate other conditions, as well, 2 3 or not. 4 MR. MURLEY: I'll ask Scott to address the last t 5 question, but with regard to your first point, I think we 6 accept it. It's a good point. We have to be very careful of the language that we use in this rule because we've got 7 8 this whole other underlying set of regulations and history 9 where words have special meaning. 10 So let us just assume that we'll take that comment ~ ~ 11 to heart. Second question, Scott. a 12 MR. GURICAN: One more followup on that second 13 comment, on the concern, second concern. The question of application'of 50.59 to changes in programs is my major i 14 15 concern with option five and that's with respect to i 16 expanding the safety review process, if you will, rather 17 than handling changes to programs that are put into effect i to handle the license renewal period or maintenance program 18 19 changes or any other programmatic changer that couldn't be 4 s 20 better handled under 50.54 rather than 50.59. t 21 MR. NEWBERRY: Your question has to do with the recommendation to use 50.59 to oversee effective programs in 22 23 Part 54 rather than 54.33, the controls in 54. The proposal i 24 that Mr. Sniezek was making was meant to, I think, simplify 25 the rule and your life, as well, to use a process that's IJUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 washington, D.C. 20006 (202) 293-3950

112 understood and ia place right now to cover programs that 1 would arise in license renewal _ather than generate a new 2 the control program that you would have to implement at 3 to do effectiveness reviews for all of the additional 4 plant 5 programs under license renewal. I guess maybe I don't 6 So to the extent that to 50.59 being appreciate the concern you have with respect 7 onerous in the context of option five. The objective there 8 was to actually simplify and make your life easier. Maybe l 9 on that. l 10 somebody else would like to comment 11 MR. RUSSELL: The fundamental issue in option five f i is to not have material submitted as a part of the FSAR f 12 which would then have to be updated through a formal change 13 including on-site committee reviews, etcetera, as l 14

process, 15 is currently described, but, instead, as is the case under the maintenance rule, you can make changes to those programs 16 17 provided the result is still acceptable.

18 So the concept was to get it closer to the maintenance rule where the information, data, etcetera are 19 maintained on-site where we would be evaluating the 20 21 performance of the structure, system or component and look ~ r at the performance histories, which would give you 22 flexibility to make changes to those programs through a 23 24 process that is conducted essentially subject to inspection rather than having something submitted specifically 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 113 i i 1 informing us of what the changes were and having to make 4 i 2 determinations that-they are still effective, without having 3 had the benefit of operating experience under them. 4 Sc the two were really an attempt to try and j reduce some of the administrative burden associated with 5 6 effective program as it was currently described. 7 MR. TRAVERS: Are there any other questions that i t i 8 you'd like to ask at this time? 9 MR. HALE: My name is Steve Hale from Florida l 10 Power & Light. I'd be interested to hear a little bit about 11 -- and we seem to have reached consensus that, yes, the rule 12 - ' change is a good idea, but how do we get to the second part j I 1 13 of Dr. Murley's list of three things, which is the form that 1 4 14 it's going to take? How does the industry and the j 15 regulators get to that point? 16 MR. TRAVERS: We're hoping to get some additional 5 i information other than what we've gotten today, and what N~ 17 we've gotten today has obviously been informative and can be 18 1 19 considered useful. But we're hopeful and I think Bill Rasin 1 20 has indicated that NUMARC plans to provide us some 21 additional information, including perhaps language of i rulemaking and ultimately the construct of some of the i 22 a 23 arguments that would have to take place in the statement of considerations to justify a new approach, a different rule, 24 25 ene that, while some might consider minor, others might a IJUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950 j

[ l i L 114 l t 3 1 consider substantive. i So we will need and are expecting to see some more 2 3 specific proposals from the industry. Bill, you might want 4 to comment on that. i 5 MR. RASIN: That's correct. Typically, in this [ 6 type of process., these workshops are very good for an l l 7 exchange of views, a gathering of views from the public and j also for people to see the ideas and the dialogue going on. l l 8 i the real useful meaningful input has got to be 9 But We do intend to make 10 in written form with precise language. 1 a submittal and followup to this workshop with a more 11 3 12 - ' detailed written description of the approach that we are 13 working cn1 right now, along with the wording that would be i required to facilitate that approach in accordance with the i 14 i 15 rule. I 16 Then, beyond that, we'll make more detailed l l l submittals as we have information available and think that l 17 it may perhaps be helpful to the staff in their process. 18 19 MR. TRAVERS: I should point out that while we j understand that kind of information is going to be j 20 21 submitted, ultimately, the staff has been directed to ( 1 of whatever we get from whatever 22 provide its best assessment including other public organizations, other industry 23

source, 24 thinking on this subject.

We ultimately have to provide a set of 25 Idm RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Euite 300 Washington, D.C. 20006 (202) 293-3950

I 115 l l 1 recommendations that will, in all likelihood, as Dr. Murley j I 2 indicated, not initially at least include a full rulemaking 3 package, but which would be expected to provide the j 4 construct of an amended rule. i 5 MR. RASIN: I'd like to add one other thing to i 6 that that's, I think, kind of important to the expeditious. r 7 process that we would like to see go forward. It's one of 8 the reasons that we tried to develop a unified package for I 9 the industry and submit it, because if, in fact, the staff l 10 had to contend with 46 separate utility proposals, all with 11 their ideas and subtle nuances, we'd probably be five years 12 'until they sorted through and answered all the questions and 13 did everything they had to do for the Commission. 14 So we do intend to make a submittal on behalf of 15 the industry with support of the industry. 16 MR. TRAVERS: I think your question does point out 17 that we have a big challenge ahead of us, though. It's 18 probably obvious to most people that what we have done, and 19 I think Terry Pickens' demonstration of how industry 20 reviewed some of the assessments that we provided and how 21 the technical resolutions could be reached, they were very 22 similar. 23 And now the challenge before us is to construct a 24 rule, justify it in the language of rulemaking, that 25 supports a reasonable process for carrying that out. That's i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 -.,,- _. -.-.. ~.--

i 116 1 not an insignificant task and we've been faced with it to an l 2 extent before and we.have identified it as a very difficult 3 thing to do. It's going to take some time. i 4 Anyone else? i r 5 MR. MIZUNO: This is Gary Mizuno. I guess I had a 6 question for not only NUMARC, but also the Department of 7 Energy and Yankee Atomic, just so that the staff and OGC B understands what's going to be coming in. i 9 As I listened to the approaches, I believe that 10 the Yankee Atomic description of what they would like to see t happen in license renewal is significantly different from 11 12 the NUMARC approach, certainly from a rulemaking standpoint 13 and the substantive arguments that need'to be made. 14 I guess from Yankee Atomic, I'd like to know whether they intend to submit a separate package with their 15 proposed rule changes and substantive arguments in favor of 16 ) 17 that, which would be separate from any NUMARC submission. 18 Then with respect to the Department of Energy, I l guess I would like to know whether -- nithough their 19 i 20 approach seemed to be much closer, from my standpoint or ~ 21 from my observation, to the NUMARC approach,.their 22 description of their process suggested that they are in the ) 23 process of developing a separate package. I guess I would like to know whether there is l 24 25 going to be, in fact, a separate package. Then as a general i r i ANN RILEY & ASSOCIATES, LTD. l Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 e a ~

-117 1 observation to all three industry groups, I think that the 2 most important thing in this exercise is not simply to 3 decide where you want to be at the end of the license 4 renewal rulemaking process and if you want to have a new 5 rule. 6 It's not simply sufficient to know what that rule 7 language is going to be, although that's obviously very 8 important. I think the most difficult task for the agency 9 is to develop the rationale from a legal and policy and 10 technical standpoint that underlies that. We can have great platitudes about how certain 11 things are acceptable and are sufficient to address certain 12 problems and why certain administrative burdens need not be 13 14 undertaken by both the licensee, as well as the NRC, but 15 unless there is a basis for making these kinds of 16 conclusions, such a rulemaking is not going to, at least in 17 my mind, meet legal muster and either in a direct challenge 18 to the rule at the time that the rule is promulgated or, 19 even worse from the industry standpoint in terms of 20 certainty, at the time that a renewal application is submitted, because there could very well be challenges that 21 22 will be raised in the context of an individual renewal 23 application. 24 So I think it's very important that the rationales 25 be submitted as soon as possible so that the staff and OGC ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i i 118 1 can evaluate them and provide some sort of analysis to the f Commission as-to the likelihood of prevailing in any kind of 2 3 challenge. i 4 MR. FRANKS: I'm Sterling Franks with the 5. Department of Energy. To respond to you, I think, as I 6 mentioned, it was our intent to finalize a draft of our 7 comments and provide those to you. I think it does address 8 some of your concerns about jur,1fications, both from a i 9 legal and a technical standpoint. j 10 MR. EDWARDS: We intend to provide an entire t 4 i 11 package. f 4 12 MR. TRAVERS: Does anyone else have a question or 13 comment at this point? i 14 MR. RUSSELL: Just one comment, and not because I j 15 always want to go back to technical issues. But I do think 16 whatever we come up with, and I speak both to DOE, Yankee } 17 and NUMARC, I believe it needs to be illustrated with a I-number of examples to indicate how and what bases you would 1 18 be using to disposition issues as either being not unique to l 19 age-related degradation or why they have an effective 20 21 program or, in the Yankee case, why this is a component which requires special review for the purposes of renewal 22 23 and others do not. The discussion at a policy level, what might make 24 25 a good legal argument is one thing, but we also have to ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i 119 l I recognize that this next time around, it's got to be such that implementable from a technical review standpoint, 2 t 3 a framework is in place, i 4 I would submit that while we might not be able to j t do that between now and the middle of October as your 5 6 proposals come in, there is going to have to be a dialogue 7 very shortly thereafter that illustrates each of these concepts or proposed changes with some concrete examples of 8 things which.we can agree clearly are being effectively 9 maintained under current programs today and things which l 10 i would be clearly within the scope of concern for an extended 11 ' period of operation, and so examples which are at the 12 13 margin, which could go either way as to how to discuss these j il 14 issues. 3 i So I think one of the problems that we've had over 15 16 the last year or so is that there has not been a sufficient 17 dialogue as it relates to hard examples of dispositioning 18 these issues and that that really is the task before us. So I would suggest to each of those who are coming j 19 in with proposals that you anticipate supporting those d 20 proposals with some concrete examples in the very near term 21 22 afterwards so that we don't start down a process. We don't rule two to suffer the same fate that we had with rule 23 want one regarding uncertainty and ambiguity in language. ~ 24 The only way I know of to make sure that doesn't 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

~- 1 I i 120 1 happen again is to have a good technical discussion with 2 some examples to address these processes. 3 MR. TRAVERS: Does anyone else have anything for l 4 us? 5 [No response.] i 6 MR. TRAVERS: I think that's it. We have gone through today's workshop and gotten a lot of information, 7 i 8 some discussion. I'd like to thank everybody for coming .I 9 out. It's been very interesting for me and we'll look 10 forward to continuing on in license, renewal. t 11 Thank you very much. j 12 IWhereupon, at 2:02 p.m., the workshop was f 13 concluded.] i 14 1 .i 15 3 16 17 { 18 1 19 20 f 21 l L 22 23 24 25 NRJ RILEY & ASSOCIATES, LTD. I Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

REPORTER'S CERTIFICATE l This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: NAME OF PROCEEDING: License Renewal Workshop i ? DOCKET NUMBER: PLACE OF PROCEEDING: Bethesda, MD i were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. nuTAdKJG official Reporter Ann Riley & Associates, Ltd. 1 l l l i}}

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