ML20209B967
| ML20209B967 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3083, NUDOCS 9907080377 | |
| Download: ML20209B967 (182) | |
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OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
Title:
MEETING: PLANT LICENSE RENEWAL TRO4 (ACRS)
R ET"JRN ORIGINAL ** k TO EJWHITE
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f M'S T-2E2E 415 /130 THANKS!
Docket No.:
f-i Work Order No.:
ASB-300-839
(/j/d LOCATION:
Rockville,MD DATE:
Thursday, July 1,1999 PAGES: 198 - 350 9907080377 990701 3083 PDR O'lU16d ANN RILEY & ASSOCIATES, LTD.
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DISCLAIMER UNITED STATES PUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS JULY 1, 1999 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory I
)
Committee on Reactor Safeguards, taken on July 1, 1999, as
%J reported herein, is a record uf the discussions recorded at the meeting held on the above date.
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
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UNITED STATES OF AMERICA
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2 NUCLEAR REGULATORY COMMISSION 3
ADVISORY COMMITTEE ON. REACTOR SAFEGUARDS 4
5 MEETING:
PLANT LICENSE RENEWAL 6
7 8
9 U.S. Nuclear Regulatory Commission 10 Two White Flint North, Room T2-B3 11 11545 Rockville Pike 12 Rockville, Maryland
'13 14 Thursday, July 1, 1999 15 16 The subcommittee met, pursuant to notice, at 8:30 17 a.m.
18 19 MEMBERS PRESENT:
20 MARIO V. BONACA, Chairman, ACRS 21 ROBERT L.
SEALE, Member, ACRS 22 THOMAS S.
KRESS, Member, ACRS 23 WILLIAM L.
SHACK, Member, ACRS 24 ROBERT E.
UHRIG, Member, ACRS 25 ANN RILEY & ASSOCIATES, LTD.
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PROCEEDINGS f) 2 (8:30 a.m.]
V 3
CHAIRMAN BONACA:
Good morning.
4 The meeting will now come to order.
This is the 5
second day of a meeting of the ACRS Subcommittee on Plant 6
I am Mario Bonaca, Chairman of the 7
Subcommittee.
i 8
ACRS Members in attendance are:
Drs. Thomas 9
Kress, Robert Seals, William Shack, and Robert Uhrig.
10 The purpose of this meeting is for the 11 Subcommittee to review the NRC staff's safety evaluation 12 report related to the Oconee license renewal application, 13 crediting of existing programs, and related matters.
The 14 Subcommittee will gather information, analyze relevant
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15 issues and facts, and formulate proposed positions and 16 actions, as appropriate, for deliberation by the full 17 Committee.
Mr. Noel Dudley is the Cognizant ACRS Staff 18 Engineer for this meeting.
19 The rules for participation in today's meeting 20 have been announced as part of the notice of this meeting 21 previously published in the Federal Register on June 1, 22 1999.
23 A transcript of this meeting is being kept, and 24 will be made available as stated in the Federal Register 25 notice.
It is requested that speakers first identify
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'l themselves and speak with sufficient clarity and volume so 2
tha't they'can be readily heard.
3 We have received no written comments or requests 4
for time to make oral statements from members of the public.
5 We will now proceed with the meeting, and I call 6L upon Mr. Christopher Grimes, Chief of the License Renewal J
7 and Standardization Branch, to begin.
8 Mr. Grimes, i
~9 MR. GRIMES:
Thank you, Mr. Bonaca.
10.
Before the staff resumes its presentation of the 11-Oconee safety evaluation report, as a scheduling matter I'd 12 like to request because of a number of other schedule
)
13 demands and interests in the topic related to SECY-99-148 on 14 credit for existing programs that since we're about an hour
()
15 and a half ahead of schedule, in accordance with the agenda, 16-that we still maintain the one o' clock time to discuss that 17 particular topic so that interested staff members and 18 participants will be available.
If that's acceptable to the i
19 subcommittee, that will give you more time to discuss the 20 results of the Oconee review and the plans for the full 21 Committee meeting, or an extended lunch, whichever you 22 prefer.
23 CHAIRMAN BONACA:
You would propose that we stay 24 with that discussion.
25 MR. GRIMES:
With the afternoon part of the ON_.
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agenda, starting at one.
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2 CHAIRMAN BONACA:
Sure.
Yes, and that's the plan, J
3 yes.
4 MR. GRIMES:
Okay.
5 CHAIRMAN BONACA:
We'll do that.
6 MR. GRIMES:
Thank you.
Then we'll proceed with 7
the staff's presentation of SER Section 3.5 on engineered 8
safety features with a panel led by Stephanie Coffin.
9 MR. COFFIN:
I got my slide on right the first 10 time.
11
[ Laughter.]
.12 My name is Stephanie Coffin, and I am from 13 Materials and Chemical Engineering Branch in the Division of 14-Engineering.
I'll be presenting today highlights from two
()
15 sections from our draft SER, the 3.5, which is the 16 engineered safety features system, and 3.6, which is 17 auxiliary systems.
And following the presentations from 18 yesterday we'll be hitting on four topics -- open items, 19 confirmatory items, license renewal issues, and items of 20 interest.
21 For the engineered safety features systems, I'll 22 skip right to the confirmatory items, and this has to do 23 with the reactor building spray system inspection, which is 24 a one-time inspection of stainless steel components in the i
25 reactor building spray system to evaluate the aging effects,
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if any, of stainless steel exposed to an alternate wetting
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2 and drying environment and exposed to borated water.
And 3
the applicant is also crediting this same inspection for the 4
nitrogen purge and blanketing system So the open item or 5
the confirmatory item has to do with the basis for saying
)
i 6
the one-time inspection of the reactor building spray system 7
is applicable to the nitrogen purge and blanketing system.
8 And we discussed this on the phone. and it's actually 9
written up -- the basis is written up in the draft SER, and 10 the staff's requesting formal documentation of this.
11 DR 2 HALE:
It was written up, but that particular 12 explanation was not in the original submittal to the staff.
13 Is that --
14 MS. COFFIN:
That's right.
And we have it
()
15 documented also in a meeting summary.
16
.DR.
SEALE:
Um-hum.
17 MS. COFFIN:
But for this particular item we 18 wanted a formal under oath and affirmation documentation.
19 DR. SEALE:
Certainly.
Certainly.
20 MS. COFFIN:
License renewal issues, none in this 21 section to discuss, and for items of interest I brought up 22 the one-time inspection, and I took this opportunity to l
23 bring this up because one-time inspections have received a 24 lot of discussion at the staff level, and there was some 25 discussion at the ACRS level, too, for the BG&E application,
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and these one-time inspections are a little bit -- are a
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2 different animal, because they're not really programs.
v 3
They're not aging management programs.
They're more to 4
determine if an aging-management program is needed.
So the 5
evaluation of these -- the way the staff approached these 6
was a little bit different, and I just want to point out 7
that we've seen it now in both BG&E's and in Duke's 8
application, so I expect to see more of these types of 9
inspections in future applications.
10 DR. SHACK:
Will this be a visual inspection, 11 volumetric?
12 MS. COFFIN:
I think it's going to be one or the 13 other.
That answers your question.
If it's accessible, 14 they're going to do a visual probably from the inside,
/~N 15 but --
(j 16 DR. SHACK:
Oh, okay, an inside.
17 MS. COFFIN:
They're probably going to be looking 18 at welds, so they'll probably be doing a UT from the outside 19 I would imagine.
But it's their decision to make.
I think 20 in the SER it says volumetric, but --
21 MR. ROBINSON:
Greg Robinson.
It'll be 22 volumetric, and as you say, anything that is accessible 23 internally, we'll do a visual.
24 DR. KRESS:
Did you give much thought to the 25 timing of a one-time inspection as to when that ought to
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take place?
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2 MS. COFFIN:
ha discussed it a little bit in the f
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SER, and there are advantages -- if you do it earlier, 4
sometimes it's nice for the staff, because you have the 5
results.
Like if they had done this inspection before they 6
came in, they would have the results t'o discuss with us.
7 But at the same time, it's nice to put it off as long as 8
possible, because operating experience says that this isn't 9
something that's happening that we're aware of, and the 10 longer you put it off, the more time you give for it to 11 happen.
So that would be the advantage of putting it off.
12 So when we can't come to a decision on when to do it, we 13 just let them decide based more on economics, and they have f
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14 to do the inspection before their renewed license begins.
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15 That's the only --
16 DR. KRESS:
That's the only --
1 17 MS. COFFIN:
That's the only criteria.
Right.
1 18 DR. SEALE:
Could we ask Duke if they have any 19 thoughts on that timing?
s 20 MR, ROBINSON:
Greg Robinson.
Duke.
My thought i
21 was similar to Stephanie's.
We need to be able to 22 characterize any aging that's there, but I don't want to 23 rush out and gather some data.
I would like to do it at an j
24 appropriate time and make sure that we can understand what 25 we're looking at.
I don't feel an urgency to do it in the
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next two years, in other words.
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2 DR. UHRIG:
Suppose there are some consequences of 3
this inspection.
Would the corrective systems or whatever 4
you need to do be in place before the license begins, or 5
would this be on an as-feasible basis?
6 MR. ROBINSON:
As far -- Greg Robinson again.
As 7
far as.the corrective actions, the one-time inspection is 8
set up to determine if the aging occurs, and if it does 9
occur, then it will instigate through our corrective action 10 program additional programmatic actions.
So it's already 11 geared, it will be geared to push toward a program if 12 something formal is needed.
13 MR. GRIMES:
This is Cris Grimes.
I'd want to 14 clarify a couple points.
The first is upon completion of
()
15 this review we'll be issuing a new license, so it's a matter 16 of ue capturing these commitments to perform one-time 17 inspections in the new license before the end of the 40-year 18 term, so it's a question of making sure that we have an 19 enforceable commitment.
But then, as Stephanie mentioned, 20 we'll leave it to the applicant to then exercise its 21 judgment in terms of an appropriate timing for this i
22 inspection, and you should recall that yesterday we pointed 23 out that these commitments to do things for nonsafety 24 systems need to be formalized into some kind of change to 25 the QA plan or a change in the FSAR so that Appendix B will
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apply and all of the attributes of an Appendix B prompt and
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2 effective corrective action to evaluate and act on the G
3 results of any of these inspections would be also 4
enforceable.
5 DR. SRACK:
Just what's the nature of the visual 6
inspection you do internally.
I mean, is it a boroscope 7
down through a thing or a " pig" with a TV camera?
8 MR. ROBINSON:
Greg Robinson again.
There's a 9
check valve in the area that we're looking to do the 10 inspections, and we know that the check valves disassemble 11 periodically, and the hope is that we can disassemble the 12 check valve and then either visually or through some type of 13 boroscope do the inspections that way.
We wanted to leave 14 ourself the option of being able to do it visually or t'%
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15 perha'ps even with a combination of U2, 16 MS. COFFIN:
This is the second part that I'll be 17 presenting on auxiliary systems, 3.6.
And again I'll touch 18 on the four open item confirmatory items, license renewal 19 issues, and items of interest.
20 We have three open items in this section.
The l
21 first one has to do with aging effects, and the lack of 22 identification of vibrational loading as causing aging 23 effects for the HVAC systems.
The second two open items 24 have to do with aging-management programs.
The first one is 25 the basis -- we're questioning the acceptability of the
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scope for the reactor coolant pump motor oil collection
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2-system.
This is a one-time inspection again that is looking 3
for aging effects', if any, due to corrosion in the reactor 4
coolant pump motor oil collection evstem due to water 5
contamination in the oil.
There are a lot of components, a 6
lot-of materials, actually, that the applicant is taking --
7, is using this program for, not just carbon steel, but copper-8 and stainless and maybe a couple other ones.
But they're 9
only looking at one carbon steel tank.
And the staff is 10 questioning the basis for the scope of that inspection, is 11 that adequate for what they're trying to do.
12 DR. SEALE:
Your first bullet can be read two 13 ways.
Identification of vibrational loading is causing 14 aging effects for the HVA systems.
Does that indicate.that
()
15 you'have reason to believe that they're remiss in not 16 questioning the existence of vibrational loadings, or is 17 that a statement that says you don't have any?
18 MS. COFFIN:
I'll let Tom Cheng answer that.
19 MR. CHENG:
My name is Tom Cheng, Engineering 20 Division, NRR.
21 Based on our review of other plant operating 22 experience, some cracking of duct work and also the 23 loosening of fasteners, based on our experience we raised 24 the question.
However, the applicant claims that's because 25 they have sound isolator being installed between some O
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equipment-created vibration loads, such as fans.
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- 2 therefore they thought it's not necessary to include it in
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3
.the scope.
But, however, we did not agree with that, 4
because the isolators, made of rubber or some other kind of 5
soft material, can be degraded because of temperature, t
6-pressure, or relative motions.
So because of the l7 degradation of the insulations and -- isolations, I'm I
8 sorry -- the dynamic load can be transferred to the system.
1 9
So that's the basis where we'cannot agree with the licensee.
10 MS. COFFIN:
The third open item has to do with 11 frequency of oil sampling in the Keowee oil sampling 12 program.
The licensee stated that they'll be taking samples 13
.every six months, and chis is a very simple open item where 14 we're simply asking what the basis is for_that six-month
()
15 frequency.
There's sort of a related question to this is 16 that the applicant said that this program is not going to be 17 formalized or instituted until 2013, which is the end of 18 their operating license, which seems somewhat contradictory 19 to the staff, in that here's a program that is such a need 20 that you need to do a sampling every six months, yet you 21 don't need to start doing it until 2000, which doesn't make 22 sense to the staff.
So we're also questioning the basis for 23 that.
24.
Under confirmatory items we have a question --
25 this is documentation again -- we've'been on the phone with O
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1 209 j
1 them.
We've discussed either open items that we discussed
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2 with them, closed out based on a phone call, but we leave 3
the request for formal documentation in the draft SER.
The i
4 system performance testing is applied to various systems, 5
raw water systems, to detect fouling and loss of material, 6
and they essentially measure system pressure and flow rates.
7 And we're simply asking for documentation of their operating 8
experience.
They've been doing this testing for at least 9
ten years, for some systems since startup, and we're just 10 asking for that to be submitted.
11 Same thing for the Keowee oil sampling program.
12 They have an acceptance criteria.
It's based on EPRI 13 industry standarda, which is acceptable to the staff, and 14 we're simply _aski7g for formal documentation.
t( )
15 CHAIRMAN BONACA:
Could I go back to the second 16 bullet --
17 MS. COFFIN:
Yes.
18 CHAIRMAN BONACA:
On the -- could you tell me 19 again what is the disagreement on the scope of reactor 20 coolant pump motor oil collection?
21 MS. COFFIN:
Okay.
This is a one-time inspection.
22 It's for the reactor coolant pump motor o1.1 collection 23 system.
j 24 CHAIRMAN BONACA:
Yes.
i 25 MS, COFFIN:
And most of the components are
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exposed to oil.
Now the oil can become contaminated with
(
2 water, and you could conceivably get corrosion or even 3
cracking.
I'm not sure how far they went in their aging 4
' effects.
And they state that for carbon steel, stainless 5
steel, I think -- brass, copper, for~all four of these 6-materials they're citing this one-time inspection.
And the 7
.one-time inspection consists of looking at the bottom of one 8
carbon. steel -- at this point one carbon steel motor oil I
9 collection tank.
Is that correct?
That's where the 10 applicant -- and the staff -- it's a very limited scope, and i
I 11 the staff's questioning the basis for that.
j J
12 CHAIRMAN BONACA:
That's a very important system l
13 from a fire --
i 14 MS. COFFIN:
Yes.
Yes, that's why they have it l
15 included in here.
16 DR. KRESS:
What's the source of the water?
17 MS. COFFIN:
Can you' talk to that, Greg?
l 18 MR. ROBINSON:
Greg Robinson, Duke.
It could be j
19 building spray, decon, washing things down, it can flood
]
20 down and then collect in the tank.
21 MR. GRIMES:
This is Cris Grimes.
I'd also like 22 to point out the controversy surrounding the value of these 23 license renewal reviews relative to a proposal to institute 24 a sampling for the Keowee oil system, and whether or not it 25 needs to be instituted now or at'the end of the 40-year 0%
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It, as Stephanie explained it, this clearly 2
illustrates that'there's a question about the discontinuity 3
associated with the adequacy of the existing current
.4 licensing basis relative to decisions to change programs or 5
add programs, and it's going to be difficult to judge, you 6
know, whether or not such a commitment needs to be 7
instituted sooner.
But it's an issue that needs to be q
8 resolved.
I 9
DR. UHRIG:
But, if it were implemented sooner, it l
10 would have to go through the normal procedure for the 11 existing license.
12 MR. GRIMES:
If the applicant chose to insist that 13 they don't -- it's not required today and they're going to
)
14 put it off until, you know, the end of the 40-year term and 15 begin it at year 40, we would have a very difficult time 16 backfitting that requirement on the current licensing basis.
17 So we're in a rather delicate situation.
18-DR. SHACK:
But it's only that oil. sampling system 19 where you have to sample the oil for water in the oil?
I 20 mean, why not all the oil systems?
21 MR. GRIMES:
There are sampling requirements for 22 diesel fuel and, you know, there are current license 23 requirements associated with --
j 24 DR. SHACK:
Oh,.it's Keowee's unique status again, 25 you don't have too many hydro --
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l' '
MR. GRIMES:
Right.
l 2
MR. ROBINSON: 'This is Greg Robinson of Duke.
May 3
I add,,certainly all systems in their hydro stations, 4
particularly hydraulic oil and things, are very important.
5)
You can't operate the stations without good, clean oil.
And 6
certainly;we have a standing program at Keowee.
7 As Cris has spoken, it is somewhat of a 8
nomenclature issue as to whether we declare that program 9
formally a' regulatory license renewal program today,
)
10
. tomorrow, five years from now, or in 2013, and in a lot of 11 cases.there's a consistency in our application at 12 establishing, making sure new programs are established at 13 least by the'end of the first 40-year period.
14-So I think we have to work through the issue of 15 when we declare it a real, live program, but in fact it does 16 exist today, and it's very necessary to have it today, and 17 we owe some more explanation of frequencies and some of the j
18 basis for those things.
But I don't think we're going to j
19 run into'a real snag on that particular item.
20:
DR. KRESS:
Do you have a quick top-of-the-head 4
21 basis for that frequency.
The frequencies are awfully hard 22 to establish a. technical basis for, and they usually come 23-about by experience or how -- either experience or how long 24 you can live with a problem if it occurs.
25 MR. ROBINSON:
Greg Robinson again.
I do know ANN RILEY & ASSOCIATES, LTD.
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we've been running hydro stations since 1904.
(
2 DR. KRESS:
And you've never found a problem?
(,,)
3 MR. ROBINSON:
And the frequency has probably, as 4
you say, played out by experience over time.
I do know we 5
do a full changeout of oil -- at least on our latest hydro 6
station that I'm more familiar with we do a full changeout 7
of oil, purify it, so we have a full reservoir of oil that 8
goes back in while we take the operating oil out and purify 9
it and clean it, because, as I say, it's a very important 10 part of operations.
And it's something we don't take 11 lightly.
12 MR. GRIMES:
This is Cris Grimes.
I want to 13 reinforce what Greg said.
There is nothing magic about 40, 14 but the applicant was very consistent in terms of b
15 identifying commitments to do new things and saying they j
16 would begin before the expiration of the 40-year term.
But 17 what the staff's review has focused on is looking at each of 18 these commitments like the one-time inspections.
On each 19 one we've looked to see whether or not there's a technical 20 logic associated with what to do when it's quite 21 conceivable, and actually I don't think this is going to be 22 a toughy either in terms of, you know, if they don't want to 23 formally institute this as a regulatory program until end of 24 year 40, you know, that's going to be more like a minor 25 policy decision, and we're not really going to make a
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decision like that oni you know, on a technical basis.
But j
}
2 we acknowledge that a number of these practices currently 3
exist and that they're now going to be relied upon as aging 4
management. programs.
5 CHAIRMAN BONACA:
Before we move from this issue I 6
would like to just go back to the issue of threat to coolant 7
pump motor oil ~ collection system.
I'm kind of surprised 8
that -- what this is telling me is that there will be one 9
inspection due to license renewal.
That te.ls me-that if we 10 had no license renewal, there would be no inspections in 11
.that system?
What I mean is that that's a critical system 12 to prevent fire resulting from splashing of oil over very
' 13 hot components.
I mean, that has been the source of events 14 in the past in other plants..The question I have about the
., ~.
l 15 collection system, if we had no license extension, would s
16.
there be inspections planned for that system at all?
17 MS. COFFIN:
I'm not going to speak for Duke, but 18 I would imagine that all these one-time inspections from my 19 read of the application is no, they would not do them unless 20 something came -- operating experience dictated to them that 21 they needed to do this.
These are ones developed 22 specifically for license renewal.
I don't know if you want 23 to add anything to that.
24 MR. ROBINSON:
Greg Robinson again.
I think 25 you're correct..This was an observation we made quite ANN RILEY & ASSOCIATES, LTD.
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frankly as we developed the license renewal materials that
(~')'
2 this was an area that could experience corrosion, and we v
3 needed to go take a look and convince ourselves it was not 4
corroding, but I don't know any other motivation that would 5
have driven us to do this look-see.
i 6
CHAIRMAN BONACA:
Because, I mean, if you have a 1
7 failure there because you don't look at it, you're going to
]
8 have oil splashed, and you're likely to have a fire.
So now 9
you can correct the kind of consequence if you happen to get 10 into that.
But that troubles me.
11 In addition to corrosion, don't you have issues 12 with vibrations in the collection system?
You do?
13 MS. COFFIN:
Staff didn't identify any issues.
14 CHAIRMAN BONACA:
You have mounted components on eN l
( p) 15 top of reactor coolant pumps and stuff like that.
16 MR. ROBINSON:
This is Greg Robinson again.
It's 17 independent of the pump.
It's below the pump.
18 CHAIRMAN BONACA:
Okay..
19 MR. ROBINSON:
As of collection.
20 CHAIRMAN BONACA:
Okay.
Thank you.
21 MS. COFFIN:
You're welcome.
I' 22 No license renewal issues, and I point out just 23 one time again that there are several one-time inspections 24 as part of the auxiliary systems aging management.
But in 25 general the staff found for both the engineered safety
(~)
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features systems and for the auxiliary systems that the bulk
()
2 of the aging management programs are very common, standard,
\\_/
3 existing programs that the staff's very familiar with, j
4 That concludes my presentation.
I think we're 5
doing section 3.7 next.
6 CHAIRMAN BONACA:
Okay.
]
7 MS. COFFIN:
Thank you.
8 MR. PARCZEWSKI:
Good morning.
My name is Kris 4
I 9
Parczewski.
I'm a member of the staff of Material and
)
10 Chemical Engineuring Branch, and I'm going to present today 11-Section 3.7 of the SER dealing with steam and power 12 conversion systems.
13 The steam and power conversion system consists of 14 four systems -- main steam system, condensate system, em3
(
15 emergency feedwater system, and feedwater system.
We in our A_.j i
16 review didn't identify open items, confirmatory items, or 17 license renewal issues.
18 There is one item of interest.
This is 19 erosion / corrosion program.
All the aging effects for those 20 systems indicated are due to a different type of corrosion, 21 and erosion / corrosion applies to two systems.
It occurs in 22 main steam system and in condensate system.
23 What is different about the other programs, 24 management programs for other systems are a common aging 25 management programr, and they are described in Section 3.2 O'
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which was presented yesterday.
What is difficult about
()
2 erosion / corrosion systems is that the control of the erosion 3
corrosion systems usually -- the systems are controlled by 4
oxygen concentration.
The lower the oxygen concentration, 5
the less corrosion occu'es.
6 This is not true for erosion / corrosion.
7 Erosion / corrosion apparently is higher at the low oxygen 8-concentration.
And this is why it is a conflicting 9
requirement to keep the environment to reduce corrosion.
10 And therefore the program for erosion / corrosion, aging 11 program, is not controlled but is monitoring the effect of 12' erosion / corrosion.
13 There.are two ways.
One is there is a program, a
.14 computer program which predicts the amount of f~
\\
15 erosion / corrosion, and then there is a process by which the i
16 thickness of reduction of the system of the thickness of the 17 wall of the components affected by erosion / corrosion can be 18
. measured using either UT measurement,-ultrasonic, or by 19 radiography.
And this is why this particular program is 20 described in Section 3.7.
j 21 DR. KRESS:
Is that computer program called 22 Checkworks?
23 MR. PARCZEWSKI:
It's Checkworks.
24 DR. KRESS:
Checkworks.
.25 MR. PARCZEWSKI:
It's developed by EPRI.
i
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DR. KRESS:
Yes.
]
2 MR. PARCZEWSKI:
And generally accepted by most of 3'
the plants.
J4 This is all I have to present.
'5 DR.-UHRIG:
Has the power level been increased 6
since the original license?
1 7
MR. PARCZEWSKI:
Not that I know.
8 DR. UHRIG:
You have no plans to increase -- to 9
.ask.for an upgrade of power on these units?
10 ~
MR. ROBINSON:
At this point, no, sir.
We have 11 discussed power uprate, and it is not currently in our plans 12 for Oconee.
13 DR. SEALE:
There's another question of timing 14 which is always intriguing having to do with the
()
15 Lerosion/ corrosion program and the in-service inspection
{
16
. activities.
As we all know, I'm sure you're aware of the
~ 17
' pilots that have been done on in-service inspection with the 18 idea of' refocusing inspection sites on the basis of some 19 assessment of risk and so on.
Presumably you are not 20 proposing to do that as a part of this process.
You're 21 going:to essentially continue to do your in-service j
i 22 inspection according to the longstanding rules in the j
i 23 regulations.
Is that correct?
)
24-MR. ROBINSON:
Yes, sir., that is correct.
.25 DR. SEALE:
Downstream that of course does not in i
f)%
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- 1h 2
reissued that you might want to come in and request a V-3 conversion, if you will, to an in-service inspection program 4
that's risk-based or risk-informed.
5 MR. ROBINSON:
Duke has actually begun to study 6
that issue, and we're following others in industry that have
\\
7 made further progress on risk-informed inspection, and I J
j 8
suspect as the maturity of the industry moves forward, Duke
]
)
9 will be right there.
\\
10 DR. UHRIG:
I have a question for I think Cris i
a 11 here.
Suppose an applicant was awarded an extended license, I
12 but before the 40 years was up, they decided to upgrade, and 13 this was approved, upgrade the power 5 percent or something i
14 of this sort.
Would that 5-percent increase carry into the
()
15 new license at the end of 40 years, or would there be an 16 additional review of that?
17 MR. GRIMES:
In order to make the point as clear 18 as I can, upon the completion of a license renewal review,
'19 there is a new license, and it has a new license basis.
If 20
'following the granting of a new license for Oconee, assuming 21 that the Commission concludes that one is warranted, they 22 were to apply for a power uprate, then the staff would 23
. review the power uprate on the basis of the --
24 EDR. UHRIG:
New license.
25 MR. GRIMES:
New license, i
P ANN RILEY & ASSOCIATES, LTD.
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DR. UHRIG:
Okay.
[\\
2 MR. GRIMES:
New licensing basis.
So to the s
3 extent that I think you're hinting around the potential 4
effects of a power uprate in terms of increasing.the 5
potential for erosion / corrosion or other things in the steam 6
and conversion systems, the staff would need to be careful 7
about looking at the programs that are relied upon for aging 8
management as part of the review of a power uprate.
9 DR. UHRIG:
I'd forgotten the small nicety that it 10 is in fact a new license.
Thank you.
11 DR. SHACK:
Is the feedwater system all ferritic?
12 MR. PURCZEWSKI:
Well, except for the minor 13 components which are stainless steel, but most of it is.
14 DR. SHACK:
Okay.
So they can keep the PH
-s
(,
15 reasonably high?
16 MR. PURCZEWSKI:
Yes.
17 DR. UHRIG:
One last question, you used the term 18
" emergency feedwater system."
Is this -- I presume this is 19 what commonly called the auxiliary feedwater system, or is 20 this a separate --
21 MR. PURCZEWSKI:
Yes.
This is the same thing.
22 DR. UHRIG:
All right.
It is just a matter of 4
23 terminology.
24 MR. PURCZEWSKI:
Yes.
Well, actually, the 25 terminology used in the applicant's application report.
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CHAIRMAN BONACA:
I have a question regarding
(}
2' scope.
DoLyou have any disagreement on the scope, 3
components in_ scope?
l 4
- MR. PURCZEWSKI:
Yes.
5 CHAIRMAN BONACA:
You did have disagreement with 6
Duke.
Did.you -- or you completely agree with the scope?
i 7
MR. PURCZEWSKI:
Yes.
I do' agree with the scope 8
presented'by.the applicant.
l l
9 CHAIRMAN BONACA:
Yes.
And the question I had,-
10 what about, you know, passive portions of large components 11 like stop valves and steam chest?
12 MR. PURCZEWSKI:
Yes.
I 13 CHAIRMAN BONACA:
That-typically are subjected to i
14 force, you know, pretty high solicitation during operations.
1
()
15' MR ~. PURCZEWSKI:
Yes.
16 CHAIRMAN BONACA:
They are included in the scope?
17 MR. PURCZEWSKI:
Yes.
They are included in the 18 scope, yes.
19 CHAIRMAN BONACA:
Okay.
What kind of inspections 20
_are provided for those?
21' MR. PURCZEWSKI:
There is preventive maintenance 22 which includes the inspection.
23 CHAIRMAN BONACA:
Okay.
24 DR. SHACK:
I am curious on the erosion corrosion.
'25 MR. PURCZEWSKI:
Yes.
O
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DR. SHACK:
Do people see continual losses?
I
- D}
/
2
'mean, you know, is it something you are going to have to
.3 replace piping on a five or ten year basis?
Or, you know, 4
does something go wrong and, you know, the pipe looks okay 5
today and you are-blowing a hole out in four months?
6 MR.-PURCZEWSKI:
Well, this is why you have this 7
predictive checkworks program.
It is supposed to predict 8
-the rate at'which erosion /ccrrosion damages tne component.
~
9 So, really, if you prealct at the very beginning of the 10 cycle that the component wouldn't last till the end of the 11
. cycle, you replace it or repair it..
12 And I think after the program was introduced, 13 there was considerably less failure of the components due to 14 erosion / corrosion, so, definitely, the program works pretty
()
15 well.
16 DR. SHACK:
But is there regular replacement going 17 on?
18
-MR.
PURCZEWSKI:
Well, the regular -- yes, most of 19 the plans have erosion / corrosion program implemented.
So, 20 yes.
But whenever you' check all the components -- I mean l
21 not all of them, but most of the more susceptible components
]
22 and then they are replaced if you need it.
And usually it 23 is replaced in many cases by the material which is not j
i L
24 effected by erosion corrosion like stainless steel or P-12, 25 you know.
1 percent of chromium already completely make it l
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immune to erosion / corrosion.
2 DR. KRESS:
Your question was, has it ever 3
occurred that'you had to replace something, a piece of pipe?
4 DR. SHACK:
No, they have to replace it, you know,
'5 but I just wondered if it was --nif you actually found it to
'6 be sort of a continuous' process, you know, in this 7
particular location I lose 1 mil a year and so I know in 20 8
. years, I am going to have to replace this pipe.
9 DR. KRESS:
Checkwcrks thinks it is' continuous.
10 MR. PURCZEWSKI:
Well, tais -- all the components 11 are a check, the checkworks which predict which one will 12 have to be replaced.
13 DR. SHACK:
Yeah, and I guess I am asking, do 14 people actually make replacements for these slow continual
()
15 losses, or does it, you know, when you suddenly blow out the 16 system, yeah, I go in and replace it?
17 MR. PURCZEWSKI:
No, no, no.
There is a regular 18 / and'there is replaced the components which are already --
19 DR. SHACK:
Replaced.
20 MR. PURCZEWSKI:
You know, affected by 21-erosion / corrosion.
No, there is a systematic program 22 existing.
23-DR. SEALE:
Well, there are in fact measurements 24 that are made to confirm the predictions of the checkworks 25 analysis.
V
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DR. SHACK:
Yeah, but my question is, I mean, you
/T 2
know, am I measuring a' half a mil at this location --
V 3
DR. SEALE:
I understand.
understand.
4 DR. SHACK:
-- and all of a sudden that elbow --
5 CHAIRMAN BONACA:
Well, actually, after checkworks 6
is refined with experience of the unit, after a number of a 7
years, then it prescribes pretty clearly which one you have 8
got to look at, you know, what sections, what locations and 9
so on.
10 MR. PURCZEWSKI:
Well, the rate of 11 erosion / corrosion is not necessarily constant.
So you 12 cannot see -- so this is why the program is used, is being 13 used, you know, which includes the plant operation 14 parameter, so, really, it predicts more or less what would
/%
(
)
15 be for different type of operation, operation of parameters.
16 So it is a little bit more sophisticated, just, you know, 17 assuming certain constant rate of the erosion damage to the 18 surface.
19 CHAIRMAN BONACA:
Any other questions?
20
[No response.]
21 MR. GRIMES:
Are you ready to proceed on?
22 CHAIRMAN BONACA:
Yes, we are.
23 MR. GRIMES:
The next section is Section 3.8, 24 Structures and Component Supports, and David Jeng will make 25 the staff presentation for that section.
I i
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MR. JENG:
Good morning.
My name is David Jeng.
I' \\
2 I am a member of the Mechanical and Civil Engineering Branch V
3 in the Division of Engineering, NRR.
This morning I would 4
like to report to you our review of the Section 3.8, 5
Structures and Component Supports.
6 The structures and component supports basically 7
include the following key structure systems, auxiliary 8
building, earthen embankments, intact structure, keowee 9
structures, reactor building internal structures and vent 10 stock, turbine buildings, yard structures and Class 1 11 component supports.
12 Our review has completed with the exception of 13 four open items which I am going to discuss later.
We have 14 found that Oconee applicant has properly identified the
(~h
( )
15 applicable aging effects and also adequately proposed 16 effective mean of managing those aging effects for the 17 structures I just identified.
So we have do have four open 18 items to report to you.
19 The first items pertains to the spent fuel pool 20 structure water temperature.
The licensee in the 21 application indicated the temperature could be allowed to go 22 as high as 183 degrees and yet in the FSAR of the plant, it 23 was indicated that 150 degrees is limited low temperature
{
24 range.
And the staff is concerned about this discrepancy 25 because the temperature going anything higher than 150 for a i
/"')
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226 1-sustained duration may potentially affect the prope2. of
/T 2
G' the concrete in terms of its measure of elasticity or its 3
strength characteristics.
Therefore, the staff request the 4
applicant to provide additional information to clarify these 5
discrepancies, whether indeed allow the water to go on a 6
constant basis up to 183 degrees, and so this is open item 7
number 1.
8 A second open item pertains to -- in the applicant 9
identification discussion of the applicable effects, they 10 somehow did not adequately refer to their so-called baseline 11 inspection aspect and, also, their past experience about the 12 unusual event in terms of some degradation discovered.
And 13 the staff fears that they should enhance this kind of a 14 discussion and factor it into past experience, including the
(.- s) 15 potential baseline inspection data into their consideration 16 and differentiation of the applicable aging effects.
So we 17 did request the applicant to provide additional information I
18 in this aspect.
This is the second item.
19 The third item pertains to the monitoring of the l
20 precise tendon forces in the secondary shield wall tendons.
]
21 The applicant did have some ongoing monitoring system 22 programs, however, they did not specifically commit to 23 monitor the actual forces in the tendons, and the staff 24 considers this as a major important parameter which needs to 25 be monitored to ensure the integrity of the structure ANN RILEY & ASSOCIATES, LTD.
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{
1 system.
2 The last item pertains to the attributable AMR for 3
the cable trays and conduit supports.
The applicant did 4
identify the aging of this system applies to the cable trays 5
and conduit support region of containment, reactor 6
containment system, but for the same cable trays and conduit 7
support, our side of the containment, they determine that 8
the aging management is not required.
bad the staff 9
maintains there seems to be some inconsistency in the 10 disposition of this particular effect, and we did ask the 11 applicant to clarify this discrepancy and justify as needed.
12 And these are the four open items which I believe 13 can be readily resolved by the applicant for additional 14 information.
O)
(
15 Let me move to the licensing issue item.
There v
16 are two licensing issue items which I think is of interest, 17 potential interest to you, and the first item pertains to 18 the 98-0057 Maintenance Rule of structures.
The issue 19 pertains to whether the ongoing structure inspection 20 monitoring system within the current plant operation should 21 be somehow credited, considered towards the license renewal 22 aging management credits.
And the staff is in discussion 23 with the industry about if issue reflected what extent a 24 given program should be provided, given the credit for the 25 consideration as a contributing effort towards the aging
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management program.
/}
2 The NEI recently submitted a proposal which came 3
in in a memo in. March, early March, and the staff is right 4
now reviewing this proposal and this, in due course, should-5 be resolved and the staff plans to come up with a position.
6 The second item pertains to the 98-0100 FERC dams.
7
- FERC stands for Federal Energy Regulatory Commission.
The 8
FERC has been applying some standards of dam construction, 9
design-maintenance inspection for a class of dams across_the 10 country.
There are quite a few dams which are under nuclear 11 power plant jurisdiction, but they happen to be using the 12 FERC's maintenance program, so-called five-year dam 13 inspection maintenance programs.
14
.And the staff did take a close look at the FERC's
()
15 program contents and with respect to their design standards, 16 their maintenance standards, their inspection standards, and 17 their disposition of the damages if damages were to be 18 determined.
And we came to the conclusion that the FERC 19 standards is quite adequate 40. the purpose to ensure the 20 license renewal goals.
Therefore, the staff took a position 21 earlier that any dams which.is based on the FERC five-year 22 inspection program standards and implemented accordingly are 23 all sufficient to meet the staff standards for license 24-renewal.
25-So these are the two license issues.
One is the
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229 pending review and the other one is resolved and accepted by 1
()
2 the staff.
This concludes my presentation and I am open to 3
your questions.
4 DR. SHACK:
There are other plants besides Oconee 5
then that have dams?
6 MR. JENG:
Yes, of course.
Just I read about some 7
19 dams under this category.
8 MR. GRIMES:
There are other plants who have dams 9
in the vicinity of the nuclear power plant site that are 10 regulated by FERC, hit not as emergency power supplies.
I 11
.believe that Oconee.s the only plant that relies on a hydro 12 station as an emergency power supply.
13 But if.you -- you know, my experience is with 14 Yankee Rowe, the Harriman d 7 upstream of Yankee Rowe is a
()
15' potential flooding source, and so we rely on the -- yeah, we 16 rely on other regulatory functions that tend to maintain the 17 safety of those dams, to the extent that they cause 18 potential impacts on a nuclear site.
19 DR. UHRIG:
I am trying to identify what is called 20 here the secondary shield.
What do you mean, is it part of 21 the containment?
22 MR. JENG:
Okay.
No.
It is within the 23 containment, yeah, the enclosures, primarily made of i
24 concrete structures which surrounds the steam generator, the 25 reactor.
Yeah.
4
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HDR. UHRIG:
Okay.
That are internal to the I\\
2 containment?
V 3
MR. JENG:
Yes.
Yeah.
4 DR. UHRIG:
And they are post-tensioned?
5'
.MR. JENG:
Yeah, for this particular plant that 6
. happened to use post-tension tendons.
7 DR. UHRIG:
That is not common, is it?
8 MR. JENG:
Sort of uncommon, but -- yes, I agree, 9
it is sort of -- not very common.
10 DR. UHRIG:
Okay.
11 CHAIRMAN BONACA:
Thank you.
12 MR. JENG:
Thank you.
13 MR. SHEMANSKI:
Good morning, my name is Paul 14 Shemanski, I am with the' Electrical Instrumentation and
()
15 Controls Branch, Division of Engineering, and I will be 16 discussing the last two sections of the draft SER, Section 17
-3.9 on. electrical components and Section 4.0 on TLAAs.
18 With regard to electrical components, yesterday
{
1 19 you heard the electrical scoping and screening process d
1 20.
described by both Duke and the staff, and that scoping and 21 screening-process basically resulted in identifying four 22 types of electrical components at Oconee that are subject to j
23 an aging management review.
And those four component types 24 of electrical buses, these are high voltage electrical 25
_ buses, and they typically connect the, generator to a
[~}
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transformer or a transformer to switch gear and disconnect
(
2 switches.
3 The other three components are insulated cables 4
~ and connections, insulators used for high voltage equipment, 5
and. transmission conductors.
6 Now, the service environments is identified by 7
_ Duke for these four types of components are thermal, 8
' radiation and moisture.
They then looking at the bounding 9
environments that these four types of components were 10 subjected to and, based on their analysis, there were no 11 applicable aging effects identified.
They did identify 12 aging mechanisms for electrical buses, cables, insulators 13 and transmission conductors, but in all cases the aging 14 mechanisms that were identified did not result in any
()
15 significant aging effects.
16 So the overall conclusion for electrical 17 components was thatfthere are no aging management programs 18 required for the four electrical component types I 19 mentioned.
-20 The Staff agreed with that analysis by Duke.
21 There are no open items or confirmatory items regarding 22 electrical components.
We did have one Priority 1 license 23 renewal issue on fuses.
This issue went back several years, 24 as NEI 95-10 was being developed, where we were categorizing 25~
components as to-whether or not they were active or passive.
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Fuses were identified as sort of a mystery j)
2 component.
If you look at the intended functions of a fuse,
%s-3 it is put in primarily as a protective device, to protect 4
against electrical overloads.
However, it has a secondary 5
function, that of continuity, which we believe was a passive
{
6 function.
The bottom line is that after many discussions in
{
{
7 April of '99 the Staff issued a letter to NEI concluding 8
that fuses are considered to be active for license renewal.
9 We did acknowledge that they do have a passive 10 intended function, but if you read the statement of 11 considerations in the rule, they talk about ancillary or 12 sort of secondary functions, and that is why we dismissed 13 the passive continuity function.
14 While all this sounds very confusing, the bottom r~T
(_-)
15 line is fuses are considered to be active when they perform i
16 their protective function.
It is a change of state, 17 therefore they are out of the scope for license renewal.
18 DR. SHACK:
But they are not exercised very 19 regularly, hopefully.
20 MR. SHEMANSKI:
Well, their i.acueed function is 21 to protect during an electrical overload, and normally they j
22 are just sitting there basically in a continuity state.
In 23 other words, they are just carrying the rated circuit 24 current and voltage.
I 25 DR. SHACK:
But I thought the argument was the I~N ANN RILEY & ASSOCIATES, LTD.
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activel) functioning component had a sort of performance
(}
2 indicator that you know, whether it --
3 MR. SHEMANSKI:
Right, and that was why we had 4
this dilemma, because fuses, degradation of fuses --
5 DR. SHACK:
Right.
6 MR. SHEMANSKI:
-- is not readily monitorable.
It 7
is a very difficult device to perform an electrical test and 8
determine the amount of degradation that might be occurring.
9 Fuses typically give little or no indication.
They just 10 blow due to an overload condition.
11 DR. UHRIG:
You have no way of determining the 12 level at which they blow has changed as a result of aging.
13 MR. SHEMANSKI:
That's correct.
It is very 14 difficult to do.
The most prudent thing perhaps would be on
()
15 a periodic basis to replace the fuses if there were an aging 16 concern, but based on our interpretation of the rule and the 17 fact that fuses are put in as a protective device when they 18 perform that intended function they do it in a manner which 11 9 is a change of state.
Therefore they are-considered to be 20 an active component outside the scope of renewal, so that is 21 how we left it.
22.
There are some utilities that do replace fuses, 23 selected fuses on a periodic basis, but again they are put 24 in primarily for equipment protection, so we did struggle 25 with this issue for about two years but right now it has O
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234
{
1 been resolved.
That is, fuses have been determined to be l']
2 active components outside the scope of renewal.
Qi 3
CHAIRMAN BONACA:
But it seems that you are 4
presenting the problem as if the issue -- the problem was is 5
it active or is it-passive, and I think the problem is is 6
there an aging effect that may disable the fuses in the long 7
term -- I mean then we can decide what it is, i haven't got 8
a clear understanding from you whether in fact aging of the 9
fuses will make them less capable of performing their 10 intended function.
11 MR. SHEMANSKI:
The problem is the fact that it is 12 very difficult to detect that aging.
There are not readily 13 or easily monitorable techniques, electrical techniques that 14 you could determine how a fuse might be aging.
There are
(( ),;
15 some potential aging mechanisms.
Each time a fuse is 16 energized, the wiro may become more brittle, possible 17 because of electrical stressors.
18 Another potential aging mechanism could be a fuse 19 sitting in a holder, maybe subject to corrosion.
That could 20 perhaps change its impedance characteristics.
It may affect 21 its current-time relationship, that is, when a fuse should 22 actually blow, so there are some potential aging mechanisms, 23 but again, to actually detect these and determine how a fuse 24 is aging is rather difficult if not impossible.
25 MR. GRIMES:
This is Chris Grimes.
First of all, ANN RILEY & ASSOCIATES, LTD.
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I want to compliment Paul on his patience and perseverance
}
2 as we wound through that issue over the last couple of 3
years.
We didn't get to a point of trying to decide whether 4
or not there were, quote, any " applicable or plausible aging 5
effects" associated with fuses because we had to get over 6
that.first hurdle -- the sequences, is it passive and 7
long-lived,fand'then if it is, what are the applicable aging
-8 effects?
9 But we went through it very carefully all the way
-10 to the point of do we think that there is any value that is-11 added to nuclear safety by virtue of-declaring it a passive 12 device, then nailing the applicable aging effects, but 13 ultimately, as Paul points out, the prudent practice is 14 simply if you are not sure, replace them, but trying to 15 establish that as a regulatory standard ia a formidable
( f 16-question, so at this point we approached it, and Paul did 17 this with the other electrical components too, we went i
18
.through each one of them, and there are other aspects to it 19 like is a: fuse a component by itself or is it part of a 20 circuit?
Is it a piece part?
21:
Even though you don't blow them regularly to test
)
22 them, the circuits are normally cycled in some way, I
23, energized in some way, so there should be some kind of i
24 manifestation of operating experience that suggests that 1
25 there would be.an aging concern and we really didn't see
()y.
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236 1
any, so we made the determination on the basis of the first
()
2 requirement of' license renewal'and that is, is it active or 3
_is it passive, but we did very carefully consider all of 4
these other aspects in making that determination for this 5.
and other electrical components like this, transformers --
6 MR. SHEMANSKI:
Heaters, heat tracing.
7 MR. GRIMES:
Yes.
So I don't want to leave you 8
with the impression that the only thing we got to hang our 9
hat on here is this bizarre explanation of the active nature 10 of a-fuse.
We put more thought into it than that.
11 DR. UHRIG:
But isn't a program of replacing 12 electrical components very often counter-productive?
The 13 history in the electron tube era of replacing tubes in 14 computers was a disaster because of the bathtub effect with
()
15 the very high burnout rate in the early stages.
Would that 16 not be similar to what you would run into with a fuse 17 replacement program?
18 MR. GRIMES:
Yes.
I am' familiar with the 19-experience that suggests that preventive maintenance on 20 electrical. systems tends to cause more plant transients than 21 the failures that_you are trying to prevent by virtue of the 22 aging of the components, and I'll let Paul add, if he feels 23 like it -- that really wasn't a consideration in terms of 24 whether-or not we felt it would be prudent and enhance 25 safety by.trying to push towards a fuse replacement program.
(
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We never really got to that point of saying
()
2 whether or not the aspect of a fuse replacement program 3
might be detrimental because of the potential failures 4
introduced by replacing the fuses.
I don't think we got 5
there.
6 MR. COLAIANNI:
This is Paul Colaianni at Duke.
I 7
am the Electrical lead, and I was involved in some of the 8
discussions, and I just want to back up the Staff's 9
position, also in the letter that they issued.
10 They are going to be looking at this in Part 50 11 because if there are some aging problems going on with fuses 12 then they do need to be addressed today, and so they are 13 going to be looking at a Part 50 issue and addressing it 14 that way, which would give us results before the end of the
()
15 40-year license.
16 DR. KRESS:
I think it would strike most people as 17 rather bizarre to characterize a fuse as an active 18 component.
I think that is going to cause you more problems 19 than you think, because it is going to look like you are
)
i 20 hunting for a way to get around the problem, rather than i
21 face the problem head-on.
22 I don't know if that is going to be a problem to 23 you or not, but that is the way it appears to me.
24-MR. GRIMES:
Well, like any of the 108 generic 25 renewal issues, like all of them, we hung ourselves out f/)
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there and just blatantly put all that thinking out in our A
2~
letter to NEI and we have shared that with the committee, 3
and if you feel like we are going to damage any public 4
credibility with that cockamamie story -- excuse me, with 5
that technical explanation --
6
[ Laughter.]
7 MR. GRIMES:
-- then by all means I would like.the 8
committee's feedback on that because we do not want to 9
damage public credibility by doing something bizarre.
10 As I said, we wrote up an explanation on the 11 determination of fuses being an active component as well as 12 similar determinations for some other electrical components, j
l 13 and we put that position forward to NEI, and of course they
]
14
.werequite pleased because those positions limited the scope l
~
15 of license renewal, but if the committee feels that that 1
16 explanation is going to damage the credibility of the l
17 program in any way, by all means let me know and we will do 18
'something about it.
19 CHAIRMAN BONACA:
The question I have is what does 20 operating experience tell us about fuses?
I mean there's 21 been a lot acceptance for 60 years but we have had 20-plus 22 years ofLoperation of power plants.
Is their operating 23 experience telling us that there is an issue there?
24 MR. SHEMANSKI:
We have looked at LERs and there
.25 is not an overwhelming story with regard to fuse failures.
ANN RILEY & ASSOCIATES, LTD.
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Certainly.there'have been fuse failures in the past, but we
[ )\\
2 don't.have overwhelming evidence that they tend to be a
-3 significant problem at least from an aging standpoint.
4 I will note one more thing.
In response to the 5
April letter we sent to.NEI, EPRI picked it up and is 6
'considering a program involving removing fuses from Big Rock 7
Point,. selected fuses which are approximately 35 years old, 8'
and EPRI is considering the possibility of doing some 9
selective testing with the focus of determining to what
.10 extent aging may be occurring in these fuses, so that was 11 gracious of EPRI to pick up our letter and go one step 12 further with it.
13 We will be anxious to see if they continue with 14 the fuse testing program on fuses from Big Rock Point.
15 DR. KRESS:
What kind of aging effect'can you 16 imagine that would keep a fuse from blowing, which is its 17 basic purpose?
Seems to me like it's almost a failsafe 18 device and you could eliminate it on some basis like that.
19 MR. COLAIANNI:
Well, this is Paul Colaianni, 20 Duke, again.
The possible or theorized failure modes of a 21 fuse -- you know, one is that it would blow sooner than you 22 need it.
23 DR. KRESS:
But would that give you a problem?
24.
MR. COLAIANNI:
Well, it may take a circuit out 25 earlier than you actually wanted it to and that, depending
'/D' ANN RILEY & ASSOCIATES, LTD.
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20036 (202) 842-0034
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on the circuit, it might cause you a problem, I don't know.
[ )D 2
DR. KRESS:
That would be inspectable for though.
3 MR. COLAIANNI:
Yes, yes, but as a matter of 4
point, it is not agreed upon in the industry, be it for 5
contractors, vendors suppliers, manufacturers, that these 6
aging effects are really taking place.
Some people say they 7
are.
Some people say they're really not.
8 There is not real agreement, and that is something 9
that is still being searched out.
10 DR. KRESS:
My point was even if they are, is it a 11 problem?
That would be the way I would analyze it.
12 MR. COLAIANNI:
We haven't seen a lot of 13 indication that it would necessarily be a problem.
There is 14 a good bit of doubt in the area to begin with.
\\
i(
f 15 DR. UHRIG:
The alternative to a fuse, of course, i
16 is a breaker system, and how are breakers classified?
J 17 MR. SHEMANSKI:
Breakers are classified as active l
18 components because based on the definition in the rule they 19 have moving parts or they change configuration basically, 20 which is a change in state, so breaker switches, those type 21 of components are categorized as active and as such outside 22' the scope of renewal.
23 Very few electrical components were classified as 24 passive -- cables and connections, electrical 25 penetrations -- so the scope of electrical components is
/
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rather narrow compared to the mechanical list of components.
2 The next section is 4.0 on time-limited aging 3
analyses, and during the course of the review, Duke 4
identified 10 time-limited aging analyses which are 5
presented on the next two slides.
And then for each of the 6
10, I have a summary slide which will talk about open items 7
and confirmatory items.
But, briefly, let me just run 8
through these 10.
9 One is on fatigue analyses for containment liner 10 plate and penetration.
The next one is the loss of 4
11.
prestress in the containment post-tensioning system.
The 12 third one is fatigue and fracture mechanics.
Four, the 13 reactor coolant system and Class 1 components.
14 CHAIRMAN BONACA:
Could I interject?
I 15 MR. SHEMANSKI:
Okay.
16 CHAIRMAN BONACA:
Looking at this presentation, l
l 17 this'is the last one for the morning.
I 18 MR. SHEMANSKI:
This is the last presentation.
19 CHAIRMAN BONACA:
And it is a lengthy one.
20 MR. SHEMANSKI:
It is a lengthy one, that is why 21 we have the people up here.
22 CHAIRMAN BONACA:
So I wopld propose that we take 23 a break now, and then we do.the meeting with this
~24_
presentation and then continue that.
Otherwise, we have to 25 interrupt in the middle probably.
4 O
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MR. SHEMANSKI:
Okay.
F.ine.
(O 2
CHAIRMAN BONACA:
So if it is okay with you, let's
,)
3 break and resume the meeting at 10:00.
4
.(Recess.]
5 CHAIRMAN BONACA:
All right.
Let's begin.
6 MR. SHEMANSKI:
Okay.
Continuing on Section 4.0, 7
time-limited aging analyses.
As I mentioned earlier, Duke 8
identified 10 TLAAs, Fatigue analyses for the containment i
9 liner plant and penetration.
Prestress loss in the j
10 containment post-tensioning system.
The third TLAA is 11 fatigue and fracture mechanics analyses for ISI reportable 12 indications in the reactor coolant system and Class 1 13 components.
14 The fourth TLAA-is neutron embrittlement of the J
15 reactor pressure vessel, and also inter-granular ~ separation 16 in the heat. effected zone for low alloy steel.
The fifth 17 TLAA is flow-induced vibration, transient cycle count 18 assumptions and ductility reduction of fracture toughness 19 for the reactor vessel internals.
20 The next slide shows the remaining five TLAAs.
21 Fatigue analysis of the reactor coolant pump flywheel.
22-
. Fatigue analyses of mechanical components.
Environmental 23 qualification of electrical equipment.
Fatigue analysis of I
24 the polar crane and the final TLAA is aging evaluation of 25 boraflex in a spent fuel rack.
e ANN RILEY & ASSOCIATES, LTD.
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20036 (202) 842-0034 i
i
243 1
Now, for each one of these 10 TLAAs I have a slide
(
'2.
which lists the open items, confirmatory items and license
'3.
renewal issues, so we will just take these one at a time.
4 And if you have any questions,.I will have the appropriate 5
member sitting next to me answer them.
6 The first one is on containment liner plate and
'7 penetrations.
The open item deals with the applicant 8
providing a discussion of the cumulative effects of all 9
possible cycles and a fatigue analysis.
10 CHAIRMAN BONACA:
What are the sources of the 11 cycles on the containment anyway?
12 MR. ASHAR:
What is your question?
I didn't 13 quite --
14 DR. KRESS:. What are the cycles that cause fatigue
()
15 on the containment?
What creates the pressure side?
16 MR. ASHAR:
Thermal cycles mainly.
I am Hanraj 17 Ashar.
The~ number of cycles being considered are mainly 18 thermal cycles.
19 DR. KRESS:
Heatup and cooldown?
20 MR. ASHAR:
Heatup and cooldown, heatup and L21 cooldown, that kind of cycles.
22 DR. KRESS:
How about the summer and winter, is 23 that a. cycle?
24 MR. ASHAR:
Summer and winter not affecting liner
'2 5 '
penetrations as.much, no.
But it is being considered but O
. ANN RILEY & ASSOCIATES, LTD.
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1 does not affect too much the final analysis really.
()
2 DR. KRESS:
Day and night doesn't affect it 3
either, the temperature variation between day and night?
Or 4
is it thermal lag time, too?
5 MR. ASHAR:
Well, because mostly the liner plate 6
and penetrations that are we are looking at from inside, and 7
how much they are going to be affected by the fatigue.
The 8
outside temperature for concrete containment like at Oconee 9
will not be of that much.
10 But they have considered day and night cycles, 11 yes.
12 DR. KRESS:
But it is mostly just heatup and 13 shutdown of the plant?
14 MR. ASHAR:
Heatup, yeah.
()
15 DR. KRESS:
Thank you 16 MR. SHEMANSKI:
Okay.
There is one confirmatory 17 for the containment liner plate and penetrations.
The 18 applicant should note that the performance-based Option B 19 allows the 10 year frequency, if previously leak rate tests 20 had no problems.
However, additional leak rate tests may 21 have to be performed after any measure modifications.
For 22 example, a steam generator replacement.
23 There are two items of interest associated with 24 the containment liner plate and penetrations, the first 25 being the containment leakage testing program and the second
/
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one:is the containment ISI plan.
()
- 2 Are there any questions on the items of interest?
3
.If so, Hans could probably speak to them.
4 CHAIRMAN BONACA:
Would you tell us something
-5 about these items of interest?
6 MR. ASHAR:
There is more -- the two items of 7
interest.
8 CHAIRMAN BONACA:
The thermal leakage testing 9
program.
10-MR. ASHAR:
Leaking testing program.
In 11' yesterday's. presentation to you on containment structure, I 112
' mentioned to you that in one of the program,.that the 13 applicant has considered as a part of the aging management 14 program is the containment leakage testing program.
And
()
15 because the ferritic cycles and the liner plate and 16 penetrations are being affected by containment leakage, or I 17-mean they could be source of leakage, that is why they 18 really want items there so I put that in as a part of items 19 of interest, really want items.
20 CHAIRMAN BONACA:
Right, I understand.
~
21 DR. KRESS: ;The containment thermal cycles, there 22 is not much you can do about those.
I mean they are sort of 23 fixed.
And there is not much you can do in the way of
~
24.
inspection to see if you have.got fatigue damage.
The 25-leakage testing is too few and far between to be of much ANN-RILEY.& ASSOCIATES, LTD.
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20036 (202) 842-0034
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246 1
use.
IY 2
I am having. trouble trying to figure out this
'd 3
particular aging management problem, how you are going to l
4 manage the aging of this.
All you did -- I presume what you 5
~did'is just calculated it away and said that there is no 6
problem.
4 7
MR. ROBINSON:
Greg Robinson.
Yes.
Primarily-8 here we are looking at boundary conditions on the original-9
. design and checking the boundary conditions to make sure i
10 they would be acceptable for 60 years.
11 DR. KRESS:
For the rest, yeah.
1 12 MR. ROBINSON:
Not so much aging management.
13 DR. KRESS:
It is not going to be a management 14, program.
So I. don't understand then why there is an ISI and
()
15 a containment leakage items of interest up here on the 16 slide.
That is what is bothering me.
I mean they don't 17 seem to be relevant here to me.
18 MR. ASHAR:
Well, let me answer that question.
R19 The reason we just put that as items of interest is because 20 in ISI plan, the containment liner and penetrations will be 21 visually examined.
If there are problems, they will be NDE 22 examined.
If there any problems due to the ferritic, it 23 will show up during those inspections.
Or it may show up 24
.during the leakage rate testing.
So that is the reason they 25 are being put as items of interest and not really related to
[~'l
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.1 '
the ferritic is particular, but in general basis, you know.
[~'E 2
DR. KRESS:
Items of interest, when they show up
.V 3
in this SER, have no regulatory requirements or anything 4
' associated with them?
5 MR. ASHAR:
That's right, exactly.
6' DR. KRESS:
Okay.
7 MR. ASHAR:
Exactly, yeah.
8 DR. SEALE:
But you already have an ongoing 9
requirement to do the leak. rate testing.
10 DR. KRESS:
Yeah, for some other reason.
11 DR. SRACK:
Other reasons, yeah.
12 DR. SEALE:
Obviously, yeah.
But you are absolved 13 it once you go to the license renewal.
14 MR. SEBROSKY:
Dr. Kress, this is Joe Sebrosky.
()
15 Just as a point of clarification, the items of interest were 16 determined by'the staff that is tomething that the ACRS may 17..
'be interested in.
They are not identified in the SERs as 18 items of interest.
3 19-DR. KRESS:
Thank you very much.
20 MR. SEBROSKY:
It is just the staff thought --
1 21' DR. KRESS:
That helps me a great deal.
)
122 MR. SEBROSKY:
Thought you guys would be -- as a 23' matter of fact, we were requested, if we thought that there 24 was a particular item in a section that you would be
]
25
-interested'in,'to try to identify that.
So it is our best
[\\
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guess.
O.
2 DR. KRESS:
Okay.
Thank you.
That helps a lot.
3 MR. SHEMANSKI:
Okay.
The second TLAA involves 4
'the containment post-tensioning system.
There is one open 5
item dealing with the trend lines that will demonstrate the 6
adequacy of the existing prestressing forces in the 7
containment tendons have been not been shown by the 8
applicant for the period of extended operation.
9 There is one license renewal issue involving 10 IWE/IWL for the tendons.
11 Hans, do you want to --
12 MR. ASHAR:
Yeah.
This is what I discussed 13 yesterday when I was talking about the containment structure i
14 and there is the temperature effect on the tendon
()
15 prestressing forces, and that we discussed yesterday.
I 16-think you asked me a few questions on that one.
So if you 17-want to know a little more about it, I can, but, otherwise 18 that is all --
19 DR. UHRIG:
What is involved in closing out this 20 item, open item?
21 MR. ASRAR:
The open item, let me -- I think I 22 have,got something I can show you.
Yeah, I think I have got 23 it.
~.ihat the applicant has given us right now, this is 24.
calledEa minimum required value.
This is required for 25 withstanding the pressure, internal pressure during the
(~}-
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LOCA.
Okay.
What applicant has given me, another line
(
)
2 which says here PLL line.
PLL line is this line here which 3
-- the one with the dots on.it, that is a PLL line.
4 These are the two items that applicant has given 5
in this particular sketch on which dimension yesterday, in
{
6 UFSAR supplement, Chapter 16 of the UFSAR supplement.
7 Now, what they should have done is to add some 8
additional line, not just add it, based on the measure of 9
~ prestressing forces at various' times.
They can tell us as 10 to what is the train line of the existing prestressing i
11 forces.
These are PLL and MRV, all -- both of them are i
12 based on the estimated values.
During the time of 13 construction or later on, they might have revised them, 14
. whatever, but they are estimated values.
They are not the 15 actual value existing in the containment.
16 What we are looking for is-that based on their 17 experiences until now, what they have found, and through 1
18 regression analysis show us that at 40 and 60 years, you are 19 going to meet that PLL and the MRV.
MRV is this line, PLL 20 is-this line.
21 Okay.
I am showing you two lines here which may 22 go below the PLL~1ine'at 60 years.
j 23 DR. SHACK:
Those are just conjectured lines?
24 MR. ASHAR:
These are conjecture lines.
They are 25
' conjecture lines, correct.
But this is the area we are
~(
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looking for from the applicant.
2 CHAIRMAN BONACA:
What do you mean conjecture?
I 3
mean are_they results of calculations or --
4 DR. KRESS:
He just threw them up there.
5 MR. ASHAR:
No, this is just -- I was showing just 6:
two lines to show -- I can show you another line from 7
another' plant which shows, it shows measure data and how 8
regression in ISI is performed.
9 DR. SHACK:
But I mean even if the line went below 10 that would just be part of your aging management plan, would 11 be to retension the --
12 MR. ASHAR:
Yeah, there is to be systematic 13 retensioning of the tendons in order to make sure they are 14 in average way, in the whole group of tendons, there will be
()
.15 a certain amount of prestressing force, that compression in 16 the concrete.
17 Now, this line is from another licensee and this 18 is another plant, not Oconee.
But it shows you that how 19 they do the -- these are the measured results.
These points 20 are the measured results at various times.
At various times 21 they measure the prestressing forces.
These are the 22 measured prestressing forces.
23 Based on these measured prestressing forces, this 24 particular licensee drew the regression line going up to 25 here 30 years.
They said that with this data they can go
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i 251 l'
.only'up to 35 years here.
After 35 years, they will have
-(
2 problem.
They will have to do something about retensioninct 3
the tendons in. order to meet 40 years and 60 years if they 4.
want to apply for a plant life extension.
5 DR. KRESS:
You have some sort of acceptance value 6
on the regression coefficienu for that?
7 MR. ASHAR:
Yes.
We have --
]
l 8
DR. KRESS:
Because I would have a lot of trouble i
9 of accepting that regression line through that data.
I 10 The question is, I could draw tha line going the 11 other way on this.
f 12 MR. ASHAR:
No.
This line is not the way it was 13 conj ectured line last time.
This line --
i 14 DR KRESS:
I know, it's a regression line.
15 MR. ASHAR:
Regression line.
1 16 DR. KRESS:
But the regression coefficient must be 17 awfully small.
18 DR. SHACK:
He is saying the data looks like a 19 shotgun blast.
20 DR. KRESS:
The data looks like a shotgun.
21 MR. ASHAR:
Well, first, let me explain to you how 22 the time-dependent losses.
I can explain to you maybe a 23 little more than this, okay?
24 It might seem like it is shorter than that, but it 25 is not.
The time-dependent losses in pre-stressing forces O-ANN RILEY & ASSOCIATES, LTD.
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1 has been'shown'to have direct relationship -- the force
['\\
\\s-)
versus the time shows a linear relation when the time is log i
2 I
3 scale, okay?
It has been shown.
]
4 DR. KRESS:
So you know it is linear?
5 MR. ASHAR:
We know it is -- log-normal --
6 DR. KRESS:
Yes, you know --
7 MR. ASHAR:
So that line is a linear line is an 8
assumption in that sense, but it has been shown by a number 9
'of other analyses.
10 DR. KRESS:
That I buy, it's just that you still 11 have to accept the slope and --
12 MR. ASHAR:
Well, that comes from the list square, 13 the normalized list square here.
14 DR. KRESS:
That is why they have the problem.
15 DR. SHACK:
If the computer spits out an R, it's 16 good enough.
17 DR. SEALE:
Yes, but I could change my criteria t
18 for accepting the validity of one or two datapoints and jack 19 that line almost in any direction I wanted it to go.
20 MR. ASHAR:
Yes, I agree with you.
There are a 21 number of manipulations possible in plotting these lines, 22 okay, and this has.been discussed in our latest information 23 notice that we issued in March, 99-10, where we discuss 24 these particular items in more detail.
25 DR. UHRIG:
You have labelled those observed
'()
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forces.
Are'those measured forces?
Were they re-tensioning 2
at each interval the data is taken there, or was that just 3
what it was at that particular time?
4 MR. ASHAR:
There are a number of tendons, 5
pre-stressing. tendons.
They did the lift-off testing which 6
is measuring pre-stressing forces.
They measured the 7
pre-stressing forces at those points and those shown here, l
l 8
for example, it would be 1125 kips they show, then here they l
9 must have seen 1240, 1245 or something, so these are the 10 shown measured results of those pre-stressors.
l 11 DR. UHRIG:
But they did not do any f
12 post-tensioning at that time?
13 DR. SHACK:
When he measures 1125, does he say, 14 oh, gosh, that's getting kind of low and inject that --
r 15 MR. ASHAR:
No, no.
That they don't do because 16 the method of lift-off testing is very precise.
Wha it j
17.
does is it just picks up -- and they have a filler gauge 1
18 underneath to make sure that it picks up all the tension, 19 and then they measure it on the side of the document 20 somewhere, okay, and at that time they do not re-tension or 21 nothing.
They do not add any shims-or anything like that 22 in-between.
It is what it is at that time, so it stays at 23 that time unless the decide to de-tension that for some l
24 other reason, if they find some problem -- they decide they J
25 would,like.to investigate a little more, which they did in O
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1 Calvert Cliffs earlier, then it would be different.
Then
(
2 they would re-tension again. They could re-tension at "3
different levels, yes.
4 DR. SHACK:
Is this a typical dataset, what this 5
looks like?
6 MR. ASHAR:
Yes.
Yes, this is a very typical 7
dataset as far as --
8 DR. SHACK:
My experiments don't look so bad now.
9
[ Laughter.)
10 MR. ASHAR:
You should remember there are so many 11 variables to have measuring this thing -- the calibration of 12 jacks, the way the things are put together, the way the 13 friction plays a part in the whole thing.
There are a lot 14 of. variables in this one, before you come out with this
()
15 simplified data even.
16 DR. SEALE:
That's what I said.
If you change the 17 criteria for selecting a datapoint or two --
j 18 MR. ASHAR:
No. As far as what we have in the 1?
Regulatory Guides and subsection IWL of ASME Code, we 20 considered them adequate enough to get the gross area, gross i
21 item.
If sotnething goes wrong, we will be able to figure it 22 out.
That is the idea.
23 DR. SHACK:
Yes, I guess that is a code-minimum 24 value.
25 MR., ASHAR:
That is the code-minimum value.
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DR. SHACK:
Already got a safety factor on it.
2 MR. ASHAR:
That is norrect.
3 DR. UHRIG:
The force on an individual tendon?
4 MR. ASHAR:
The crosses you are seeing are the 5
forces on the tendon that they pulled.
6 CHAIRMAN BONACA:
But each time it measured a few
-7 tendons, right?
8 MR. ASHAR:
Each time you measure a few tendons, 9
right 10 CHAIRMAN BONACA:
And you get that kind of spread.
11 MR. ASHAR:
Normally we call them randomly 12 selected tendons.
That is the way the word is used but many 13 times " random" doesn't work but we tolerate that within 14 certain bound of certain certainty, you know?
()
15 DR. UHRIG:
What is the typical diameter of a
-16 tendon here?
Half an inch, three-quarters of an inch?
17 MR. ASHAR:
This one I don't remember.
On Oconee 18 I think there are 95 tendons -- yes.
In Oconee plant there 19 are 95 tendons with a force close to over 700 kips or 20 something~1'ike that.
21 CHAIRMAN BONACA:
The conjectured curve by Oconee 22 doesn't look.that bad anymore.
23 MR. ASHAR:
Well, Oconee, as you mentioned, it was 24 conjectured lines.
They were not based on any measured 25 data.
I wanted to show that this thing can happen.
It can O
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256
-1 go below 60.
It can stay above 60.
You never know, but
(
'2
'that' plain line has not been shown by the applicant to us, 3
' based on the measured data.
That is what we are asking them 4
to do.
5-MR. SHEMANSKI:
Okay.
There is one item of 6
interest regarding the containment post-tensioning system 7
.that deals with the containment ISI plan.
8 MR. ASHAR:
Containment ISI plan.
This item of j
9 interest, because it is related to the post-tensioning 1
10:
system -- yes.
11 MR. SHEMANSKI:
We will move to the next, TLAA,
)
1 12
. which is on fatigue analysis of the reactor coolant system.
13 There are two open items.
The first one deals with the d
14 reactor coolant system is not adequate to address fatigue
{
15 concerns for operation beyond 40 years.
This is basically 16 GSI-190.
17 The second open item deals with the corrective 18 actions regarding the Section XI flaw evaluation.
Any 19 questions or comments on the open items?
20 DR. SHACK:
I thought yesterday that the Framatome 21 people told us they did go back and re-analyze the things, j
22 the limiting locations, and found that they were okay.
23 MR. FAIR:
This is John Fair, with the Division of j
24 Engineering.
Framatome was talking about the vessel 25 evaluation.
l
.(~)
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DR. SHACK:
The vessel?
2 MR. FAIR:
And they had done an evaluation of the 3
vessel using the data that was available a couple of years 4
ago.
The new stainless steel data that we are concerned 5
with.in this evaluation didn't impact those points we were 6
concerned with in the vessel.
7 MR. SHEMANSKI:
Okay.
There is one confirmatory 8
item dealing with the completion of emergency feedwater 9
nozzle analysis -- actually three confirmatory items.
The 10 second one is Class I analysis of the attached piping to the 11 first isolation valve and the third item is the revised 12 response to NRC Bulletin 88-08, looking for the revised 13 response by July 1, the year 2000.
-14 DR. SHACK:
Now what are you expecting them to do
()
15 on the 190, for example, to look at some limiting locations 16 in the piping system?
17 MR. FAIR:
That.is what we would like them to do.
18 Yes.
That was our recommendation in the SECY 95-245, and so 19 far I haven't seen anything from B&W plants on this 20 evaluation.
21 DR. SHACK:
The flaw evaluation, that is the 22 reportable indication that they have in the vessel, is that 23 the one we are talking about here?
I think there are several locations 25 where they have reportable indications.
I am not the ANN RILEY & ASSOCIATES, LTD.
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258 1-reviewer on this particular issue, but I believe they i
l
/
2' have -- the-open item is just some discussion of what kind J
l 3-of evaluation they did and what they are cranking into the 4
analysis.
It really came up late in the review and the 5
licensee.didn't have a change to respond to the issue.
]
6 DR. SHACK:
Okay, but it doesn't seem to be a 7
critical problem?
-8 MR. ELLIOT:
Not really.
We talked about this 1
9 yesterday with respect to the vessel.
There are flaws in 10 other pilations in the plant.
This covers all of those 11 locations.rather than just the vessel.
12 MR. SHEMANSKI:
There is one license renewal issue 13 regarding the fatigue of metal components?
14 MR. FAIR:
John Fair again.
This is just the same O
15 open issue on the environmental data.
j fy 1J MR. SHEMANSKI:
There are no other items of 17 interest on fatigue of the reactor coolant system.
)
18 The fourth TLAA deals with the reactor neutron 19 embrittlement and underclad cracking.
There were no open or 20 confirmatory items identified.
However, there is one 21 license renewal issue regarding vessel surveillance.
22 MR. ELLIOT:
Vessel surveillance was discussed 23 yesterday.
They have an integrated surveillance program.
24 DR. SHACK:
I mean it is a larger issue because 25 not all plants may be as well off as Oconee.
I assume that Q
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1 259
(
1 is why it is a generic issue.
~
i
{)
2 MR. ELLIOT:
We just put this down so that if you 3
wanted to discuss it here we could discuss it some more.
4 MR. GRIMES:
This is Chris Grimes.
The larger 5
. generic issue from the standpoint of renewal is the extent 6
to which the Staff can clearly identify on the standard 7
review plan the expectations for an adequate vessel 8
surveillance program.
As Barry pointed out yesterday, each 9
of the owners' groups has got a vessel surveillance program 10 and so it is just a matter of us capturing those things and 11 integrating them into the review plan.
12 MR. SHEMANSKI:
We listed four items of interest 13 regarding the reactor neutron embrittlement and underclad 14 cracking.
One deals with pressurized thermal shock.
The I
15 next one is Charpy Upper Shelf energy.
The third one is 16 underclad cracking.
The fourth one is pressure temperature 17 limits.
18 MR. ELLIOT:
These all relate to neutron 19 irradiation embrittlement, pressurized overshock -- there is 20 a screening criteria which we discussed yesterday and may 21 satisfy.
The Charpy Upper Shelf energy and the underclad 22 cracking were also embrittlement issues discussed in 23 BAW-2274 and BAW-2275, We discussed those yesterday.
24
. Pressure t emperature limits are also -- it's an 25 embrittlement question.
Appendix G of 10 CFR 50 establishes
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'l limits for pressure temperature limits.
The' licensee has i
2 looked back and is~ submitting new curves right now.
I think 3
it is for 33 effective full power years, and we are 4-reviewing it at this time.
5 The 48 effective full power years they say that 6
they can generate sufficient curves.
A concern here was 7-would there be an operating window between the pressure 8
temperature limits and the reactor coolant pump pressure 9
. suction limit, and they have looked at that and they said 10 based upon the new regulatory requirements coming in from 11 the ASME Code and NRC, they will have an operating window to 12 operate at 48 effective full power years.
13-MR. SHEMANSKI:
If there are no questions, then we 14 can move on to the next, the fifth TLAA, which deals with 15 the reactor vessel internals.
Two open items have been 16 identified.
The first one deals with -- a plan must be 17' submitted and approved by the staff which develops data to 18 demonstrate that the internals will meet the deformation 19 limits.
And the second open item, the applicant did not 20 address the applicability of flaw growth acceptance in 21 accordance with'the ASME B&PV Code, Section 11, ISI 22 requirements.
23 MR. ELLIOT:
Barry Elliot again.
The deformation 24 limits, there is a deformation limit in the code.
When you 25 do seismic evaluation you must have certain amount of O
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deformation allowed.
And-the question is, when you get
()
2 embrittlement, do you have'that -- do you still have that 3
' deformation limit?
Is there sufficient ductility remaining I
4 after embrittlement that you can still make the deformation 5
limits of the-ASME Code?
6.
And this next question has to do with flaw growth.
7
-If you have flaws in the internals, how are you going to 8
evaluate them?
-9 DR. KRESS:
What is this plan to develop the data?
10 The first item.
'll MR. ELLIOT:
They have a reactor vessel internals 12 program and they have -- this is sort of an industry-wide 13-program onLinternals in which they are going to look at 14 embrittlement and see.what the impact on the
()
15
-fracture-resistance of the stainless steel --
16 DR. KRESS:
The question is just not 17 Oconee-specific?
18' MR. ELLIOT:
No, this is not Oconee.
But this is 19
-- for Oconee they have to -- they are part of that program, 20 and when they make that program, they should take into 21 account that they have to satisfy the deformation limits of 22 the code in their program.
The industry program should be 23' able to answer.that, whether it has enough ductility, at the 24 end of 48 years -- 40 effective full power years, based upon 25 embrittlement.
Q ANN RILEY & ASSOCIATES, LTD.
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DR. KRESS:
Is that different than -- as long as a
(
}
2 they know what the fluency is, don't they have enough data 3
to determine that, know what the materials are?
4 MR. ELLIOT:
I don't think there is a lot of data 5
in this area.
We haven't gone -- this is, I mean we don't 6
have a plan yet, so I mean --
7 DR. KRESS:
Okay.
8 MR. ELLIOT:
We are going to have to look into 9
this with them and this is -- we want to the industry to 10 kick this off and start telling us what they are going to be 11 doing.
I don't know at the moment --
12 DR. KRESS:
It is a new embrittlement issue that I 13 hadn't encountered before.
14 MR. ELLIOT:
This is an internals issue.
()
15 DR. KRESS:
Yes, it is an internals.
16 MR. ELLIOT:
Most of our work in tira past in the 17 NRC has been the vessel.
18 DR. KRESS:
The vessel itself, yeah.
19 MR. ELLIOT:
The internals are really getting more 20 attention now than in the last couple of years, and this is I
21 part of that attention.
22 DR. SEALE:
Could I go back to an issue?
You guys 23 have been dropping shoes up there so fast, I am having a 24 hard time keeping up with you.
You were talking about the 25 metal fatigue issue back in 4.2.3.
And, finally, the rust f~
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'got off of my cra:n and I realized that there is a related j
()
2 problem that has been nagging at us now for a long time, a
3 little thing cal.~.2d GSI-190.
And I think these are kind of 4
related to each other, and I wondering does the July 1, 2000 5
which is in fact a year to the day from today, does that 6
suggest we may get GSI-190 done by about that time, too?
7 And glory hallelujah if we do.
8 MR. FAIR:
This is John Fair again.
The dates are 9
not coupled.
The July 2000 date that you were looking at 10 was a commitment for the licensee to complete a reevaluation 11 of HPI.
12 DR. SEALE:
I appreciate that.
I am grasping for 13 straws on 190.
14 MR. FAIR:
-I believe that they are pushing hard to A
I
)
15 get some resolution of GSI-190 done.
I don't want to make y p 16 commitments for our fellow research people, but I believe 17 they are pushing hard to get that completed.
18 MR. GRIMES:
As I recall, the last time we had a 19 conversation with the Office of Research, they were talking 20 about updating an action plan and getting the industry 21 involved in the action plan to try and bring a timely i
22 resolution to GSI-190.
And the extent to which the industry 23 can support the action plan with dictate what the end point 24 is, but they.are currently scheduled to complete their 25 activities by the end of this year.
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264 1-DR. SEALE:
Thank you very much.
2 MR. SHEMANSKI:
C'. y.
The next TLAA, number 6, 3
deals with the fatigue of the reactor coolant pump flywheel, 4
and there are no open items, confirmatory items, no renewal 5
issues or no items of interest.
So that one is --
6 DR. KRESS:
That takes care of that one.
7
[ Laughter.]
8 MR. SHEMANSKI:
So that one is no problem.
9 DR, SEALE:
Nolo contendre.
10 MR. SHEMANSKI:
As a matter of fact, the next one i
11 is the same category, nothing --
12 DR. KRESS:
Well, before you leave that one, when 13 you are talking about fatigue of the reactor coolant pump 14 flywheel, are you including the axle that it is mounted on?
()
15 I mean I wouldn't think the flywheel would have a feed 16 problem, but the thing it is mounted on, the pump axle, pump I
17 shaft.
Is it mounted on the motor or the pump?
18 MR. SHEMANSKI:
It is on the shaft, I assume.
19 DR. KRESS:
It is on the shaft.
20 DR. SEALE:
He is asking, when you do the fatigue 21 analysis, is it the whole unit?
22 DR. KRESS:
Do you do it on the shaft?
23 DR. SEALE:
Is it the shaft that is included in 24 there?
25 MR. WESSMAN:
This is Dick Wessman from the staff.
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Unfortunately, the lead reviewer for this area is not here,
()
2 and maybe the Duke Power folks can help us out, but that 3
flywheel is mounted.on the end of the shaft I think above 4
the motor.
But I think the focus is on the flywheel and not 5
the shaft.
Sam.
6 MR. LEE:
Yeah.
This is Sam Lee, I am from 7
License Renewal-Branch.
And the way I understand this is 8
that the flywheel is mounted on the shaft through a keowee.
9 So that is fatigue analysis on the keowee.
10 DR. KRESS:
The keowee itse3f.
11 MR. LEE:
Yes, on the keowee itself, that is the 12 way I understand it.
J 13 MR. SHEMANSKI:
The seventh TLAA deals with the 14 fatigue analysis of Class II and Class II components and,
()
15 again, nothing has been identified.
16 Okay.
TLAA Number 8 is on environment l
17 qualification of electrical equipment.
We did not identify 18 any open items or any confirmatory items.
- However, 19 regarding this issue, there is a priority -- this was 20
. identified as a Priority 1 license renewal issue on EQ.
21 And, basically, the question was whether or not the EQ Rule, 22 10 CFR 50.49, could be found acceptable as an aging 23 management program, that was the issue, and we have since 24.
resolved that issue on the basis that we before EQ Rule 25 50.49 is or can be an acceptable management program for
- [~')
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266 1
long-lived electrical equipment for the period of extended 2
operation.
3 As part of the EQ qualification program it does 4
include qualification testing for. thermal and radiation 5-aging prior to LOCA testing, so there is an element of the 6
50.49 EQ program that does consider the effects of aging of 7
electrical components.
And during your discussion this 8
afternoon on credit for existing programs, I am sure EQ will 9
be discussed as an example.
10 DR. SEALE:
Could I ask, yesterday we heard 11' something about concerns for the generic nature of the 12 resolution of items as they take place with respect to 13 Calvert Cliffs and Oconee.
You said this is an issue that 14-has been resolved.
Is that in the narrow sense of Oconee (O/
'15 and Calvert Cliffs, or is that in the more generic sense of 16 the whole works?
17 MR. GRIMES:
This is Chris Grimes.
This is in the I
18 narrow sense that we drug the details of how the 19 environmental qualification life-limited analysis are going 20 to be managed for the period of extended operation, we drug 21 that from these two applicants kicking and screaming, and 22 that is what kicked off and stimulated this entire issue 23 about what -- how credit for existing programs can be 24 manifest in an application.
25 After getting the information from both of the ANN RILEY & ASSOCIATES, LTD.
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20036 (202) 842-0034
267 1
first two applicants, we concluded that the programs were U'O 2
adequate without the need for any modification, not so much 3
because they would continue to comply with 50.49, but that 4
we could point to specific aspects of the programs that 5.
constitute the basis for compliance with 50.49.
And so now 6
we are going to deal with it 'n the much broader context of 7
credit for existing programs.
8 But Paul put a particular item of interest up 9
there and that is the two applicants approached this set of 10 time-limited aging analysis very differently.
Oconee 11 actually went through and categorized the analysis in 1
12 accordance with which of the analysis is already qualified I
13 for 60, which have been updated to 60, and which ones are 14 left to be managed for the period of extended operation.
t 15 Calvert Cliffs threw all of the EQ analysis into the managed
]
16 for period of extended operation bin.
17 MR. SHEMANSKI:
That is exactly what I was going 18 to say.
19
[ Laughter.)
20 MR. SHEMANSKI:
We did find both approaches 21 acceptable.
As Chris mentioned, Oconee basically did the 22 evaluation upfront.
For the large majority of equipment on 23 the master list, they actually did the calculations 24 extending the qualified life from 40 to 60 years, primarily 25 for -- well, for cables, they did that for all cables.
And
-[]
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268 1
they do have a number of items which they will evaluate
(
2' later.on'and'either extend the qualified life or replace 3'
those items.
4 And the difference is that BGE basically deferred 5
their evaluations.
They will at some point prior to the 6
expiration of qualified life of the electrical components, 7-BGE will then at that point assess whether or not they could 8
extend the qualified life or have to replace the components.
9 So, again, we did find both approaches acceptable 10 even,though there is a large difference between how they 11 were actually conducted.
. 12 The ninth TLAA is on the fatigue of the polar s
13 crane and there were no items or confirmatory items, no
' 14 renewal issues or no items of interest identified during the l
()
15 review of this TLAA.
16 The final TLAA is on the aging of Boraflex in the i
17 spent fuel racks.
There were no open items, confirmatory 18 items or license renewal issues.
However, there was one 19 item of interest and the item of interest was focusing on 20 the Boraflex monitoring program involving the visual 21-inspection of the Boraflex coupons, monitoring gap 22 information the Boraflex panels by blackness testing, and 23
.the final item of interest dealt with the monitoring future 24 performance of Boraflex by measuring the silica in the spent 25 fuel pool and using the RACKLIFE computer code.
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-]
L 269 1
Are there any questions on any of these items of
[
2 interest?
3 DR. KRESS:
Have you evaluated RACKLIFE?. Is this 4-a good code?
5 MR. SHEMANSKI:
Kris Parczewski will --
i 6'
DR. KRESS:
-- SCR on it or anything like that?
7 Kris Parczewski will speak to that question.
8 MR. PARCZEWSKI:
My name is Kris Parczewski for 9
the Material and Chemical Engineering Branch.
Please repeat 10 the question.
11 DR. KRESSi My question has to do with what do you 12 know about RACKLIFE?
Have you evaluated it and written an 13 SER and said it's adequate for this application to determine 14 the Boraflex condition?
1
()
15 MR. PARCZEWSKI:
Well, usually we actually run the 16 tests for each -- we have a coupon.
There are coupons in 17 the spent fuel pool which we examine visually, so that's one 18 way of doing it and we can predict future degradation of 19 Boraflex by using this procedure mentioned in the last item.
)
20 DR. KRESS:
RACKLIFE is an EPRI code?
21 MR. PARCZEWSKI:
Beg pardon?
1 22-DR. KRESS:
RACKLIFE is an EPRI code?
23 MR. PARCZEWSKI:
Yes, this is EPRI-developed.
24 DR. KRESS:
You have reviewed it and written an 25 SER on it?
/
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20036 (202) 842-0034'
270 1-MR. PARCZEWSKI:
No.
We just are familiar.
We
(
2 didn't review it formally, but we have all the information 3
and we know the technical bases for the program.
We 4
reviewed it.
5 DR. UHRIG:
What are the physical characteristics 6
of Boraflex in terms of its potential damage?
Does it j
7 swell?
i
'8L MR. PARCZEWSKI:
It actually has two effects.
In 9
the radiation field, the Boraflex shrinks.
If it breaks and 10 gaps are formed, those gaps are determined by --
)
11 DR. UHRIG:
Radiation meaning gamma?
)
I 12 MR. PARCZEWSKI:
Yes.
13 DR. UHRIG:
Gamma?
14 MR. PARCZEWSKI:
Yes, it is gamma.
The second
) )
15 part'is it degrades and boron carbide, which is a 16 constituent of the Boraflex is actually lost, is removed 17 from there, so this has got two effects really which affect.
l 18 DR. UHRIG:
Does that go into the water?
Does 19 that dissolve in the water or does it fall to the floor?
20 MR. PARCZEWSKI:
It falls to the very bottom of 21 the pool, yes.
This is why it can't be measured.
This 22 would be measured for silica, i
23 DR. UHRIG:
It does not dissolve?
i 24 MR. PARCZEWSKI:
Yes.
]
25 DR. UHRIG:
It does not dissolve.
O ANN RILEY & ASSOCIATES, LTD.
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MR. PARCZEWSKI:
It is heavier than water so it
(
2
' drops down, but silica stays and we correlate the. amount of 3
silica released to the amount Boracarbide released, so if 4
you measure silica you know how much boron is lost from the
~
5 panels.
6 CHAIRMAN BONACA:
So the applicant is planning to
-7 keep the Boraflex to the end of 60 years?
8 MR. PARCZEWSKI:
It should stay, yes, it'should 9'
stay for --
10 CHAIRMAN BONACA:
Is the spent fuel pool at 11 Oconee, are the spent fuel pools fully rac}.ec.?
12 MR. GILL:
This is Bob Gill with Duke.
Several 13 years ago we racked the pools, probably for the second time, 14 to put the high density racks in there, so they are 15 replaceable components but',for the purpose of license 16 renewal it is an ongoing program.
We monitor it.
If they 17 degrade far.enough, there are other actions you can take by 18 checkerboarding the assemblies, replacing the racks --
l 19 CHAIRMAN BONACA:
But you have already racked the 20 whole pool?
21 MR. GILL:
Yes, sir.
22 CHAIRMAN'BONACA:.Okay, so you are going to have 23
.an opportunity to put new material in some new racks?
l 24 DR. SEALE:
Of course the technical requirements 25 for quality of the borax don't cease at the end of 60 years.
1 i
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CHAIRMAN BONACA:
No.
It's just that if you have 2
continuous degradation like this and these cracks and 1L 3
openings exceed certain sizes, then you may have some issue 4
about managing this.
5 DR. SEALE:
Well, really the issue is that the 6
license you are running under is a 60-year license and so 7
the period covered is 60 years, but the post-operational 8
license, the license at that point then is still going to be 9
worried about the quality of the Boraflex, so it is a much 10 longer lifetime concern than -- or it is a longer lifetime 11 concern.
12 DR. KRESS:
Yes.
You need that spent fuel stored 13 somewhere.
14 DR. SEALE:
Yes.
()
15 DR. KRESS:
And we were wondering about whether it 16 should be 60 years or longer.
17 CHAIRMAN BONACA:
The reason why I asked the 18 question is some licensees that have the opportunity to 19 re-rack, they typically put the very old fuel in areas where 20 there is Boraflex and they use new material where they have 21 new upflow to the core, fuel, but evidently you have racked 2 21 the whole pool so --
23 MR. GILL:
Right, and we also have an independent 24 spent fuel storage facility on Oconee 2 that with real old 25 fuel we could --
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DR. KRESS:
You could get that stuff out of there 2
if you'had to. MR. GILL:
Obviously, we'want the back end of the
'4 high level waste cycle to be taken care of by the Department 5
of Energy but, you know, but we have a lot of contingencies 6-underway to handle it.
j 7
IN1. SEALE:
Like GSI-190.
'8 MR. SHEMANSKI:
Okay.
If there are no further 9
questions, that concludes the Staff presentation for the 10 draft SER.
11 CHAIRMAN BONACA:
I have a question regarding your i
12 mechanical components evaluation.
13 You. divided the presentation into Class I and 14 Class II and III components, but if I remember, is that
(
15.
separation appropriate also for Oconee?
I know they have a 16 QA program and they have a. lot of different categorization 17 of components or.--
18 MR. FAIR:
This is' John Fair.
I don't think-the 19-reviewer on that section is here but I believe the issue, 20 and maybe Duke can help out, is that for Class II and III 21' they don't -- components, they don't have formal fatigue 22 analyses.
What they have is a set of stress criteria that's 23 applicable for a'certain number of cycles and the TLAA is 24.
simply confirming that you don't exceed that number of 25 cycles.
1
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CHAIRMAN BONACA:
But has the Staff reviewed what
,/
}
2 that means, what this family of components consists of 3
versus the scope issue that we discussed yesterday?
4 MR. GRIMES:
This is Chris Grimes.
I will attempt 5
to field that in context.
I think that that is going to be 6
implicit in our resolution of the scoping issue in terms of
.7 how they have applied -- how they have used this suite of 8
events in order to make sure that they capture all the 9
intended functions, and then from that you get all of the 10 systems, structures and components that are subject to 11 license renewal, and so we attacked it from the other end.
12 We are going to make sure that we cover all of the 13 appropriate systems, structures and components irrespective 14 of whether or not the quality assurance system designates
( )
15 them as Class II or III or some other class.
16 CHAIRMAN BONACA:
The only reason I asked that 17.
question is that in fact you confirmed that there are 18 different criteria being applied for fatigue analysis 19 monitoring to Class II and III.
All right, I understand.
20 I have no further questions.
Any other questions from 21 members?
22
[No response.]
23 CHAIRMAN BONACA:
Thank you.
24 MR. GRIMES:
Thank you.
25 CHAIRMAN BONACA:
Does this complete your
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presentation?
{}
2 MR. GRIMES:
That 's correct, Mr. Bonaca.
That 3
completes the Staff's presentation and I'd be pleased to 4
entertain any questions you might have or any instructions 5
you might have about how we can prepare for the full 6
committee and what information you found most interesting 7
and would like us to present there.
8 CHAIRMAN BONACA:
Okay.
A couple of things.
9 First of all, regarding the afternoon meeting, 10 there has been a request from the Staff that we view or 11 attend the address from the Chairman.
12 MR. GRIMES:
That is correct.
13 CHAIRMAN BONACA:
And that is at one o' clock, 14 which means it would push back a little bit the other
()
15 presentations we have scheduled, you know.
To the degree to 16 which we can accommodate that we will accommodate it.
17 DR. KRESS:
We can view that on this screen.
18 CHAIRMAN BONACA:
Yes, they have got it on the i
19 screen now.
The only thing I wanted to make sure is that if 20 this lasts a very long time that bump into some of the 21' schedules of some of the members.
They have travel later in 22 the day, so we will try to monitor that.
1 23 The intent is to see this address from the i
24 Chairman and then to get'into the meeti'ag no later than 2:00 25 p.m. and then to try to contain those presentations within ANN RILEY & ASSOCIATES, LTD.
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the one hour and 45 minutes that we have scheduled for 2
those.
We will try to do that.
3 Second,-now regarding the items for the September, 4
1999 ACRS meeting, I understand that is when you are going 5
to'have the actual presentations from the Staff.
6 It seems to us that there should be a brief 7
presentation from Oconee, maybe 20 minutes, and I think that 8-a summary of the more significant points from your 9
presentation-that you had yesterday that simply -- I thought 10-it was a very well put-together presentation and I think 11 some highlights of the approach you took, particularly where
-12 it differed from the BG&E applications for Calvert Cliffs, 13 that the committee is familiar with, it would be helpful 14 because I think you proposed a new process or a different (Oj 15 approach.
That is my thoughts about what would be useful 16 and also will provide the full committee with an 17 introduction to the Oconee stuff to do.
18 Second, for the Staff I think it would be 19 important for us to have a summary of the results of the 20 Staff's evaluation of BAW-2251, reactor vessel and 21 associated evaluations, a discussion of open items 22 associated with identified program weaknesses or 23
. controversial.
I wouldn't go into every open item.
I would l
24 just focus on those which have to do with programmatic 25
~ issues, open issues, and also an identification of maybe
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unique plant configurations that have made the review of
'2 Oconee unique, different from -- so that would tend to bring 3
to the ACRS lessons learned.
These are just some thoughts.
4 DR. UHRIG:
Will we have a session later on where 5-the Staff will present'a comparison of the two and what they 6
are going to recommend in terms of the future applicants, 7
this type of thing?
8 MR. GRIMES:
At this point we are continuing to 9
work with NEI to try to get the industry to choose on a 10 preferred format for the application.
We have provided the 11 industry with an explanation of what is convenient for the i
,12 Staff,.what will help us, and now we are trying to get them 13 to. achieve a consensus on how the industry wants to package 14-the application most effectively and efficiently.
t 15 Then we are going to move from there into a plan 16 for' conforming and updating the standard review plan and 17 continue to work with NEI for them to incorporate the 18.
resolution of the generic renewal issues into NEI'95-10, but 19 at this point we are not trying to say that we prefer one 20 thing or the other, and as a matter of fact I invite the 21 committee to offer us any suggestions you have about what 22 works we.
Jor you that we could roll into that dialogue.
23 DR. UHRIG:
Do you have a time schedule on the 24 decision?- Is it a month or three months or six months away?
i 25 MR. GRIMES:
It is probably a month or so.
We are l
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going to have a meeting in July.
I think by the time of the l\\'
2.
.V September full committee meeting we should be able to report 3
on where we stand.
-4 CHAIRMAN BONACA:
We discussed about a month ago 5
the possibility of having in fact a subcommittee meeting 6
with the Staff, just to look at lessons learned.
That may 1
7 be something we want to schedule at a later time for the 8
subcommittee.
9 DR..UHRIG:
That would be before the September 10 meeting?
11 CHAIRMAN BONACA:
No.
I don't~think it can be 12 done that way.
It would be more after the September meeting 13 because it would be really more focusing on the SRP and 14 lessons learned for process improvement.
(A) 15 DR. KRESS:
I think it would be nice if the Staff 16 could be sure to focus on some of the items we might want to 17 include in our interim letter.
It would behoove us to try 18 to identify those.
19 CHAIRMAN BONACA:
Yes.
20 DR. KRESS:
They might also, you know -- it would I
21 be an incomplete list probably, and they may want to think 22 about what they think might be an interim letter also.
l 23 CHAIRMAN BONACA:
I think at this point we could 24 talk about some of these items now.
J 25 DR. KRESS:
Because we are going to put them in l
1 l
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the letter.
The full committee needs to debate them and
{
/'
2 hear about them.
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CHAIRMAN BONACA:
Sure.
Do you want to move on to f
4 discuss that now?
5 DR, KRESS:
Of course, we can't do anything on the 6
existing program.
'7 DR. SEALE:
The September meeting presentation?
8 MR. GRIMES:
-- sir, I think I understand what you 9
want.
We are going to go through and we are going to screen 10 the open itetas and confirmatory items to pick out the ones 11 that are programmatic and we'll have a Staff presentation on 12 that.
We will also provide you with an update of what 13 progress has been made since the subcommittee relative to 14 how we came up with that set of open items.
()
15 CHAIRMAN BONACA:
Before we move on to this 16 discussion of the interim letter, let's just talk about the 17 logistics for the July meeting.
18 We are going to have a presentation on credit for 19 existing programs.
It is on the schedule, and that is 20 pretty simple.
I think that this should be almost a 21-repetition of what we are going to hear today.
22 We will have essentially from Staff presentation 23 of the proposed options and NEI will provide a summary of 24 it's proposed approach.
25 MR. GRIMES:
That is about the same time on the
[~'
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full committee agenda?
It is 12:30 to 2:00, I believe?
/~')
2 CHAIRMAN BONACA:
Let's see -- correct.
It is one
\\s/
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and a half.
1 4
MR. GRIMES:
So it will be about the same 5
presentation as this afternoon.
6 CHAIRMAN BONACA:
And I think that would be of i
7 interest to the full committee.
8 DR. SEALE:
Will you wish to have us then write a 9
letter on that topic following that presentation or should 10 we wait until we hear a little bit more?
11 MR. GRIMES:
As I understand the timing of that 12
. issue, the Commission will hear the issue the day before the 13 full committee, and then the Commission is expecting a 14 letter from you because you said in your interim letter on ps,
( )
15 Calvert Cliffs that you wanted to review the issue, so I 16 think --
17 So the Commission is expecting you to write a 18 letter --
19 DR. SEALE:
So we should plan to have a letter 20-coming out of that meeting?
21 MR. GRIMES:
Yes, sir.
22 DR. SEALE:
Just wanted to confirm that.
23 CHAIRMAN BONACA:
Okay, so let's move on to 24 discuss some of the subjects to include in the interim 25 letter.
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You picked up a nu..eer of significant points from
()
2 the discussions we had over the two days.
Do you want to go 3
over those, to start with?
You can read them over and then
-4 we can further the discussion.
5 MR. DUDLEY:
There are points that came out of the 6
discussion at the end of yesterday's meeting.
I will just 7.
go ahead and go over the issue and then if chere's any
-8 discussion about what I was trying to capture, I think it 9
would be worthwhile to make sure that it is really what_the 10 committee was talking about, that it did not get garbled in 11 the translation.
12 Management consideration of past plant 13 performance, present risk profile and quality of assessment 14 process during the deliberation on renewing a license.
l
('Oj 15 MR. GRIMES:
I would suggest that rather than pick 16-on Duke in terms of the extent to which those things should 17 be considered and the process for deciding on a renewed I
18 license, I think you want us to focus on that at a more 19 policy level.
20 DR. KRESS:
That's a generic -- yes.
21 CHAIRMAN BONACA:
It's more of a generic issue, I l
22 agree with that.
23 DR. SEALE:
Yes.
24-MR. DUDLEY:
This is another generic issue that I L
25 don't know whether you,want to get involved in the letter --
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the importance of one-time inspections at a 40-year h
2-timeframe and an efficient and an-effective regulatory a
3 process to identify and mitigate emerging aging effects.
4 Again that is generic across the board, but an issue that 5
the committee seemed to be very concerned about.
6 DR. UHRIG:
Were there more one-time inspections 7
in the Duke application than were proposed in BG&E, or is it 8
about the same?
9 MR. GRIMES:
It's about the same.
(
10 DR. UHRIG:
Then it is a generic issne not 11 directly relative to Duke?
12' MR. GRIMES:
Well, not solely applicable to them.
13 DR. UHRIG:
That-is what I meant to say.
14 DR. KRESS:
I don't think the wording should be 15 "importance,of" here.
I think the words should be what are 16 the criteria for one-time inspection versus no inspection 17-or how periodic inspection is computed.
18 CHAIRMAN BONACA:
I think that -- I mean my 19 thought would be that the letter would discuss this issue, 20 because several of us have had some questions regarding this 21 one-time inspection that we must so preciously weigh when we 22 apply it and, you know, again it's a long future and it may 23 be totally adequate in some cases but still it is an issue 24 that seems to'be deserving consideration.
That is for sure.
25-
-MR. GRIMES:
Mr. Bonaca, from my perspective, I j
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look at how would I respond to you in terms of the action 2
that we would take on the Oconee safety evaluation, as 3
distinguished from the generic issues where I can address
~4 those as policy and process matters, and so in this case th 5
unique' thing about Oconee is that they proposed one-time 6
. inspections and they said they are going to complete them 7
before the end of the 40-year term, whereas Calvert was 8
already chomping at the bit to get them all completed so 9
' that they could have a clean new license.
10 So we know that we need to address the issue about 11 what is the appropriate time for a one-time inspection, but 12 we need to do'that in a generic way, and I don't know how I 13 would respond to you any differently.
-14 MR. DUDLEY:
This could be presented as an
()
15 observation by the committee on the Oconee license 16 application and approach?
17 DR. SEALE:
I guess my comment would be is the 18 committee prepared at this point to make a comment about the 19 relative desirability or merits of those two approaches?
If 20
. we are, maybe we'ought to say something.
If we are not, we 21 probably ought to wait'to hear what staff has to say so we 22 can second-guess them.
23
[ Laughter.)
24.
MR. GRIMES:
Which we are fully prepared for.
I 25
_ CHAIRMAN BONACA:
To me there are -- I mean my own
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thinking was, one, yes, we may express an opinion on whether
([ )
2 it should be done now or 40 years.
That is one issue.
3 The second one is in general the adequacy in all 4
cases of one-time inspection --
5 DR. SEALE:
Yes.
6 CHAIRMAN BONACA:
-- still lingers in my mind and
(
7 maybe I don't know enough about it but I certainly want I
8 to --
9 DR. SHACK:
Well, I think it's Tom's point that 10 sometimes one-time inspections are justified, sometimes 11 periodic inspections are, you know -- and what are the 12 criteria for choosing between them?
13 DR. KRESS:
How we decide, yes.
14 MR. GRIMES:
I would like to emphasize that on the I
15 Calvert Cliffs safety evaluation we specifically identified 16 a set of proposed one-time inspections which we said we 17 weren't satisfied that once was enough and that they ought 18 to be designated as periodic, and we'd leave it to decide 19 what the appropriate period is.
20 On the Oconee application we did not identify any 21 of the proposed one-time inspections that we felt warranted 22 such treatment.
We were prepared to support I am not 23 sure whether I want to say it that way -- we are prepared to 24 support once as good enough.
25 I think I would prefer to say we don't see the O
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need to try and justify establishing periodic inspection
()
2 requirements for thora particular things, and so that is the 3
way we have presented the Oconee safety evaluation to you 4
and now I am asking you to second-guess this if you see any
'5 one of those one-time inspections that crosses your 6-discomfort level to pass the threshold of writing it down 7
and I encourage you to put it in the letter and we'll 8
specifically decide whether or not we want to reconsider.
9 At least that way we clearly understand, both of 10 us, where we are going to.go with any of these particular 11 questions.
12 DR. SHACK:
Well, I don't see that we can't 13 consider both questions here, the more general one of need 14 for criteria and the specific instances in the Oconee case.
l) 15-MR. GRIMES:
Yes.
I fully intended that we would 16 continue to pursue the broader generic question about 17' criteria and the process aspect, and that is part of the 18 lessons learned that we have seen that became readily 19 apparent, but the'immediate need is for the purpose of an 20 interim letter on Oconee if there are any of the one-time 21 inspections which the Staff is saying we are prepared, 22 subject to resolution of the open and confirmatory items, to 23
. accept a one-time inspection that'may or may not result in a 24 need for further actions beyond that point, and so if any of 25 them cause you discomfort, then you should tell us that they ANN RILEY & ASSOCIATES, LTD.
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1 cause you discomfort'and then we will look at them harder.
2
.DR. SHACK:
-- or if we feel any are 3'
unnecessary --
q 4
MR. GRIMES:
Yes.
5
'We will contrast in the presentation this 6
afternoon -- we ran into a few of these existing program
)
7 areas where one applicant offered to do something and the 8
other applicant chose not to do something, and now we are 9
trying to' find what is the right regulatory line, where is 10 the balance.
11 So we have tried to do that.
We were conscious I
12 about consistency but fairness as we went through the Oconee 13 safety evaluation and to a certain extent that is reflected 14 in these'open items.
There were issues that came up that we A1]
15 identified as inconsistent treatment between the two 16 applicants and they ended up as open items on Oconee that 17 we'll have to reconcile.
18-DR. UHRIG:
But isn't that usually due to some 19' difference in the plants?
20 MR. GRIMES:
No.
21 DR. UHRIG:
No?
22 MR.- GRIMES:
In this instance --
23' DR. UHRIG:
Maybe it's not.
24 MR. GRIMES:
-- it was a matter of inconsistent 25 treatment with respect to' managing aging, not plant design
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differences -- like, you know, we didn't try and make sure
/
}
2 they were using exactly the same steam generator inspection 3
program, but we accounted for the fact that there are plant 4
design differences, but past that we-saw that there were 5
different treatments of aging effects that are applicable to i
6 both plants.
7 CHAIRMAN BONACA:
Okay.
I think we understand 8
where we have to go.
Still, I mean I think we will have to 9
discuss this issue of inspections because I think it's a 10 critical item.
I mean in part, from what I understand, the 11 inspections'oftentimes are driven also be the accessibility 12 to certain components irrespective of whether.or not you 13 have a bigger concern in a certain area.
Since it is 14 inaccessible you limit they way you look at it and you
()
15 emphasize some of those where it is easy to access, and this 16 Lbecomes more of a concern as the plant ages because you are 17 not seeing -- so, anyway, we will have to look at it 18 ourselves as a committee and when we think about the issue 19 of inspections in general.
20 I wasn't impressed, I must say, about the issue of 21 the oil collection system on the pumps because it tells me 22 that there wasn't a plan to i-epect and then we will have
'xtended the life with just one inspection and yet that is 23 e
24 certainly a source of fire concern inside the plant.
25 MR. DUDLEY:
Another issue that the members C
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discussed yesterday was an unsettling feeling about how to
)
2 handle emerging events, and that is the next bullet there, 3
that there be increased pressure on the regulatory process 4'
to identify and mitigate emerging aging mechanisms.
5 DR. KRESS:
Of course, that could be part of the 6
inspection.
The staff can address that particular issue.
7 That may be a point that we want to emphasize, how important 8-the inspection program is again.
We did that with the other 9
letter, and that is one of the reasons.
So this is actually 10 a carryover from our interim letter on Calvert Cliffs, I 11 believe.
12 MR. DUDLEY:
Okay.
13 DR. SEALE:
Yeah.
14 MR. DUDLEY.
The next bullet is more specific.
()
15 Appropriate treatment for addressing the possibility of void 16 swelling and core shroud bolts.
17 MR. GRIMES:
It is void swelling for reactor 18 vessel internals.
The core shroud bolts was a BG&E issue.
19 MR. DUDLEY:
Okay.
20 MR. GRIMES:
And'Framatone commented specifically 21 yesterday that void swelling is an interesting research 22 project.
We explained that we could not conclude that is --
23 we couldn't dismiss it as an aging effect, and this is one 24 where we are on the ragged edge of -- are we chasing a ghost 25 or not?
But we couldn't dismiss it and so we are going to ANN RILEY & ASSOCIATES, LTD.
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address it.
And if you have a view about whether or not
( )
2 this is not worth chasing, or worth chasing, you can share 3
that with us.
4 CHAIRMAN BONACA:
This issue very much depends on 5-whether the routine inspections that are performed of 6
internals would detect swelling in all locations where it 7
may be significant and important.
I can't answer that 8
question by myself.
Certain areas will be accessible.
9 MR. GRIMES:
Yes.
The nature of the controversy 10 is we have not see it.
We don't expect to see it.
You 11 haven't proven that it is something that is worth 12 inspecting, and we can't prove it is something that won't 13 happen, and therein lies the dilemma.
And, certainly, we 14 are going to -- as Barry explained a little bit earlier, we
()
15 are going to continue to pursue the broader generic, you 16 know, vessel internal program activities, and that this 17 issue would probably e:v
.lly work itself out there.
18 But in the meantime, we have to make a decision 19 about whether or not this is an applicable aging effect, and 20 we could not conclude that we could dismiss it based on what 21 we don't know, which is essentially where we stand today.
22 The industry has the view that says there isn't sufficient 23 evidence that it isn't -- it warrants concerns, and why 24 don't you go put it in a research program.
25 DR. SHACK:
I mean there is also the question of
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whether,'in fact, it warrants any action beyond what you
-t 2
need to address the degradation mechanisms that you are more
(
3' confident are active.
4 MR. GRIMES:
Yes.
5 DR. SHACK:
That'if you -- you know, if you are 6
' inspecting for IASCC, you know, will you -- you know, is 7
there something unique about void swelling that you are not 8
going to detect in your other inspection programs?
You
'9 know, does it really need to be singled out.
10-
.MR. GRIMES:
Yes.
But that would entail the 11' applicant and/or the staff going to che trouble of trying to 12 articulate the basis upon which a program that has not yet 13 been developed, that is predicated on random sampling of 14 particular locations in the vessel internals, might be (A,)
15 attentive to the potential void swelling phenomena that we 16 don't understand.
So it is -- you know, that still entails 17
'some work.
~18 DR. SHACK:
Ik), but to the extent that all these 19 degradation mechanisms are involved with high fluence 20 components, --
21 MR. GRIMES:
Yes.
'22 DR. SHACK:
-- you know, you are looking --
23 MR. GRIMES:
Or you are trying.
24 DR. SHACK:
-- for various reasons at sort of
-25 similar places.
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MR. GRIMES:
Yeah.
We could and put together an
,,\\
2 argument that says, no, we can't dismiss it, whatever it is, t'\\~)
3 and wherever it might occur, bounded by the high fluence and 4
the high fluence. region.
5 MR. DUDLEY:
The last bullet --
6 CHAIRMAN BONACA:
One thing that -- yeah, just to 7
complete at least what I am wrestling with is, if you look 8
at the area of high fluence, and below, that happens to be 9
the area which is very hard to inspect.
Okay.
So we do 10 have, you know, I think the B&W topical report was a very 11 good report in my judgment, but much of is analytical and it 12 is extrapolation to project that there will be no problems 13 to the 60 year life.
14 I am trying to understand the relationship between f
15 inspections which are difficult to make below the beltline 16 and inside the reactor, and the issue of swelling.
You 17 know, these are two issued we discussed, one is inspections 18 and the other -- and I don't know if we know enough or if 19 there is anything else that should be done.
20 Anyway, that is more something I am wrestling 21 with.
22 MR. DUDLEY:
Well, certainly, the one thing that 23 is left off your list on the items to include in the interim 24 letter is the nice compliment you gave us in a BGE letter 25 about what a wonderful job the staff did.
[)
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1 DR. KRESS:
Yeah, definitely.
(
2 CHAIRMAN BONACA:
It hasn't been typed yet.
-3 MR. GRIMES:
I just want to make sure you don't 4
lose an important detail.
j 5
(Laughter.)
6 DR. KRESS:
Well, there are some other items I
.7 would add to this list we have, too.
I would add the fuses, 8
active versus passive components.
9 CHAIRMAN BONACA:
Yes.
10 DR. KRESS:
I would probably add something about 11 rack life, some sort of validation, acceptance.
I would --
12 and as part of that, I would include the 60 years versus 13 longer for boraflex because of the spent fuel pool, and that 14 is going to go on longer.
And the fact that they have got
()
15 an interim dry storage facility helps that a lot, 16 I probably would add something on trendline, 17 utility of the trendline for tendon prestressing.
And I j
18 would probably go along with you on your oil collection j
19 inspection.
1 20 CHAIRMAN BONACA:
What about GSI-190, any thoughts 21 about it?
22_
DR. KRESS:
I don't know, ask Bob.
23 DR. SEALE:
Well, you know, we are beating a dead 24' horse in a way.
It is not really an item that these guys 25 have a lot to do with at this point.
On the other hand, O
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they are interconnected and consistency is ultimately --
[
2 well, let's say if they are not consistent between what the 3
ultimate resolution on 190 is and the effect of the 4
treatment on the license renewal, it is going to be a source 5
of real embarrassment.
6 So what we may be in the process of doing is
~
7 resolving 190 without an important subset of the people that 8
are involved being here.
Because what you come up with is 9
something that is going to have to be within the ultimate 10 resolution of 190.
And I guess it might be worthwhile
.11 saying something to the Commissioners to the effect that we 12 really ought to try to push to make sure that there is 13 consistency with what comes out of this review and what the 14 ultimate disposition of 190 is.
()
15 MR. GRIMES:
Dr. Seale, we have attempted to build 16 that in by virtue of constructing a staff position that 17 basically says that there is a feasibility to account for 18 these environmental effects of fatigue by virtue of either 11 9 monitoring or reanalysis.
And in either case, those 20 approaches can replaced.with a generic resolution that says 21 you' don't need to do anything more.
~22 So in that way we have tried to make sure that we 23 don't slam the door or misdirect the solution of the 24 problem.
25 I think-the frustration that the industry has, has
(}
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had ever since ALAB 444 said you have got to address how f
i 2
unresolved generic issues are going to be resolved, is the time and effort that they have to expend explaining how they 3
4 will solve it when it gets solved.
5 DR. SEALE:
And then you come along and say, well, 6
there is always the possibility we will say there is
'7 no-never-mind after all because it is a generic resolution.
8 MR. GRIMES:
Yes, but that is --
9 DR. SEALE:
And that just makes the frustration 10 even more acute.
11 MR. GRIMES:
Yes.
12 DR. SEALE:
So all I am saying is if we can get 13 there, we ought to-try to.
14 MR. GRIMES:
Yes.
And we will agree.
We will
()
15 simply say we would like that solution as much as the 16 industry.
17 DR. SEALE:
So I think now we ought to craft 18
.something on 190.
19-DR. KRESS:
At this point I don't see anything in 20 our interim letter that is sufficient magnitude to consider 21 the derailment of this process of licensing.
I don't see 22 anything that is really earthshaking in what these are 23 just -- most of them are sort of generic like issues for the 24 lessons learned as we go on, I think.
25 DR. SEALE:
Well, you expect the first two to be t
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pretty rich in that area.
['T 2
DR. SHACK:
Except maybe for the scope issue.
{
\\-)
{
3 DR. KRESS:
Scope is the only one.
But, you know, j
\\
4 that is an item that 5
CHAIRMAN BONACA:
Yeah, I think still we should
{
1 6
put something about maybe the scope issue, because it is 1
j t
7 still open.
Most of all because it is going to be an item 8
that may occur again, it will occur again.
I 9
One thing that, you know, I feel -- again, I noted 10 yesterday, I was impressed by looking at how many programs 1
11 are in place now, that have been put in place at the plants 12 in the past 10 years.
13 DR. KRESS:
That is impressive.
14 CHAIRMAN BONACA:
And such that almost the -- you p) 15 know, plants are positioned right now for license renewal
(
16 because they have these problems.
And, you know, when you 17 begin to make a head count, identification of the programs, 18 you realize what kind of -- you know, how much the plants 19 have grown in the past ten years.
20 Clearly, the Maintenance Rule and preventive 21 maintenance and things like that have helped there.
But 22 that is an observation that we may want to consider.
23 DR. KRESS:
Be careful.
We will have to pull out 24 our shot to clear in that area.
25
[ Laughter.]
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1 MR. GRIMES:
Actually, I would like to suggest you
[)
2
-- that is a thought you really want to include in the V
3-response to the existing program issued to the Commission, 4
because that at least sets the stage for -- for why do we
)
5 need to do anything more for license renewal?
Which is the j
6 fundamental' question.
7 CHAIRMAN BONACA:
Well, I am not sure how much it
{
8 goes into that issue in my mind.
The question is how 9
applicable is'this explanation so we can get to hear that.
10.
Any other thoughts about
~11 (No response.]
12 CHAIRMAN BONACA:
Well, that is pretty much what 13 right now it seems like.
But we meet in two weeks anyway, 14 and I think we will have an opportunity to talk about it
()
15 again, that letter.
16 Okay.
Any other comments?
Points from anyone?
17
'Are we done with this?
I think we are.
18 MR. DUDLEY:
We are.
19 CHAIRMAN BONACA:
So, in that case, I think we are 20 going to take a long recess here.
We are going to adjourn 21 the meeting for the time being.
22 DR. SEALE:
Recess.
I 23 CHAIRMAN BONACA:
Recess.
Thank you.
We are 24 going to recess the meeting until 1:00, and at 1:00 we will 25
.be here, we will give the address to the Commissioner -- or
[~))
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the Chairman.
2 MR. GRIMES:
The staff will come here at 1:00.
3' CHAIRMAN BONACA:
Yeah.
4-MR. GRIMES:
Mr. Matthews and some others who 5
~ wanted to attend are going to be in the Commission hearing 1
6 room, 'but we will let them know that as soon as the 7
Chairman's address is completed, that we will begin the 8
staff presentation on the existing program issue.
9 CHAIRMAN.BONACA:
Okay.
Thank you.
With that, we 10 will'take recess now until 1:00 p.m.
11
[Whereupon, at 11:25 a.m.,
the meeting was 12 recessed, to reconvene at 1:12 p.m.,
this same day.]
13 14 V) 15 16 17 18 19 20 21 22 23-24 25 f',/s ANN RILEY & ASSOCIATES, LTD.
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t 1-AFTERNOON SESSION 2
(1:12 p.m. ]
3 CHAIRMAN BONACA:
We are resuming the meeting of 4
the Subcommittee on Plant License Renewal, and for this
-5 afternoon we have two presentations, one from the NRC staff 6
regarding options for crediting existing programs, and then we_will have a follow-up presentation on the same subject by 7
8 NEI.
So with that, I turn to Mr. Christopher Grimes.
9 MR. GRIMES:
Thank you.
As you know, on June 3rd 10 oof this year, the staff sent a memorandum to the Commission 11 on a policy issue associated with credit *ng existing 12 programs for the purpose of the license renewal review, and 13 this paper was stimulated by issues that were raised going 14 back to a January Commission meeting on regulatory
_(
15 improvements concerning the scope and depth of the staff's 16 reviews and the basis for developing findings related to the 17 demonstration of effectiveness of aging management programs.
18 And that issue is described as best we could in SECY-99-148.
19 And so we are going to basically summarize the 20 material covered in that Commission paper and present the 21 basis for the' staff's recommendation on how to treat this 22 matter for the purpose of at least in the ongoing -- or 23 excuse me, the current generation of license renewal 24 applications.
25' And the presentation is going to be made by Dr.
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Sam Lee, who is a Senior Materials Engineering in the
~/T 2
' License Renewal and Standardization Branch.
He bi gs to
. V 3
bear-a. wealth-of experience in the development of the 4
Standard Review Plan, as well as the review of the industry 5
reports related to aging management programs 6
DR. KRESS:
Are we talking about programs that'are both required by.the regulations and voluntary also?
7-8~
MR. GRIMES - We are going to explain that in the 9
. context-of the scope of the rule.
10 DR. LEE:
Like Chris indicated, my name is Sam 11 Lee, I am from the License Renewal and Standardization 12 Branch.
I am going to talk to you about the issue of credit 4
13' for existing programs for license renewal.
14 Okay.
This is'the issue statement.
To what
(
1
()
15 extent should the staff review the existing programs relied 16 on by the license renewal applicant to manage aging for 17 license renewal?
And NEI submitted letters in March and in 18 May on this issue,and NRC license renewal steering 19 committee have met with NEI to discuss, and NEI is going to 20 make a separate presentation after the staff's presentation 21-today.
And this is the issue the way we understand it.
22 DR. KRESS:
Just to what extent you should review
. 23 these programs?
. 24 DR. LEE:
That's correct.
That's the way we 25 understand'it.
And NEI indicates that existing programs are i
/^
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1 subject to the regulatory oversight and NRC inspections, and 2
(V the staff should not review existing programs for license 3
renewal to any extent.
And the staff has evaluated this issue'and have prepared SECY paper 99-148 to discuss options 4
5-an'd we made a recommendation, and that is the subject of 6
today's presentation.
7 MR. GRIMES:
Sam, before you leave that slide, I 8
would also like to emphasize that we are going to use the 9
term " manage aging effects" or " aging management" in a 10 shorthand way and it will represent this statement that 11 talks about reasonable assurance that programs will be 12 effective in managing the effects of aging on functionality 13 of structure systems and components for the period of 14
-extended operation.
()
15 It is hard for us to say that over and over again, 16 but it has to be understood that it is in that context that 17 we talk about aging management.
18 DR. LEE:
During the license rulemaking the 19 Commission determined.that license renewal is based on two 20 fundamental principles.
And the principles says the process 21 is adequate and the current license basis will carry forward 22 into license renewal, with an important exception, which is R23 the effects of aging on function of equipment in the period 24 of extended operation.
Basically, aging management, like 25 Chris indicated, this is a long -- long term, but it is i
/ _
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basically aging management.
(~v}
2 DR. KRESS:
Is that quoted directed out of the 3
statements of consideration?
4 DR. LEE:
Yeah, this is quoted right from the SOC 5
except I truncated it, it goes on a little about safety and
{
6 public defense and all of that over here.
And then there is 7
a little more about, to the same extent, about the -- you
-8 know, regarding the current operating term.
So it is a 9
little abbreviated.
10 So, based on the principle, now the license 11 renewal rule focuses on aging management.
And in the 12 rulemaking, the Commission determined that the functions are 13 active and are E,hort-lived, the equipment is assured by the 14 existing process and existing programs, and they are not
[mv) 15 subject to aging management review for license renewal.
So 16 the Commission took this off the table.
17 But then the Commission also said that for the 18 aging effects on the passive long-lived structures and I
19 components are less apparent and they are less monitoring 20 experience with'this equipment.
So the Commission said the 21 license renewal rule requires an aging management of 22 passive, long-lived structures and components.
23 And if you look at the SOC, it will talk -- it 24 will have places where talk about the process is adequate, 25 the existing program is adequate.
But if you look into it,
/~'\\
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it regards the active or short-lived structures and
[)
2 components.
LJ 3
Based on the rule, this is what the staff sees its 4
jobs to be, is to review the applicant's demonstration that 5
aging is being managed for passive and long-lived structures 6
and components.
And to do this, the staff, reviewed the 7
programs relied on by the license renewal applicant to 8
manage aging, and that includes existing programs.
9 But when the staff review existing programs we 10 find additional activities need to be performed for the 11 license renewal period, for the period of extended 12 operation, which is between 40 and 60 years, which are not 13 required for 0 to 40.
14 This creates a logic situation, where some f( J) 15 activities are required after 40 years, but not required for x.
1C the first 40.
However, aging is a continuous process.
So, 17 there is a little discontinuity there based on the review.
18 And I will show you some examples of what we found 19 in terms of the aging management program's activities.
20 These are the aging management programs identified by the 21 first two license renewal applicants.
22 This is Calvert Cliffs, this is Oconee, and this 23 is a pie chart of the aging management's programs activities 24 that the applicant's rely on for license renewal.
And this 25 piece here is the existing program, 70 percent.
So for f)
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Calvert. Cliffs, about 70 percent of existing programs do not 2
require any. modification for license renewal.
- However, 3
'there-lie 30 percent, they represent existing programs that 4
need to be modified or new programs.
5 And for Oconee, the numbers are 60 percent or so 6
for existing program that don't require modification, and 7
about 40 percent;of. programs that require modification or 8
new programs.
The numbers inside the pie chart, these are 9
the actual kind of programs activities and you will see that 10 they kind of, you know, differ quite a bit from plant to 11 plant.
12
~It is because in part Calvert Cliffs counts a lot 13 of procedures and Oconee tends to count at a high level in 14 terms of programs.
So you see a high count from Calvert
()
15 Cliffs.
And another thing I see is when certain things are
~ 16 -
identified for -- in terms of aging management for license 17-renewal, Calvert Cliffs tends to modify existing programs to 18 address those issues.
So you see a bigger chunk'of modified 19 existing programs, a small chunk of new programs.
But go to 20 Oconee, whenLthey fact the same situation, they tend to call 21 them new programs.
They tend -- but which is -- it is a 22
- matter of how, you know, whicn bin you put it into.
23 But if you look at this, there are several 24
. observations you can make.
The first observation is most of 25-the programs, almost all the programs relied to manage aging (O
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for license renewal are existing programs.
That is one
()
2 observation.
And the other observation is that there are 3
.about 30 percent or 40 percent of the programs, exAsting 4
programs that require some modification or new program.
5
.This is the contribution of_the license renewal effort.
And 6
there is, however, there is 70 percent over here on this 7
side.
These are existing programs that do not require any 8
modification.
Okay.
So, but to get to this 30 percent, you 9
-have 5 0 review the whole, to decide, you know, which is the 10 30 percent.
11 MR. GRIMES:
Sam, I would also like to point out 12 that yesterday, you know, Mike Tuchman raised the point 13 about some of their new programs are one time inspections, 14 and they contrast very differently in terms of one program
()
15 may be something that is done on a daily basis over the life 16 of the plant, and, you know, these license renewal 17 activities may be one time inspection during the entire life 18 of the plant or a 60 year period.
19 So, trying to count programs can be misleading if 20 you don't understand what you are counting.
21 And one other thing that I want to emphasize is
.2 that these program counts do not align themselves to systems 2
23 or structures or components, or aging effects.
What 24 constitutes an existing program for the purpose of taking 25 credit for managing effects means_different things to
("'/
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different people, and by itself is a difficult thing to f
2-articulate.
N
'3 DR. LEE:
From now I will use numbers like 30 4
percent, I will mean the chunk here, and then 70 percent l
5 will be the existing program that do not require 6
modil.ication.
q 7
Here are some of the examples of acceptable 8
programs we found from the Calvert Cliffs and Oconee review.
9 We put it in the three categories, the existing program not 10 requiring modification, existing programs requiring 11 modification, and new programs.
12 After we reviewed the application, okay, we found 13 programs that are acceptable without modification.
And EQ 14 is a particular example.
In this case we have extensive
(]
15 interaction with the applicants.
We have asked for 16 additional information and they have submitted it.
And then 17 we look into that program into great detail, and then we l
18 finally came to the conclusion EQ program would manage aging 19 for license renewal.
And there are other examples, and I 20 will go into this in more detail in the next couple of 21 slides.
22 Some of these existing programs require 23 modification, just simple administrative controls.
That is 24 programs are not formally controlled, they are just modified 25 to be controlled.
But I will show you some other more G
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technical programs here.
3
(~D 2
Okay.
This is the small bore piping example.
In u-)
3 the inservice inspection program, the ASME does not specify inspection for small bore piping for internal cracking.
And 4
5 there is ongoing industry initiative to address this issue, 6
and the code has activities going on, and the staff had 3
7 generic activities going on to try to address that.
And in i
k 8
particular, some of the staff activity related to the high j
9 pressure injection line crack due to thermal fatigue.
l 10 In license renewal, we are looking for a program 11 to manage aging for the equipment.
So in this case we have 12 small bore piping and there is no existing program that 13 would -- the existing program does not really address that.
i 14 So we asked the applicants to provide us a program so that
/~%
( )
15 we can determine that the cracking of the small bore piping j
1 16 would be managed.
17 And one applicant proposed a one time inspection 18 to verify that that the integrity of the small bore piping 19 will be maintained and the staff has accepted that, and we 20 are resolving this open item with the other applicant.
21 These are examples on the reactor vessel 22-internals.
The code does not specify inspection of the
{
23 internals to detect cracking and there are ongoing 24 activities, especially at the boiling water reactor owners 25 group, the BWR owners group.
They have a very active
{"'
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program to address the internals, but in this case the staff
(
)
2-needed to determine how the internal cracking will be 3
managed, so the staff has proposed a program similar to the 4
owners group to managing aging, and we are resolving the i
5 open item with the applicants.
6 And our example is the pressurizing, the inside of 4
7 the pressurizer is cladded and their operating experience at I
8 one sight that it could crack and penetrate into the base 9
metal.
And Section XI does specify inspection for the 10 cladding for cracks.
So both applicants have proposed a one 11 time inspection for the cladding and the staff has accepted 12 that.
13 This is the reactor vessel surveillance program to 14 monitor the extent of neutron embrittlement of the vessel
()
15 and Appendix H and 50.60 requires monitoring, and it 16 references a standard.
However, the standard is designed j
17 for 40 year plant operation.
It says you put so many 18 capsules, you take them out at certain times, but they all 19 key into 40 years of operation.
20 So both applicants have proposed modifying the 21 surveillance program to collect data through 60 years of 22 fluence and the staff has accepted that.
23 Here is an example of a new program.
Buried 24 piping coated and they are wrapped in protective, I guess, 22 adhesive tape before they are buried, however, they might O
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still be subject to corrosion.
So one applicant has
/
2 proposed to sample some locations by actually digging up the
- 3 buried pipe to look at how good is the coating, the 4
wrapping, and the we are resolving the open item with 5
another applicant.
6 So, based on what we looked at in terms of pie 7
chart before, there are like 70 -- actually, almost all the 8
programs are existing programs for license renewal.
Okay.
9 So, there is efficiencies to be gained in the license 10 renewal process if we can credit existing programs.
So the 11 staff and industry'are in agreement in terms of somehow 12 providing credit for existing programs to improve the 13 process.
14 In SECY-99-148, the staff described three options.
(')
15 Okay.
The first option is the staff would not review 16 existing programs.
NEI indicates that this option is 17 consistent with the rule.
However, the staff believes that 18 this option does not give us a basis for concluding that 19 action should be taken to manage the effects of aging.
So 20-because of this option, the staff believes you need a rule 21 change.
22 Okay.
Under this option the staff would rely on 23 the current record of the process.
24 DR. SHACK:
Does OGC concur with that opinion?
25 DR. LEE:
That is OGC's opinion.
I have OGC C,
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present if you want to direct questions.
A 2
DR. KRESS:
The whole department?
U 3
[ Laughter.]
4 MS. MOORE:
OGC does concur with that.
It is our 5
opinion.
6 DR. LEE:
That is Janice Moore from OGC.
7 So we go with this option, then we will be relying 8
on the current record of the process to address the 30 9
percent, so to speak.
Okay.
And if we do it this way, then 10 one of the things that we have is that we would have removed 11 the discontinuity at year 40.
Okay.
So we go -- so we 12 identify issues in the operating reactor, you just carry i
13 forward into license renewal, so it is just a continuous 14 process, no discontinuity of, you know, new aging management t
15 programs that suddenly appears at 40, at year 40 with this 16 option.
17 Under this option --
18 DR. SHACK:
In this case all potential new aging 19 management programs would have to go through the backfit 20 rule?
22 DR. LEE:
That is correct, in the zero to 40 22 years.
If we identify issue like -- take small bore piping.
j 23 Okay.
If the staff decides to have a one time inspection 24 for small bore piping because there are cracks, or potential 25 for cracking, that may go for a backfit analysis for 0 to O
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40.
Okay.
To make our opening, we have to do it, and then
)
we will carry that into the license renewal period as part 2
3' of CLB, the current licensing basis.
4 The other way we are doing it for license renewal 5
is we identified for year 40 and beyond and then we do 6
backfit.the other way to set -- tend to inspect small bore 7
piping for 0 to 40.
8 Under the option the applicant will identify a 9
component and then they will state the existing program.
10 But then the staff would not review their existing program.
11 Okay.
So in the application, the applicant would still say 12, here is a component, it is subject to aging, and here is the 13 existing program, okay, but the staff is not to challenge 14 that program.
()
15 And we said earlier is there are 30 percent of 16 these additional activities.
Okay.
Under this option, you 17 might not get there, for license renewal, under the license 18 renewal review.
Okay.
You will try to get it through the 19 process for 0 to 40 and then carry forward into license 20 renewal.
21 Okay.
With this option, okay, I think we would 22 significantly reduce the staff and the applicant's effort, I
23 the burden for the license renewal review, because the great 24 majority of programs, existing programs, the staff would not 25 review it.
There won't be much left for license renewal
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review, so the burden would be greatly reduced.
- However, d(~'\\
2 now you are relying on the regulatory process to catch up 3
with aging effects and management, and the process, the 4
regulatory process is more reactive, so you want for 5
something to fail or degrade and then you take backfit 6
action to try to address that, and then you carry that into
-7 license renewal.
So you might not get all 30 percent that 8
is I indicate.
9 The second option is to actually amend the rule, 10 to exclude structures and components subject to existing i
11 program from the rule itself.
So you go to rulemaking and 12 clearly state that if you have a component that is subject 13 to existing program, and the rule it defines what they are, 14 and then they are out of the scope of license renewal or
(
15 they are not subject to aging management review.
I 16 So if you contrast these with option one, option i
17 one the applicant in the application would say I have these 18 components and'they are subject to aging, these aging 19 effects, and here is my existing program, okay, in the 20 application.
The staff does not review it, but in the 21 application, they still say that.
22 In here, Option 2, the applicant does not say that 23 because that component is subject to the existing program, 24 so they are not in the scope of the rule or they are not 25 subject to aging management review for license renewal.
So O
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312 if the" staff is not to review the existing program anyway, 1
2 why do we need the applicant to send it in?
So Option 2 3
just said don't even bother sending it in.
<4 Here is Option 3 and this is the staff recommended 5
' approach.
We will focus the guidance in the Standard Review 6-Plan for license renewal and with this option we don't need 7
a rule change, and the Standard Review Plan will focus on 8
the 30 percent.
There is no benefit gained repeatedly, you 9
know, reviewing that 70 percent, going over every plant that 10 comes in.
11 And then based on the lessons learned and then we 12 are going to improve the Standard Review Plan.
Okay.
This
-13 is more like as we learn, we built in more efficiency.
We 14 put all that.into the Standard Review Plan.
And we will 15 involve the public in terms of developing the Standard 16 Review Plan and all the supporting documents so people know, 17 you know, where we are coming out and they can participate.
18 The staff has started called a Generic Aging 19 Lessons Learned, GALL, it is to evaluate the existing i
20 program.
This is basically -- this is a generic evaluation 21 of the whole pie, if you remember the pie chart.
Okay.
And 22 it will come out and then they will say, okay, for this 70 2 3 --
percent, they will manage aging and here is the basis.
It 24 lists the evaluation.
And they will point out this is the 25 30 percent that you need some modification or new program, ANN RILEY & ASSOCIATES, LTD.
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and the Standard Review Plan will reference GALL and
/
2 actually provide guidance in terms of how to look at the 30 N-s\\
Y 3
percent.
Okay.
So the reviewer will not spend time on the 4
70 percent, other'than to check, make sure that the 5
applicant is actually referencing the relevant program.
6 In this way the safety is maintained with a 7
focused review for license renewal.
You actually look at 8
all the programs and then you go right after the 30 percent.
9 And this will reduce the unnecessary burden 10 because the staff focus is really on the 30 percent, not on 11 the 70 percent which will probably come out okay anyway.
12 And then the GALL report and SRP will point out where you 13
.need to augment or the 30 percent.
With this option you 14 have the discontinuity at year 40, okay, because you do
-(
)
15 identify 30 percent of the programs are such that need 16
, additional activities after year 40.
Okay.
And then we
[
17 have to deal with that in terms of backfit to see what we 18 want to do between 0 and 40.
- Okay, So that is a q
19 distinction between this and Options 1 and 2.
20 We just want to show you a page of the draft GALL i
21' report.
This is in your handout but you can read it.
But I
)
22 just wanted to indicate what was going on here.
Here we 23 start with a component, in this case is the reactor coolant 24-pump, and then the aging effect is loss of material due to 25.
boracic erosion and the existing program is the applicant's
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response to NRC Generic Letter 88-05.
And the staff has
(
2 gone through and reviewed the attributes of the program in 3
accordance with Generic Letter 88-05, and then we match the 4
program attributes,.and then with the evaluation, this is 5-basically a generic evaluation of the program.
6 And then we come to a conclusion, say this 7
adequate and no further evaluation is needed.
So the intent 8
is to capture this in the Standard Review Plan.
So in the 9
Standard Review Plan, when you come to this component, that 10 aging effect, and if the applicant references this program, 11 there is no further evaluation needed.
12 However, he also shows in our component, this is 13 actually the same component, the pump, and the aging effect 14 is thermal aging of clad stainless steel and there is no
()
15 generic existing program.
So now you need to do further 16 evaluation.
So this is the -- in the 30 percent part.
17 Okay.
And the Standard Review Plan will lay out what you 18 would look for, okay, to manage thermal aging of clad 19 stainless steel.
20 Okay.
So the review effort would be up here and 21 not here.
So the 70 percent, the staff will not spend the 22 resources chasing after the 70 percent, but you will be 23 focusing on the 30 percent.
24 DR. KRESS:
There was no Option 4?
25 DR. LEE:
Right now?
Not in the SECY paper.
O)
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315 1-DR. KRESS:
To include that 70 percent if needed.
2 I mean that is a viable. option, isn't it?
3 DR. LEE:
Yes.
Yes.
We discussed that too, yes.
4 Basically, that is what we are
,m ng right now.
We are 5'
doing the -- for BG&E Oconee, we look at all the programs.
1 6
That is Option 4.
7 DR. KRESS:
You are looking at all of them, right 8
now for the specific ones.
9 DR. LEE:
Right now we are doing Option 4.
Yes.
10 Yeah.
For these two plants.
l 11 Okay.
Here is the staff recommendation and the i
12 staff will review the existing programs, okay, the whole 13 pie.
Okay.
And we believe this will maintain safety 14 because you look across all the programs and this is-15 workable because we already have done BG&E Oconee this way 16 and-it is workable.
1 17 And we recommend Option 3 to develop the GALL 18 report and improve the Standard Review Plan.
This will 19 focus the staff, you know, resources on the 30 percent where 1
20 you get most of the safety gain.
21-And right now we have done a B&W plant and we are 22 doing.a B&W and a CE plant, we will, and we still haven't 23 seen a border yet, and the other window.
So we suggested we 24 will revisit this issue after'we review more plants and we 25 will propose additional process efficiencies at that time.
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1So when we see opportunity.to improve and we will factor
()
2 that into the SRP, cover the learning process.
3 That concludes my presentation.
4 DR. KRESS:
In order to determine the 30 percent, 5
you have to review all the programs, decide which ones --
6 DR. LEE:
That's correct.
Yes.
7 DR. KRESS:
-- need modification?
8 DR. LEE:
Yeah.
And we are recommending do a 9
generic review through GALL to determine that.
10 DR~ KRESS:
You think you can do that with a
'11 generic review as opposed to plant-specific?
12 DR. LEE:
We think we can, for certain existing 13 program, if they are standardized.
- Okay, If not, then we 14 will put in the 70 percent bin -- I mean we will put in the
()
15 30 percent bin, yes.
16 DR. SHACK:
The review is actually by system 17-component and degradation phenomenon, right?
18 DR. KRESS:
That is what I was --
19-DR. LEE:
That is correct.
20 DR. SHACK:
I mean that is the way -- and then 21 this --
22 DR. LEE:
From system and then you go down to 23 structures and components, you manage --
24 DR. SHACK:
So you are really going through 25 r'erything.
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DR.~ LEE:
Yeah.
-[')
2 DR. SHACK:
And then you go over, you look it up
%.s 3
in your-GALL table to see whether it is adequately addressed 4
or not.
So in a sense --
5 DR. KRESS:
It is a review of everything.
(
6 DR. LEE:
That's correct.
Yeah.
i 7
DR. SHACK:
it is a review of everything.
8 DR. LEE:
I guess, Dr. Kress, the way I understand 9-it is what happened, the programs are not generic across the
.10 industry.
Okay.
11 DR. KRESS:
Yeah, that was the other part of the 12 question.
13 DR. LEE:
Then in that case then you just put in 14 the 30 percent bin and then you look at it on an individual
()
15 basis, until we can figure out, you know, what was the best 16 way.
17 CHAIRMAN BONACA:
But the option you recommend 18 would encourage in fact treatment of issues under certain 19 programmatic similarities, I guess.
20 DR. LEE:
Yeah, we are looking for program 21 attribu es.
Not really how you enter, what procedure you 22 use and such-and-such.
So we don't get into that detail.
23 CHAIRMAN BONACA:
So it would encourage a'more 1
24 standardized approach to the applications and to the review?
25 DR. LEE:
That is correct, yeah.
I guess if you i
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1 look forward to what we are lookingLfor in the 30 percent,
(}
2-then ask the applicant to design the programs.
3 DR. KRESS:
So your recommendation is that you j
i 4
feel that Option 3 is a good balance to be sure you capture 5
allLthe needed reviews that would not provide undue burden.
6-DR. LEE:
Yeah, like we reviewing the same 7
program, you know, the hundredth time and the hundredth 8
applicant comes in.
9 DR. KRESS:
Just wasting -- just wasting your 10 time.
11 DR. LEE:
That's right.
Yes.
12 CHAIRMAN BONACA:
But you should have included 13
. Option 4.
14 DR. KRESS:
Well, it ought have to be in there.
15-CHAIRMAN BONACA:
Not just to have a spectrum of 16 understanding.
All right.
Now, we are operating on Option 17 4.
18 DR. LEE:
We are doing Option 4 right now for BGEE 19 Oconee, yes.
Yes.
I understand.
20 DR. SHACK:
Yeah, but plant 25 though, Option 4 21 starts to look --
'22 DR. KRESS:
Starts to look pretty dreary.
23 (Laughter,]
24 DR. KRESS:
Are we supposed to write a letter?
25 DR. SEALE:
We are supposed to write a letter on
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this.
}
2 CRAIRMAN BONACA:
Yes.
We have a second 3
presentation on this issue now from NEI.
4 DR. KRESS:
We are going to hear it from NEI's 5
viewpoint.
Good.
6 CHAIRMAN BONACA:
Okay.
Any further questions for 7
Dr. Lee?
8
[.o response.]
N 9
CHAIRMAN BONACA:
Thank you for your presentation.
10 DR. SEALE:
Don't go away.
11 CHAIRMAN BONACA:
Stay around.
12 MR. WALTERS:
Good afternoon.
My name is Doug 13 Walters, and I am with the Nuclear Energy Institute and I 14 have responsibility for license renewal.
I don't have a (A) 15 formal slide show for you, but I did want to just hit a 16 couple of salient points.
I will use a couple of overheads 17 that you have already seen in Sam's presentation.
18 I think, first of all, this issue of existing 19 programs, in our view, needs to be segregated.
I think 20 there is a technical aspect of the question and I think 21 there is a process aspect of the question, and in our view 22
-- let me talk briefly about the industry process.
23 You heard a lot of discussion about this 30 24 percent of programs that have been identified.
What this is 25 intended to show is the process that BG&E and Duke used, and I
())
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the process that is outlined in our document NEI 95-10
(}
2 starts with the entire plant.
And you take the plant 3
systems, structures and components, and then you apply the 4
scoping and screening criteria that are delineated in the i
5 rule.
And out of the' bottom of that hopper you get the 6
long-lived passive structures and components that require an 7
aging management review.
8 The next step in that process is to identify the 9
functions of those long-lived passive structures and 10 components and the aging effects that could be detrimental.
I 11 The next step, and I think this is the one that is 12 not understood is that the applicant will identify programs
)
I 13 and activities that manage those aging effects to ensure 14 functionality.
That is a very rigorous, thorough review.
()
15 I think you may have heard yesterday, as part of 16 the discussion on the Duke application, 60,000 man-hours.
17 So this is not an exercise of the industry wanting to say I 18 have an existing program, thank you very much.
There is a 19 very robust process that takes place, either at the plant 20 site or at the corporate office that looks at existing 21 programs and activities, and we call it mapping, and mapping 22 that program to that aging effect to ensure the 23 functionality of_the long-lived passive structure and 24 component.
25 Now, when you do that mapping, there are likely to
)
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be three results.
One will be that the program already
{
i
())
2-exists and it is adequate as is.
An example of that might f
3 be implementation of the EQ rule.
You may find that you 4
have to modify an existing program, and you may find, in 5
fact, that you have to establish a new program.
)
l 6
Let me talk a little bit about that.
You have 7
seen this pie chart before, mine is not quite as detailed, 8
but this is the typical results.
Obviously, we are finding 9
the majority of the programs and activities credited for 10-renewal already exist.
There is a certain piece of the pie 11 that is modified programs, and then, of course, we have some 12 new programs.
13 You heard a lot about that 30 percent.
Let me 14 talk to that issue for a sec. because I think that is a tad
)
15 misleading.
The reality is that the modified programs are 16 existing programs.
And I think you will find if you look 17 hard at the details of the BG&E and the Duke application, 18 that the modification was merely to put into an existing 19 program some language that captures what the licensee was 20 already doing.
And they did that for completeness or 21 because they thought that is what the reviewers would want 22 to see.
23 It is not a modified program in the sense that the 24 program was deficient, it is a modified program in the sense 25 that verbiage was added.
Maybe the scope was increased, l
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(~']
2 existing program, that have aging that needs to be managed, L/
3 and the applicant said, well, gee whiz, that is no different 4
than this other component that is covered by program X, I am 5
going to put that in program X.
-6 The point is the adequacy of the program is not 7
' challenged.
It could be in some cases, I can't say that 100 8-percent of that area called modified is not in that latter 9
category, but I will submit to you that the majority -- and 10 in BG&E's case, that number is about 101 I will submit to
)
l 11 you that a majority of those 101 programs are already 1
l 12 existing.
They adequately manage the aging and the 1
13 modification was nothing more than the addition of some t
14 language to capture an activity that is already being done.
()
15 The new programs, let's not be misled on those 16 either.
A lot --
17 DR. KRESS:
Suppose the review that NRC is talking 18 about is just to validate that statement.
I mean that is 19 the extent of it, just to look --
20 MR. WALTERS:
Right.
21 DR. KRESS:
-- and see that, yeah, that is 22 adequate.
23 MR. WALTERS:
Fine.
24 DR. KRESS:
Fine?
25 MR. WALTERS:
Yeah.
That is a good point.
I
()
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don't I want you to, I hope, get from my remarks that the 2
review, and you'saw the language, it says we need to --
.C
.3 should the NRC do a review, they can do the review.
Our 4
point is that our process, the applicant has already done 5
that review, and it'is robust and it is thorough.
Why do we 6
need-to now have another review?
.7 And I say that with the -- at least our 8
interpretation of the rule language, that you saw in one of 9
Dr. Lee's slides,.that said the regulatory oversight process 10 is adequate, ensures that the CLB continues to protect 11
.public health and safety.
12 The 30 percent, again, _I don't think we are 13 challenging the technical adequacy or the adequacy of that 14 program to manage the aging, it is already doing that.
We O4) 15 are merely adding scope,or we are putting -- we are putting 16 language in there to tell the, let's say the operator that 17 when they walk, do their walk-around, look specifically at i
I 18 valve X.
Whereas, it might -- the procedure might say, go
{
l 19 into the room and look.
Those are the kinds of changes that 20 represent modified programs.
21 JAnd our paper, which is included in the SECY, I 22 think would support what you are saying and that is, if it 23 is a modified program, yeah, you need to provide more detail 24 in the' application and maybe there is a little more 25 sinformation that is needed on the adequacy of the program, i
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because you are adding scope.
}
2 Similarly, though, on the new programs, I think as
(
3 you heard, those are one time inspections.
And we agree 4
.that -- and our paper I think supports this, that if you are 5
in that yellow piece of the pie, that is where the real 6
focus is.
What is new?
7 Presumably, if it is a new program, it means there 8
is some aging effect that is not currently being dealt with, 9
or the aging effect has somehow been determined to be 10 different.
The rate of the aging perhaps is shown clearly 11 to be different in years.41 and beyond, and you need a new 12 program.
That is where the focus ought to be, that is where 13 we ought to provide the most information, because the staff 14 has not seen that before.
()
15 But to say that -- and, again, the point is these 16 30 percent were identified by the applicants.
So our 17 process identifies that 30 percent.
Now, I might stand 18 corrected and say it was 25 percent, there might be 5 19-percent of the 30 that the applicant decided for 20 expediency's sake it was the right thing to do, but it is 21 not like our process only looked at the 70 or 90 -- this 22 piece.
Our process identified those things.
So the review 23 is robust.
24 And the important point I think in that statement 25 is that if you then say that 70 or more of those programs
(~N.
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already exist, and they are part of the CLB, why doesn't the
/T 2
CLB make the conclusion that they are adequate?
And we U
3 think it does.
We think that is what the CLB does.
4-CHAIRMAN BONACA:
Just another question, however.
5 Clearly, you are referring to two reviews which went under 6.
Option Number 4 that Dr. Kress identified.
So now I am 7
'trying to understand what will happen if we said, okay, you 8
are right.
So, therefore, an applicant will come in and 9
probably would not go through the review of all those 10 processes that are already existing.
And so this extensive 11-review would be significantly reduced.
12 MR. WALTERS:
No, this would not change.
The 13 difference would be how much information do you put in the
- 14 application.
You saw that environmental qualification was a
,-.()
15 program that was found acceptable.
That is true.
You may 16 want to go look at the BG&E application and look at the 17 significant amount of.information that needed to be provided 18 to quote-unquote " demonstrate" that a program that is 19 implemented to comply with a regulation is adequate, and 20 they said there were no changes needed.
21 So to --
22 CHAIRMAN BONACA:
So the issue is demonstration?
23 MR. WALTERS:
I'm sorry?
24 CHAIRMAN BONACA:
So the issue really is 25 demonstration?
~(
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MR. WALTERS:
Well, that seems to be the word that I) is hanging a lot of us up is, how do you make that 2
3 demonstration?
And I think, simply stated, our view is that
-4 if it is a CLB program, that demonstration has already been 5
made.
6 Now, the staff might tell you, well, we don't know 7.
how you implement 50.49.
Well, I would submit to you that 8
is a bigger issue than just license renewal.
And if, in 9'
fact, that is the case, we ought to see some action so we 10 can right that -- r-i-g-h-t.
11 This process will not change.
We think this is 12 the right process.
We think that you have got to go through this mapping and assure yourself that in fact an existing 13 14 program is' managing the aging, even though you know that it
()
15 is.
16 We have an example in our paper on Generic Letter 17 89-13, heat exchanger fouling.
The Generic Letter provides 18 a program that the agency says is acceptable for managing 19 the fouling.
My question is, we will go back and do this 20 process if we elect to include heat exchangers in the scope
'21 and we identify fouling as the aging effect, and we will do 22 this mapping.
23 But I should not have to regurgitate my response 24 to the Generic Letter.
I'should be able to just say I have implemented a program consistent with that which you said 25 O
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was okay in Generic Letter 89-13.
2 And so that, you know, to me that is the issue 3
that we have.
We are not tryinc, to get rid of the process 3
i 4
that we do.
And I think if you read the SECY, all the 5
examples -- and some of those were touched on in Dr. Lee's i
6 presentation, small bore piping, et cetera, the SECY 7
suggests that all those additions were identified by the 8
applicant, that the applicant said they needed to do the one 9
time inspection.
So the process gets you the 30 percent.
10 CHAIRMAN BONACA:
Would Option 3, however, bring 11 some -- you know, come close to what you are proposing?
12 MR. WALTERS:
Well, it interesting to me that 13 Option 3 is already in place.
If it is an option, why is 14 the GALL activity underway?
I don't know, maybe -- I raise O
j 15 that because maybe there is some other purpose for doing 16 that.
17 It could, but I think what you see in the GALL 18 report, if you -- the sample, I think we would agree with 19 what is in there, except when you look at the column that 20 says " technical evaluation" or " justification."
I don't 21 have it in front of me, but I would -- I think our view is 22 that that column is really completed because it is part of 23 the -- because the program is part of the CLB.
That is what 24 we think the Commission found when they promulgated the '95 25 regulation, was that the CLB will take care of it.
I i
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And, again, I go back to our paper that is in the
(~h 2
SECY, we do believe there is some graded approach there.
I V
3 mean clearly you have got to do the mapping and make sure 4
that the program does in fact cover the aging.
But if it is 5
part of the CLB and it is required that I implement that 6-program because of a regulation, let's say, what is 7
difference about renewal?
8 Again, if you look at the examples, there is a lot 9
of. language that says you have got to do this for renewal.
10 And our question is -- why?
What is the standard that was 11 applied that now says this is a problem for renewal, but it 12 is not a problem today?
There may be situations like that, 13 but I don't think that should be the going-in-assumption.
14 Our going-in-assumption is that we do a very good job of 1
(
15 managing aging today.
j N.
J 16 CHAIRMAN BONACA:
Of the existing -- of the 17 modified programs, how many were they modified because the 18 staff reviewed and proposed changes that were accepted?
19 MR. WALTERS:
I don't know the answer to that.
20 But I would -- I don't think it is -- if you consider the 21 BG&E breakdown and there were 101 modified programs and 16 22 new programs, my sense is that a majority of those, if that 23 is a total of 117, I would say a majority of those were 24 identified by the applicant.
I could be wrong, maybe the 25 staff has got a different --
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MR. GRIMES:
This is Chris Grimes.
Those were all j
2 identified by the applicant and for those, the staff 3
identified 48 issues that either had to be resolved or 4
confirmed.
5 DR. KRESS:
Let's consider this GALL report, the 6
first item on there was the reactor coolant pump, and the 7
issue was thermal aging causing embrittlement.
And it says 8
that there is a plant-specific aging management program, 9
which implies to me that the different plants may treat this 10 in a different way with their management program.
Not only 11 that, if we are talking about thermal cycling aging, thermal 12 aging, the number of insults that thing gets over its 13 lifetime depends on its lifetime.
So the aging management 14 program that a plant may have had, there may be something
(
)-
15 magic about 40 years, if -- you know, if the 40 years was 16 where you counted the1 number of cycles it got, too.
17 So, the question I would have is, there is 18 possible something magic about 40.in terms of passive 19 long-lived components that may require things to be looked 20 at and reviewed.
21 MR. WALTERS:
Yes.
22 DR. KRESS:
But that is what you do when you go 23 through the screening process.
24 MR. WALTERS:
You just did it.
So if you were the 25 system engineer at the power plant, and I was responsible i
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for renewal'and I asked you that_ question, -- hey, how are 2.
we looking here?
Do'we have something that is going to
~
3 manage this effect?
4 DR. KRESS:
The managing may very well be, well, 5
our calculations say that it can't' stand this for another 20 6
years or whatever' so we are going to either reduce the 7
cycles, replace the pump cnr we are going to watch it very 8
closely.or something to manage.
9 MR. WALTERS:
Right.
10 DR. KRESS:
You know you have got a problem and 11 you manage it.
12 MR. WALTERS:
Yes.
13 DR. KRESS:
And that will come out in your 14 application'.
()
15 MR.'WALTERS:
Right.
I would' call that probably a 16 modified.
17 DR. KRESS:
That-would be a modified.
18 MR. WALTERS:
Yeah.
And I would have an 19
. obligation to talk about that in the application and say 20 what I am going to do.
21 DR. KRESS:
.It seems to me like the staff would 22 have an_ obligation to look at it and say, yeah, we think
'23 that will probably do it for you.
24 MR. WALTERS:
I agree.
25 EDR. KRESS:
I mean they would have to review that J
(s '
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to some degree.
2 MR. WALTERS:
I agree.
3 DR. KRESS:
Okay.
4 MR. WALTERS:
I agree.
And I would also clarify 5-that we don't object to the staff looking at any program.
{
6 DR. KRESS:
Yeah.
7 MR. WALTERS:
But I think the difference is, if it 8
is a program that is existing, that I implement, let's say,
~
9 because the regulation says I need to do that, then ask me 10 the question under Part 50.
11-DR. KRESS:
Well, what I would have said was 12 Option 3 sounds pretty good to me, but what NRC needs is a 13 screening process on Option 3 that asks the question -- why 14 was this program modified, or to what extent was it A
4,
)
15 modified?
And then grade my review based on that.
And that 16 may get you all the way down almost to looking at'just new 17 programs 18 DR. SHACK:
But the staff also has to verify that 19 your mapping is correct.
20 MR. WALTERS:
Sure.
21 DR. KRESS:
Well, yeah, they will do that as part 22-of the licensing renewal application, I think.
23 MR. WALTERS:
Sure.
We agree with that.
They 24 have to be satisfied that you have mapped correctly, you 25 have captured everything.
But they -- maybe I am leading
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you, I don't want to do that, but let's use another example.
i 2
I mean the heat exchanger example, I think, you 3
know, we would still go back and do the mapping.
We have 4
got fouling, you know, you can pick whatever aging effect.
5 You know what the function is.
Okay.
I would go back and 6
look at the program that I said I was going to implement in 7
my response to that Generic Letter, and I would -- I have 8
the obligation under this process to ensure that that 9
program is managing the aging.
10 I would look at maybe the operating experience of 11 that program.
I am sure the NRC has inspected it somewhere 12 along the line.
And I would ask the heat exchanger 13 engineer,' okay, how do we look?
Are we managing the aging, 14 and is that going to be good enough in the 40 year -- excuse l
15 me, in the renewal period?
The answer is yes.
One outcome, 16 the answer is yes.
Fine.
I will continue to do my Generic 17 Letter 89-13 program.
18 Why do we have to go back and revalidate or 19 rejustify that program merely because we are going to 20 operate one more year?
We think that is what the CLB does.
21 That is why the Generic Letter was issued.
There was a 22 concern about the fouling.
It didn't say we are only 23 concerned for the remainder of the life, or for the 24 remainder of your 40 year license.
25 Part 50 doesn't expire at any given time, it ANN RILEY & ASSOCIATES, LTD.
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expires when you shut down, I suppose.
Some might, you
[}
2 know, argue that.
But -- so when the Generic Letter was 3
issued, it wasn't issued with, well, we only are concerned i
4 about from now until you reach the end of your 40 year 5
license.
We are concerned about the aging, and the effect 6
of that aging on the heat exchanger performance and here is 7
a program that will take care of that.
And that program 8
should be sufficient whether I operate 30 years, 40 years or 9
60 years.
10 And if we are not satisfied with that when we go 11 through the process, then we ought to say that in the 12 application.
If the agency believes that that program is no 13 longer the appropriate program, -- maybe they have new 14 information that suggests the aging is somehow different.
()
15 Okay.
Come back to me under Part 50 under my current 16 license and tell me that.
17 Why are we using 54 as the arena to showcase these 18 enhancements are needed?
I mean in some cases that may be 19 true, but I think in that example, ask me question under 20 Part 50, don't make me do something different for renewal.
21 DR. SHACK:
That is almost inherent in an aging 22 process, is that you can ignore aging processes for a 23 certain amount of time, say 40 years, and, you know, they 24 just -- of their nature, they become more important after a
'25 certain Taount of time.
And so, you know, there is no magic
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about 40 years.
{~ )
2 MR. WALTERS:
No.
3 DR. SHACl;:
But it is certainly true they do 4
become more important with more service.
5 MR. WALTERS:
Sure, no question aging can be 6
cumulative.
All I am saying is that when I implemented that 7
program in response to the Generic Letter, I did it to take 8
care of an aging concern on the heat exchanger.
And if my 9
judgment is, in going through this process and talking to 10 the heat exchanger engineer, that that program is doing an 11 adequate job of managing the fouling, why would I do 12 anything different?
13 DR. SHACK:
You presumably wouldn't.
14 MR. WALTERS:
Right.
()
15 DR. SHACK:
You would have to just convince the s-16 staff that that is true.
i 17 MR. WALTERS:
Well, what would the standard be
)
18 that they would use to determine that it is not?
f 19 DR. SHACK:
Whatever you used to conclude that it 20 was fine.
If it was good enough to convince you, it is 21 presumably good enough to convince them.
22 MR. WALTERS:
Well, I would submit to you that if 23 they want to ask that question, they certainly can.
But --
24 DR. SHACK:
Well, the question is, how much do you 25 need to demonstrate and how much do they need to inspect, I
('])
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guess?
V(~'\\
2 MR. WALTERS:
Well, they can inspect all they 3
want.
i 4
DR. SHACK:
They can inspect all they want.
But
]
5 how much do you need to demonstrate?
\\
6 MR. WALTERS:
I ought to be able to say what I
-7 just told you.
I looked, I asked, and my conclusion is that 8
the program that --
9 DR. SHACK:
Trust me.
10 MR. WALTERS:
No, it is not trust me.
No.
It is 11 not.
It is trust me if is a program that I implemented 12 because I have a plant-specific problem.
But if it is a 13 program that the agency has said, you ought to implement I
i 14 this, and we would find that acceptable, I don't think it is
()
15 I don't think it is good regulatory practice to come back 16 and say, just because you are going for a renewal, that 17-program is now suspect and you have to come in and tell me 18 why it is okay.
19 Why do I have to do that?
I will tell you that I 20 looked at it.
I will tell you that I did the mapping.
I 21 will tell you that the operating history shows that the 22 program has been effective.
What more do you need to know?
23 You told me to implement the program.
You 24 identified the concern.
You said that the fouling was a 25 concern for heat exchanger performance, and you even gave me ANN RILEY & ASSOCIATES, LTD.
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the program, thank you very much, in the Generic Letter that
%}
2 you said would be adequate for dealing with that aging.
I t
3
.have done that, I have implemented that.
4 DR. KRESS:
This seems to tell me that all of the 5
plant programs, aging programs or whatever, are there 6
because they are required by some regulation.
I was under 7
the impression that a lot of those were done by the 8-licensees just because they thought they were needed, they 9
weren't required by regulation.
10 MR. WALTERS:
I agree.
11 DR. KRESS:
If the program has to be of that 12 nature, then it seems like NRC has some sort of obligation, 13 since they haven't specified the program, and it may be 14 different for different plants, it may be plant-specific.
()
15 They seem to -- in that case, it is not a " trust me," it is 16 a." trust me" in that case.
And for those, if it is not 17 required by the regulations, the program, then they probably 18 have an obligation to come look at it, or at least see if it 19 is adequate or something.
20 DR. SEALE:
And that is disturbing, because what 21 that -- the message there is that if you volunteer some 22 action that will respond to your perception of an aging 23 problem,' I am going to_put come hurt on you.
24 DR. KRESS:
That is always a problem with 25 volunteer programs.
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DR. SEALE:
Yeah.
Yeah.
It is kind of
()
2 interesting to me.
It strikes me that we could in all 3
candor accept the idea that the original version of NRC l
4 generated requirements, memoranda, messages about aging were 5
all initially put together under the limitations implicit in 6
a <40 year license lifetime as being a measure of what the 7
objective of the' aging program was.
8 And it doesn't seem to me unreasonable to make the 9
case that those programs, those measures all should be 10 scrutinized when one moves one site objective to 60 years.
I 11 I mean 40 and 60 is, under the regulatory process as it 12 exists in this country, a discrete watershed between the 13 two.
14' The thing that bothers me is, you say, well, do it (f
15 under Part 50.
I can imagine the hue and cry we would hear 16 if, as a result of going through ten of these license 17 renewal processes, the NRC, in its desire to collect and 11 8 learn from the lessons that were in those first ten, 19 suddenly came out with another five requirements under Part 20 50 for license holders to do some aging management programs, 21 and then those utilities who said, I am not going for 22 licensee renewal, and here you are, you are hanging this new 23 aging management program on me.
I can hear that response
{
24 too.
I 25 You know, there is a little bit of wanting it both
[}-
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ways here.
)
2 MR. WALTERS:
Well, I appreciate that feedback.
I 3
hope we are not trying to get it both ways.
I think all we 4
are trying to do is say, you know, we need to focus renewal 5
on the right thing.
And if the result is that 70 percent --
6 and I would argue'that it is even higher than that when you 7'
include the modified programs, are already existing and 8'
that, certainly, a large portion of those'are'CLB programs 9
that can.be tied to some -- not reason necessarily, but some 10 regulatory document that we have had in place for, you know, 11 for a long time and we have relied on it, and it works 11 2 today.
I am not sure I understand what is so magic about 13 moving into a year 41 or 42 that now should call that 14-program into question.
()
15 And I don't see that.
I mean we know there is 16 programs I think that were implemented in year 5 of 17 operation of my plant, that in year 10 I decided I needed to j
1 18
- change, i
19 So I think all we are trying to say is we 20 shouldn't use renewal as a playground for imposing new 21 requirements that otherwise can't be imposed in the current 22 term.
]
23 And I will tell you, I would think that the 1
24 industry, if there is an aging effect that somebody believe 25_
is somehow different or unique in the renewal period, I i
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would like to know about that now, and I would like to take f~h 2
care of it today.
J 3
But the results say we are not finding that.
4 CHAIRMAN BONACA:
Let me ask a question now.
The 5
staff indicated that there are three options, and Option 1 6
and 2 would involve a change to the rule in order to 7
accommodate your perspective.
Okay.
And the reason is that 8
they feel that under the kind of interpretation that you are 9
providing, a demonstration is not possible on their part.
10 Do you agree wi'h that?
t 11 MR. WALTERS:
No.
12 CHAIRMAN BONACA:
- Okay, I would like to hear 13 that.
14 MR. WALTERS:
Well, I think we interpret the D)
(
15 principle, the rule, which is on Slide 3, that says, "with 16 the possible exception of detrimental effects of aging."
17 What does that mean?
18 Plants -- you know, the functionality of certain 19 plant systems, structures and components.
Well, the certain 20 plant systems, structures and components are those that are 21 long-lived and passive.
We agree with that.
22 The regulatory process is adequate to ensure the 23 licensing basis provided an acceptable -- I think it is 24 provides an acceptable level of safety.
So we think that 25 means that the CLB is adequate if you can show, and do a ANN RILEY &' ASSOCIATES, LTD.
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mapping that says it is managing the aging today.
And --
(~T 2
DR. SHACK:
The commission concludes that a V
3 generic exclusion for passive structures and components is 4
inappropriate at this time.
5 MR. WALTERS:
Right.
And that is why you do this, 6
because if you had the generic exclusion, you wouldn't even 7
do this.
8 DR. SHACK:
No, the generic exclusion is for 9
active components for which you assume the CLB does in fact 10 cover all the aging.
11 MR. WALTERS:
I understand that.
I agree with 12 you.
What I am saying is -- our interpretation is that it 13 is not a generic exclusion of passive long-lives.
We are 14 still -- they are still in the scope.
That is where the
()
15 exclusion is.
Well, the exclusion is actually down here.
16 CHAIRMAN BONACA:
And so you feel that even under 17 the approach you are proposing, you feel that the staff can 18 perform a demonstration for all components?
19 MR. WALTERS:
Yeah, I think that -- I mean I am 20 not an attorney, but I think that it is the demonstration as 21 well, you will see that in the SECY.
22 CHAIRMAN BONACA:
No, I know you are not an 23 attorney, but you are proposing that the staff would not 24 review certain things, okay, that they seem to feel 25 necessary to review to say, yes, this program exists and, in
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fact, is adequate to manage between 40 and 60 years.
2 MR. WALTERS:
Right.
3 CHAIRMAN BONACA:
That is the statement that they 4
expect to be able to be -- what?
They expect to have to do,
'5 state.
Okay.
I believe that the staff believes that they 6-have to say that.
And'to say that, they cannot rely solely 7
on the applicant's statement.
I think that is the crux of I
8 the issue.
They have to look at it.
They have to say,
{
9 well, show me, explain to me why, I can agree with you or 10 not.
1 11 I understand how, you know, --
12 MR. WALTERS:
Okay.
And what I meant to say is 13 that that gets to the 54.29 finding, which says actions have 14-been or will be taken.
And I would submit that the 15 principle of the rule says, well, we have already taken that 16 action with regard to programs that are part of the CLB, i
17-that clearly manage aging today.
We are still going to do 18-that, but if they clearly manage aging today, and they are 19
~ part of the CLB, why can't the finding in 54.29 be that they 20 are part of the current licensing basis, and this program 21 manages corrosion or whatever?-
22 CHAIRMAN BONACA:
Now, let me say, there are --
23 you know, I can see both sides.
But isn't there something 24 attractive about an Option 3 where you have~a Standard
'25 Review Plan which, in fact, will take most of existing ANN.RILEY & ASSOCIATES, LTD.
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programs and declare them acceptable because in the
()
2 application it has been seen -- and also identify where in 3
fact there is some need for modifications and things of that 4
kind?
5 What I mean is that it seems to me that would be 6
attractive for --'almost like for fleet of applicants of a 7
certain design to rely on a document of that nature.
8 MR. WALTERS:
On the surface, yeah, that appears 9
attractive.
Our concern, and we still have to I think study 10 it and come up with some examples, but I will give you one 11
-- IWE/IWL.
1996 the Commission adopted a '92 version of 12 ASME, and in the statements of consideration for that 13 rulemaking, it says, "We believe that the detrimental 14 effects of aging will be managed in the current term and the
()
15 license renewal period."
16 There is also a NUREG dated September of '97 that 17-the renewal staff wrote that says they don't agree with 18 that.
Now, we could debate that and I don't want to 19 mischaracterize it, it is related to the irs.
But the 20 bottom line is there is a regulation that says IWE/IWL is 21 okay for renewal.
Implementat?~
I think is the word it 22 uses.
23 Option 3 allows for that kind of approach, and I 24 don't think that is right.
If the Commission found that 25 IWE/IWL is acceptable for license renewal, and that is what
-[~h ANN RILEY & ASSOCIATES, LTD.
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the SOC says, we shouldn't just arbitrarily say, well, I
()h 2
don't agree with that and here is the additional, the q
3 enhancement, which is what Option 3 is supposed to focus on.
4 Now, if there was a way to have that kind of 5
review to ensure that we are not -- because I would submit 6
to you, that if we have these enhancements and they are 7
touted as, well, you need to do that for renewal, it is 8
going to come back into current space.
The applicants today 9
that, on the modified or new programs, they are going to i
10 implement those today.
They are not going to wait till year 11 40.
And that is not right.
12 So I think the concept of Option 3 is reasonable.
13 I think the details of it, we would need to work on.
But 14 that is the concern, that here is the enhancement you need i
15 to make and how -- you know, who is the judge and jury of L
16 that enhancement?
17 That concludes what I had planned to say, and I
]
18 would be remiss if I didn't conclude by saying that, despite 19 the fact that we are having this discussion, the industry is
)
)
20 I think more than pleased with the way that renewal has gone 21 to date.
There is no question that the process has been 22 extremely stable, at least through the first two 23 applications.
The staff has met all the milestones.
I 24 think that is commendable.
We have proven we can get 25 through the process, and it is probably going better than
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people thought it would.
()
2 You are probably aware that there has been a 3
number of recent announcements of people lining up to pursue 4
renewal.
So I don't want to leave this with, you know, we 1
5 have got real problems here.
This is an important issue to 6
us because of the future applications.
We want to make sure 7
that future applicants have the same success that both Duke
'8 and BG&E are having and will have.
9 And we can't let -- you know, we sometimes look at 10 this the way we look at SARs and tech specs, improved tech 11 specs.
If we don't put some controls and guard rails on 12 this, this is how we grew from four volume SARs to 30 volume 13 SARs, and we don't want that to happen.
14 We are enjoying, you know, the way it is right
()
15 now, and we would like to keep it that way.
And so we think 16 this is an important issue for maintaining that stability 17 and predictability in the process.
But I don't want to 18 leave you with the idea that we are not happy with what the 19 staff has done to date.
I think they have done a great job 20 in the first reviews here and we would just like to see that 21 continue.
22 CHAIRMAN BONACA:
To help myself to understand, 23 you gave us an example about heat exchanger fouling, okay.
24 And I agree that, you know, that is an issue where if you 25 have a program, you have a program, you have a program,
[~}
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)
1 until the heat exchanger is there fouling.
You identify,
{}
2 you clean it up'and you go.
3 But there are other issues to do with aging of 4
component for which you may not have a timely meta-analysis q
5 of-40 years, but simply you have -- you know that there is q
6 some, I" don't'know, material growth or there is something 7
that happens with age.
And there was -- you know,.there is 8
a program in place to do some monitoring.
Okay.
But there 9
wasn't a timely meta-analysis on the basis of that.
Now 10 that you go to longer life, in fact, you may identify that 11 you need something different, okay 12 Now, in that particular case you would ask the 13 staff to believe in faith on the statement from the 14
. applicant that the program will just end, we will take care ges
((_)
15-of it.
That is really what -- and the staff may be 16 concerned about it because they are looking at the specific 17 issue, they are saying, wait a minute now, this is one where 18 you have no time-limited analysis, but you have a concern 19 with growth, for example, okay, and the only way I can get 20 you to change it is to go to a backfit rule.
I mean isn't 21 there -- because there are some examples of.that which are 22 not as simple as the heat exchanger fouling, I think.
)
23 MR. WALTERS:
Yeah.
There are.
And, again, let 24 me make sure_that it is clear,. we are not proposing in the 25 application that it is_one or two sentences.
We have to ANN RILEY & ASSOCIATES, LTD.
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provide enough information in the application to show this 2'
mapping.
And'I think what you -- the way you just' described 3
it'is what I would have put in the application.
Hey, I 4
found this aging effect.
I think somehow it is going to be 5
different in the renewal period, and here is why.
And I 6
might base that on operating experience, I might base it on
-7
. industry _ operating experience.
8 And then, you know, I will say, here'is how it l
9 affects the function.
And then I will have to describe what I
10 I am going to do about it.
11 Our point is that if it is an existing program
'12 that is part of my current licensing basis, and we think 13 that'it adequate for managing that aging, -- that is not a 14
-good example because I would submit that if in fact I 15 identified that the aging is somehow different, I probably 16 don't have an. existing-program.
I might have to modify an
-17 existing program.
And I would have to explain that in the 18 application.
And I think that is the area where certainly 19 the' agency should say, okay, do I think that is correct?
Do 20 I agree with that?
And we have to provide sufficient 21 information for them to make that de' trmination.
-. 2 2 So.I would agree with your example, yeah.
And I 23 hope that is what our paper says that is in the SECY.
I 24 think it does but maybe it doesn't.
25 Thank you very much for the opportunity.
I O
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appreciate it.
(
2 DR. SEALE:
Thank you.
-3 CHAIRMAN BONACA:
Thank you very much.
Appreciate 4
it.
5~
Any other thoughts?
6 DR. UHRIG:
There will be a review of this at the 7
next meeting?
i 8
CHAIRMAN BONACA:
Yes.
At the next meeting we
.9 will have pretty much'the same presentations.
10 DR. UHRIG:
The same review.
11 CHAIRMAN BONACA:
I would expect that, you know, 12 we have allotted one-and-a-hour to the full committee 13 meeting, and this is pretty much the time it took today.
14 So, I would propose that we just go through this 15 presentation as is.
16 DR. KRESS:
I don't see where you can cut it back 17 any.
18 CHAIRMAN BONACA:
No.
19 DR. KRESS:
It was a pretty concise presentation.
20 CHAIRMAN BONACA:
And they were both very clear 1
21 presentations.
I want to say that at least I got an 22 understanding of the issue, a better one than I had before.
j i
'23 So --
24
-MR. MATTHEWS:
Mr. Bonaca.
25 CHAIRMAN BONACA:
Yes.
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MR. MATTHEWS:
Hi, I am David Matthews, the Direct 2
of the Division of Regulatory Improvement Programb.
I just 3
wanted to make just a minor concluding remark from the staff 4
perspective's.
I don't think I could improve on Dr. Lee's 5
presentation with regard to the clarity of the issue as far 6
as the staff sees it.
7 I just would remark that the reason that we are 8
bringing this issue to the Commission is because the staff 9
is of the belief that the literal wording of the regulation, 10 as backed up by the principles that Dr. Lee described,
'll obligate the staff to conduct the review within the scope of 12 what we have described, and we don't believe that we can 13 carry out that mandate under the manner in which NEI has 14 proposed that they believe we could interpret the rule to r( )
15 allow.
'16 So, that is the reason we raised it to the 17 Commission, because we feel we are carrying out their 18 policy, and if we were to do differently, we would need 19 their agreement and direction to do it differently.
So that 20 is why the issue is before them.
21
~With regard to the absence of an Option 4, the 22 paper was drafted with an Option 4, but it became clear that 23 we had never-intended Option 4 to continue, even though it 24 describes how we are doing the initial reviews.
25 We had already initiated efforts to move to
(~N ANN RILEY & ASSOCIATES, LTD.
-(,)
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.
20036 (202) 842-0034
349 1
something looking like Option 3 by our initiation of the
[}
2 GALL effort and.our efforts to improve efficiency and 3
effectiveness and reduce regulatory. burden, unnecessary 4
regulatory burden.
So we had already moved in that 5~
direction'.
The groundwork was in place.
So Option 4 really 6
wasn't a realistic option for any extended period of time as 7
far as the staff was concerned.
8
. CHAIRMAN BONACA:
I understand the reason why, on 9
the'other hand, if you put it on the table, then you realize 10-that all Options 1 and 2 and 3 are in the direction of 11 efficiency and reduction.
So, and it put current' reviews in 12 the proper context.
13' MR. MATTHEWS:
Yeah.
You know, it would have 14 demonstrated some contrast, that is for sure.
Anyway, that 15 is all I wanted to offer.
Thank you.
16 CHAIRMAN BONACA:
Are there any other remarks from 17' anyone?
Any of the members have anything else they would 18 like to ask right now?
19 DR. SEALE:
Well, I would just remind everyone 20l that we are being asked to write a letter on this question 21.
at our next meeting.
22 CHAIRMAN BONACA:
Right.
23 DR. SEALE:
And I urge you to think very 24-judiciously about the questions and be prepared to help us 25-put together as succinct and useful a response to the F..
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue,- NW, Suite 1014 Washington, D.C.
20036 (202) 842-0034 i
350 1-Commission as we can.
I have been asked to sort of herd
["')).
2 that letter and so I am deeply concerned -- I am deeply 3
concerned about removing as much of the fog from this 4
particular issue as I can.
5
.DR. KRESS:
We will send you some e-mails.
6 DR. SEALE:
Fine.
7 CHAIRMAN BONACA:
I just changed my reservation, I 8
will be here on the'13th in the morning, so we can stew on 9
'that'.
10 DR. SEALE:
Yeah.
11 CHAIRMAN BONACA:
Okay.
So if there are no 12 further comments at this time,1I would proceed to adjourn 13 the meeting.
And with that, this meeting of the
- L4 subcommittee is adjourned.
Thank you very much, everybody.
()
15
-[Whereupon, at 2:40 p.m.,
the meeting was 16-concluded.]'
17 18 19 20-21 22 23 24
.25' 1
/
(s-)/
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, SuiteL1014
]
' Washington, D.C.
20036 (202) 842-0034 J
REPORTER'S CERTIFICATE This is to certify that the attached proceedings
,}
before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING:
MEETING:
PLANT LICENSE RENEWAL CASE NUMBER:
PLACE OF PROCEEDING:
.Rockville, MD 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.
4 i
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