ML20212H350
| ML20212H350 | |
| Person / Time | |
|---|---|
| Issue date: | 09/23/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3090, NUDOCS 9910010041 | |
| Download: ML20212H350 (140) | |
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L (~5 OFFICIAL TRANSCRIPT OF PROCEEDINGS V
NUCLEAR-REGULATORY COMMISSION l
? ADVISORY COMMITTEE ON' REACTOR SAFEGUARDS
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Title:
MEETING: PLANT LICENSE RENEWAL-l TRO4 (ACRS:
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Docket No.:
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'I DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S-ADVISORY COMMITTEE'ON REACTOR SAFEGUARDS SEPTEMBER 23, 1999 The contents of this transcript of the proceeding of the United' States Nuclear Regulatory Commission Advisory A( )
Committee on Reactor Safeguards, taken,on September 23, 1999, as reported herein, is a record of 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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f 1-1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION-3 ADVISORY COMMITTEE.ON REACTOR SAFEGUARDS l
-.4 5.
MEETING:
PLANT LICENSE RENEWAL 6-
-7 l
8 Room 2B-3 9
White Flint II 10 11545 Rockville Pike 11 Rockville, Maryland 12 Thursday, September 23, 1999 13 14 The subcommittee met, pursuant to notice, at 8:30
)
11 5 '
a.m.
16 17 MEMBERS PRESENT:
18 MARIO V. BONACA, Chairman i
19 THOMAS S. KRESS, ACRS Member 20 WILLIAM J.
SHACK, ACRS Member 21-ROBERT E. UHRIG, ACRS Member 22 JOHN J.
BARTON, ACRS Member 23-JOHN D.
SIEBER,-ACRS Member 24 25 ANN RILEY & ASSOCIATES, LTD.
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PROCEEDINGS gsI 2-
[8:30 a.m.]
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3 DR. BONACA:
Good morning.
The meeting will now 4
come to order.
5 This is a meeting of the ACRS Subcommittee on 6
Plant License Renewal.
I am Mario Bonaca, Chairman of the 7
Subcommittee.
8 ACRS members in attendance are John Barton, Thomas 9
Kress, William Shack, Robert Uhrig, and John Sieber.
10 The purpose of this meeting is for the 11 subcommittee to hear presentations from the staff concerning 12 development of license renewal guidance, resolution of 13 license renewal issues, standardization, standardizing the 14 format for license renewal applications, the status of the 15 staff review of the Calvert Cliffs and Oconee applications, 16 and associated activities.
17
-The subcommittee will gather information, analyze 18 relevant issues and facts, and formulate proposed positions 19
-and actions, as appropriate, for deliberation by the full 20 committee.
I 21 Mr. Noel Dudley is the cognizant ACRS staff 22 engineer for this meeting.
23 The rules for participation in today's meeting 24 have been announced as part of the notice of this meeting 25 previously published in the Federal Register September 3, I
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1 1999..
(-s) 2 A transcript of this meeting is being kept and 1
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3 will be made available as stated in the Federal Register j
4 notice.
It is requested that speakers first identify 5
themselves and speak with sufficient clarity and volume so j
6 that they can be readily heard.
1 7
We have received no written comments or requests 8
for time to make oral statements from members of the public.
I 9
The subcommittee met on April 28-29 and June 10 30-July 1, 1999 and heard presentations on the Calvert 11 Cliffs and Oconee license renewal applications.
12 On the basis of these meetings and the associated 13 ACRS committee meetings, ACRS issued interim letters on the l
i 14 staff r(, )
15 evaluation of reports related to the license renewal
)
16 applications.
17 The subcommittee plans to use the information 18 presented today to develop a strategy for more efficiently 19 reviewing staff's evaluation reports and to establish a 20 schedule for reviewing selected issues.
21 I request that the staff, during its 22 presentations, provide suggestions as to when ACRS review of 23 specific issues will add the greatest value to the license 24 renewal process.
25 We will proceed with the meeting and I call upon
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1 Mr. Christopher Grimes, Chief of the License Renewal and
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2 Standardization Branch, to begin.
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3 MR. GRIMES:
Thank you, Dr. Bonaca.
My name is 4
Chris Grimes.
I'm the Chief of the License Renewal and 5
Standardization Branch.
Dave Matthews, who is the Director 6
of the Division of Regulatory Improvement Programs, will be 7
joining us.
8 This is a very timely meeting.
As many of you may 9
know, projection for the number of-license renewal 10 applications over the next several years is expected to 11 increase dramatically.
We have two applications scheduled 12 for submittal in the near future. Arkansas is planning on i
13 submitting its license renewal application in December of I
14 this year and Hatch is expected to submit its license
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15 renewal application in February.
16 In the subsequent years, we're expecting or we're 17 planning for four license renewal applications in fiscal 18 year 2001 and four in 2002, and the information that we have 19 is that by 2003 to 2005, we could be working on as many as 20 seven to ten applications at any time.
So the purpose of 21
-today's meeting is to concentrate on where we stand relative 22 to developing guidance for the conduct of the license 23 renewal reviews, to describe our plans for responding to the 24 Commission's staff requirements memo on credit for existing 25 programs, to focus on areas where programs need to be i
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augmented for the purpose of aging management, j )
2 We're also going to reflect on how we got to this 3
point based on the developmental work that was derived from 4
the nuclear plant aging research program that began back in 5
1982, and then we're going to discuss the status of the 6
Calvert Cliffs and Oconee applications.
7-We intend on coming back to the committee to 8
discuss the resolution of the open items, but by discussing 9
the status of those two renewal applications, it may give 10 you some insights into process means.
11 So for that reason, we can talk about where we 12 stand relative to the review of t"? first two applications 13 in order to provide some insight. for developing ideas and 14-strategies on how to make the rev_uw effective, efficient
)
15 and realistic using the terms from the strategic performance 16 measure that we feel is most appropriate at this point to 17 the future of license renewal.
18 We're going to begin the staff's presentations 19-with a discussion about the development of license renewal 20 guidance and I will ask Mr. Matthews if he has any other 21 opening remarks, before we turn it over to the staff 22 presentation, i
23 MR. MATTHEWS:
No.
I don't have any additional 24 remarks this morning.
Thank you.
l 25-MR. GRIMES: 'With that, I'd like to introduce Sam O
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Lee, from the License Renewal and Standardization Branch, j
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2 and Jit Vora, from the Office of Research, and they're going O
3 to discuss the development of the license renewal guidance.
4-DR. LEE:
Good morning.
This is the schedule, and 5
now we are on the development of license renewal guidance.
'6 My name is Sam Lee, from NRR, and I have Jit Vora, from 7
Office of Research.
8 The licente renewal rule requires aging management i
9 of long-lived passive structures and components.
In the 10 initial license renewal applications, we found that most of 11 the license renewal programs are existing programs.
12 So NEI raised a question on credit for existing 13 programs; that is, to what extent should the staff review 14 existing programs relied on by an applicant to manage aging t-'y
( )
15 for license renewal.
16 This was raised as a policy issue to the 17 Commission and the staff prepared an options paper, 18 SECY-99-148, and the staff made a recommendation to do a 19 generic evaluation of existing programs and focus the 20 standard review plan for license renewal on areas where 21 existing programs would be augmented.
We briefed the ACRS 22 and we received ACRS endorsement.
23 And similar to that, the Commission also approved 24 the staff's recommendation and directed the staff to develop 25 this generic evaluation, which is called the generic aging O
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lessons learned, the GALL report, and to develop the SALP l[j 2
and the reg guide, and have stakeholder involvement.
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3 We plan on issuing these documents for public 4
comment and we are to brief the Commission on the public 5
comments and then request the Commission approval to publish i
l 6
these documents.
7 Also, in the SRM, the Commission indicated that l
8 after the steff had reviewed additional license renewal 9
applications, we should return with our recommendation on 10 whether we should undertake rulemaking to provide credit for 11 existing programs.
12 Now I'm going to talk about these reports, the 13 GALL, the SALP and the reg guide, in more detail.
l 14 GALL is a generic evaluation of existing programs
(
15 to manage aging.
If the program is found adequate, the GALL 16 will document the basis for that determination.
If certain 17 things are needed in addition to what people are doing 18 today, then GALL will identify these areas, so that they 19 would be augmented for license renewal.
20 Previously, staff contractors had published a 21 contractor report on GALL, which is a compilation of plant 22 aging information.
I'll get into that later.
We plan on 23 extending that study to review the aging effects, identify 24 existing programs, and actually evaluate the elements of the 25 program to determine if they're adequate to manage aging for D]
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l' 2
Some of the elements are the scope of the program, 3'
does it cover the right structures and components, what kind 1
4 of inspection method are people using, is the inspection 5
adequate.to find certain aging effects, and what kind of 6
acceptance criteria do they have, what kind of corrective 7
action.
8 The GALL right now is being conducted by Argonne 9
and~Brookhaven as contractors to the staff and they have 10 prepared a draft.of the report and it is now under staff 11 review.
12 We plan on involving stakeholders and, for i
13
. example, we believe the industry can provide information on l
14 existing programs that can be evaluated by the staff in 15 GALL, also.
16 This is the standard review plan for license 17 renewal that's in the staff recommendation and the
,1 18-
' Commission SRM.
We are going to focus the staff review on l
l
-- 19 areas where existing programs should~be augmented for 20-license renewal.
This will reference GALL for the credit 21 for existing programs and one of the things that we are to l
22 work out is a template in' terms of how to take GALL and kind 23 of propagate it into the SRP.
So we still have to work that 24 out.
If GALL says this program is adequate, the reviewer 25 has to look.
If GALL says it's not adequate, what the ANN RILEY & ASSOCIATES, LTD.
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1 reviewer. ids to do.
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2 Anocher thing is that once GALL identifies there 3
.are certain things that need to be augmented, the SRP needs 4
to provide guidance on an acceptable way to augment a 5.
. program.
So those things needed to be developed.
Also, we 6
.need to incorporate lessons learned from the initial license 7
renewal applicaticn reviews and the license renewal issues.
8 You will' hear about license renewal issues, I
.9 guess, in a subsequent presentation, 10 Another thing is to improve the efficiency of the 11 review.
The SRP should match the format of the application 12 and this is one of the things that we have been working on 13 with NEI.
14 So we can have the next slide.
()
15 We have been working with NEI on the standard 16 format for an application and this is what I guess the staff 17 proposed to you in August.
We have a couple iterations on 18 that, and now we have NEI's general agreement on this 19 format.
This follows the structures of the rule.
So the 20 first section of the application would be cdministrative
'21 information, like plant ownership, plant 11 w.se and 22 proprietary information type of statements.
Section 2 is on 23 the structures and components for license renewal.
This is 24 on..the scoping methodology to identify these structures and 25 components and the results of their scoping.
Three is the ANN RILEY & ASSOCIATES, LTD.
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This is the bulk of the application, f(g
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2 which is aging effects, aging management programs and such.
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Section 4 is the time-limited aging analysis.
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This is analysis that has been performed for 40 years of 5
plant operation and we need to evaluate how that will I
6 continue for license renewal.
7 Then we have sort of an appendix here, on the FSAR 8
supplement to summarize the aging management programs, and 9
the time-limited aging analysis for license renewal.
10 And the intent is to have the SRP actually match 11 the application one for one.
So hopefully we have a Section 12 1 of the SRP that will address the first item, and Section 2 13 would match the Section 2, so on and so forth.
14 We also have a reg guide on license renewal.
NEI
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15 previously developed Industry Guidance 95-10.
This is on i
16 the implementation of license renewal.
The staff issued a 17 draft reg guide for public comment to endorse this 95-10 18 document.
Now we plan on having NEI to revise 95-10 to 19 incorporate what is ongoing activities and then we will l
20 revise 95-10 for endorsement in a reg guide.
21 DR. SHACK:
Do you have NEI buy-in to this 22 process?
23 DR. LEE:
Say that again?
24 DR. SHACK:
Do you have NEI buy-in to this 25 process?
I )
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'DR.
LEE:
I believe we have, yes.
Do you want to
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2 say.something, Doug?
3~
MR. WALTERS:
Doug Walters, from NEI.
I'm not 4
sure exactly what you're referring to when you say the
'S process, but I will tell you-we just signed a letter out and 6
'gave'it to Mr. Grimes denoting our agreement with the 7
standard format.
8 LDR. SHACK:
And the process for essentially l
9 incorporating the GALL into 95-10?
J 10 MR. WALTER:
Yes.
I think, in general, we agree 11 with that.
Obviously, we haven't see the specifics and 12 we're getting some of that today, but I think, in general, 13 yes, we would agree.
l 14 DR. LEE:
Thank you, Doug.
And here is the draft O
15 schedule for some of the milestones.
This has not been g,f 16 approved by management, but this shows the current staff l
i 17 thinking.
18 One milestone is a workshop on the draft SRP, 19 mostly likely in November, and, also, the issue of the draft 20-SRP, GALL and 95-10 reg guide, about summer next year.
Then 21-there is a Commission briefing on public comments and here 22 is Commission approval of SRP.
This is early 2001 and prior 23.
to that, we will brief the ACRS and request a letter to 24 support the Commission approval.
25 We will be having, I guess, meetings with ACRS to l
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keep you updated on the current activities.
But these are i
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just some milestones that we need a letter from ACRS at that L.)
3 point.
i 4
Also, we will be briefing the Commission on the 5
option to have rulemaking, probably like 2001, late in 2001.
6 By that time, we will have, I guess, Arkansas, Hatch, and 7
Turkey Point under review at that time.
8 MR. GRIMES:
Sam, I'd like to comment that when we 9
put this schedule together, we recognized that it's a fairly 10 ambitious schedule, but that's an expectation.
The 11 Commission is anxious to see the standard review plan and 12 GALL processed, to achieve some stability and 13 predictability.
14 So what's most important to this schedule is
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15 biting off what we can chew.
So we will be looking at 16 taking the largest chunk of work that can be digested in the 17 shortest period of time, and that's one of the things that I 18 would set out in that first milestone, meeting with NEI to 19 develop a scope of effort that can be achieved in this 20 timeframe.
21 The Commission also recognized in the staff 22 requirements memo that the guidance would likely become
)
23 living documents, like the standard review plan is today.
24 So we're going to talk a little bit about generic renewal 25 issues and how we've gone through and prioritized those and l ("'
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I would expect that the process would continue in the
-( )
'2 future, where we constantly look across an inventory of 3
recommendations and issues to address and concentrate on 4i getting'the most bang'for the buck, getting the most work 5
' accomplished in the shortest time, in order to achieve a 6
maximum amount of efficiency and effectiveness in the
'7 process.
8 DR. LEE:
Now we are going to give you the 9-background of GALL.
This is a contractor-prepared document, 10 I guess,'back in.'96.
It's called GALL and it is an 11 extensive compilation of plant aging information.
12 It is based on the Office of Research's nuclear
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13 plant aging research program, NPAR, and Jit will explain 14 what is NPAR in more detail.
It also consists of NUMARC,
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g, 15 the Nuclear Management and Resources Council, NEI's industry 11 6 report on managing aging of major plant components for
.17 license renewal, and they cover reactor vessels, reactor 18 vessel internals, containment, structures, piping, that 19 kind.
20 It also covers operating experience, the LERs and 21-generic commur'.catio.s.
But the bulk comes from the NPAR 22 program.
23 And now I will turn it over to Jit, from the 24 Office of Research, and he'll give you more on the NPAR i
25 program.
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14
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l' MR. VORA:
Thank you., Sam, and good morning, Mr.
()
21
' Chairman and members of the committee.
My name is Jit Vora 3
'and currently I'm a team leader for the license renewal l
4 project team in the Division of Engineering Technology of 5
the Office of Research.
1 l-6 This morning I would like to present to you and I
L 17' discuss'with you some of the key elements and the main 8
features of now completed nuclear plant' aging research 9
program, or the NPAR program.
The NPAR program is a 10 hardware-oriented engineering research program.
11 Early in the program, it was recognized that aging 12
-- the age-related degradation effects and mitigation 13 measures should be addressed for the renewed license or at 14 that point in time we talk about the life extension of the
)
15 operating nuclear power plants.
16 At the same time, we had recognized that 17 understanding age-related degradation effects and managing 18 its detrimental effects during the renewed license period 19 would also benefit many of the issues for the current 20 license term.
- 21 In this particular program, five national labs 22 were involved, along with the National Institute of Science 1
23 and Technology and the Wyle Laboratories.
So then there 24 were a number of staff involved in this program, so one of 25 the things that we tried to do is actually have a uniform
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1 definition or understanding or the working definition of
)
2 what constitutes aging.
This was actually a part of the now J
3 completed program.
4 And it was defined as a cumulative change in properties or 5-performance which occurs over a period of time, and we 6
mention about the properties as primarily involving the 7
long-lived passive components and structures and we talk 8
about the performance, we understood the aging associated 9
with the active components, such as motor-operated valves, 10 circuit-breakers, and relays.
And if unmitigated, aging can 11 result in loss of function and impairment of safety.
12 The scoping studies for the NPAR program, many 13 workshops and major workshops for the age-related issues 14 have been completed during the 1982-84 timeframe, and the
%s) t 15 nuclear plant aging research program, a comprehensive 16 program plan was developed in 1984 and we had issued the 17 program plan in the NUREG-1144.
18 In 1985, I was privileged and I had the opportunity'/to accompany my division director, Mr. Guy 19 20 Arllato, to the Office of the EDO, Mr. Vic Stello, and Mr.
l 21 Vic Stello talked about the subject of life extension 22 license renewal and he asked Mr. Arllato, this time around, 23 if we talk about life extension going beyond 40, how we are 24 going to put our arms around this issue.
We better have 25 some good technical basis when we actually go about the life
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extension license renewal.
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2 And Guy immediately replied to Vic, the way I
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3 understand it, it is going to be very important to 4
understand the age-related degradation effects and ways to 5
mitigate these effects during the renewed license period.
6 And what he further stated is that we better do our homework 7
now and do it now, so ten years from now, 15 years from now, 8
when we're really going into the renewed license phase, we 9
have a good technical basis upon which we all have the 10 confidence that, yes, we recognize age-related degradation 11 effects, but yet, also, it is possible to manage the 12 age-related degradation effects which could be detrimental.
13 And at that point in time, the EDO, Mr. Stello, 14 directed an interoffice review group or working group,
( ),/
f 15 called the technical integration review group for aging and 16 life extension, and the members of this review group 17 included branch chiefs and the division directors, Mr. Ed 18 Jordan was involved, Mr. Brian Sheron, Mr. Larry Shao, and 19 they published a program plan in 1987 to integrate the 20 age-related degradation activities within the agency.
21 The purpose of this plan was actually to identify, 22 at that time, they called it the technical safety issues 23 related to aging and life extension and the regulatory 24 issues, which we should visit or evaluate for the extended 25 life considerations.
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The other part was to actually evaluate the n
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2 effectiveness of the ongoing programs to manage age-related v
3 degradation, and the third objective of the plan was to 4
actually provide the future direction to the Office of NRR 5
and Office of Research.
6 Also, during the 1987 timeframe, Chairman Zech, 7
Mr. Stello, Mr. Arllato and myself had the opportunity to t
8 actually go to the Congressional hearing on the safety 9
implications of the aging of nuclear power plants, before 10 Mr. Sharp's subcommittee, and the purpose of this hearing 11 was to see actually how the NRC and the industry is doing to 12 ensure that the plants -- as the plants get older and the 13 equipment wears out, they continue to operate safely.
14 Then actually in 1993, my current division I
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15 director, Mr. Craig, also briefed the Commission on the 16 overall aging research program.
This hardware-oriented 17 engineering research program or the NPAR program was 18 completed in 1995.
It involved, as I mentioned earlier, the 19 five national labs, PNL, Brookhaven, Argonne, INEL, and 20 Sandia.
It also involved the NIST and the Wyle 21 Laboratories.
22 Upon completion of this program, by 1993, 23 actually, we had issued 141 technical reports on various 24 components, systems and structures.
We studied the PWR and I
BWR systems and components.
We had completed the study on 25 l
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22 ' components, 13 systems, and' ten special topics.
The
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- results of these reports and the studies have been 3
summarized in'a bibliography and abstract in NUREG-1377,
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4 which-is-widel'y distributed and is now also being used 5
throughout.the country, as well as outside the agency and l
6
- overseas.
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'7 The overall scope.of the aging-related program 8
inclu'ded primary system pressure boundary components, 9
reactor _ pressure vessel, the steam generator, the piping 10 NDE.
It also involved. electrical.and mechanical components, 11 such as motor-operated' valves, check valves, pumps, l
12 circuit-breakers, relays, cables, transmitters, batteries, 13 battery chargers and inverters, RTD, et cetera.
i 14
.With regard to the safety systems and support
/
f 15 systems, we have the reactor protection systems, relief 16 water system, active feed water system.
We also had an 17
. aging-related' program on the containment and civil E18 structures.
19 And a part of this NPAR program, and this is a 20 ivery.important element of the program, we did some special j
21' topic studies.
It includes the residual lifetime evaluation j
22 of long-lived passive components and structures..
It i
23.
-includes a' program about the record-keeping needs and data l
24
' trending for an' effective aging management.
I 25 It also included to evaluate inspection I'
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integration activities.
We did a study on the degradation I i 2.
modeling.
We reviewed the effectiveness to manage aging and V
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_3 other regulatory interments.
And one of my primary l
4 responsibilities was to' integrate all_these research 5
activities with five national labs, the other contractors, 1
6 within the Office of.Research, and within the agency and
-7 also outside th,e agency.
8 Domestically, we integrated this program with the 9
Department'of Energy, Electric Power Research Institute.
I 10 had an opportunity;to go to NASA at the Langley Center to 11 see.some of'their diagnostic and condition monitoring 12 methods.
I had the opportunity after the Aloha incident to 13 visit the FAA, because they wanted to start a comprehensive 14 aging program to manage aging in the older jet aircraft.
()
healsohadinteractionswithIEEEandASMEand 15 16 also the Department of Defense, that I was privileged to 17 evaluate-the maintenance effectiveness to manage aging in 18
-nuclear power submarines, and, through that effective 19-
. program,.they are actually able to increase the overall time 20 from X years to 2X years.
21 I think this is actually some of the key elements 22.
of the overall-program.
Because we had five national labs, 23 we_ started with something like 40 components recommended by 24 the Tirgalex review committee.
We had different project 25 managers.
But what we wanted to do is streamline and make ANN RILEY &-ASSOCIATES, LTD.
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sure that we have a clear understanding of how we go about
[
j 2
understanding and manage aging in the operating nuclear s/
m 3
power plants that involve systems, structures and 4
components.
1 5
So one of the key elements of the program was to i
6 understand aging.
So whether a component is a 7
motor-operated valve or check valve or a cable or a water 8
system or a reactor pressure vessel for internal, we defined 9
the component or system boundary of interest.
10 Once we do that, let's identify how well we know 11 the materials which are used in the design, construction, 12 fabrication of that component and system, and when it is 13 installed, what other materials might have been used for the 14 lifetime of the components, systems and structures.
The i
15 more we know about the types of materials which are used for 16 that component, that will be very useful information to 17 understand the age-related degradation effects.
18 We also want to identify for that component what 19 are the operating environments within its application for 20 the -- talking about the temperature, radiation, humidity, 21 et cetera.
22 We also identify what are the stressors which 23 might be associated with that component during its 24 operation.
We talk about electrical stressors, the 25 mechanical, the thermal, which are actually the operating
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stressors for that given component over its lifetime.
L [-)
2 And most importantly, the materials, the
\\_/
3 stressors, the environment, and their interaction over time 4
would give us the insight to understand the age-related 5
degradation or the aging effects and to identify what are
'6 the key aging mechanisms and, more importantly, to identify 7
what are the degradation sites, where these aging mechanisms 8
are operative.
9 So we identify aging mechanisms and also try to 10 identify where within that component boundary those key 11 aging mechanisms which could be detrimental are within the l
12.
site of the component boundary.
So we identify the 13 degradation sites, and this is true for -- if you look into 14 any of these component reports within NPAR, whether it's
(~m
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15 MOVs or we're talking about the reactor internals or a cable 16 or containment structure, the contractor involved and the 17 project manager involved would have a section on the i
18 understanding aging.
i 19 For that component, they will identify the 20 mechanisms, its effects, and what are the degradation sites.
i 21 Some of the key aging mechanisms that we have l
22 identified as part of the program are very straightforward.
23 We are addressing the fatigue, erosion and corrosion, 24 radiation embrittlement, thermal embrittlement, chemical and l
25 biological effects, creep, and operational and environmental l
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?1 effects.
(
2 The' creep became actually an issue when it 3
involved the' polymer and insulating materials, if they're 4
subjected to high temperature and if you have pressure and 5
. vibration, there is a possibility that insulating materials I
'6 or epoxiesccould creep over time.
7-Then came the next phase 1of the program.
Once we 8
identified the age-related' degradation effects with 9
. materials, stressors, environment and where the degradation 10 sites are, what are the effective aging mitigation methods 11 for;those specific age-related degradation mechanisms at 12
'those sites.
13.
We looked into part of the program for every 14-component, system and structure, how effective are 15 inspections, surveillance, condition monitoring.
The 16-record-keeping and trending is a very important part of 17 actually tracking the age-related degradation over time, the
)
i 18 refurbishment, replacement, general maintenance, or when you 19 can actually change your stressor and environmental 20 conditions to manage age-related degradations to mitigate.
21 For every component, system and structure, we use 22 a phased approach to research.
Once we selected components, 23-systems and structures, the Tirgalex identified 40 24 components, systems and structures.
The selection of 25 components and systems was a hybrid approach.
We had over ANN RILEY & ASSOCIATES, LTD.
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35-40 years of design experience, with 25 years of operating
)
2 experience.
We had an expert panel.
We also looked into j
3 from the risk insight and we put all these things together 4
and we had a report actually called the prioritization of l
5 the Tirgalex components, where we brought all this 6
information, we did our selection of components and systems 7
and structures.
8 And once we did that thing, as I stated earlier, for understanding an!
knaging aging, we ran systematically 9
10 for that component, system and structure to evaluate the 11 age-related degradation and its mitigation metho'd.
An 12 important part is question, everybody was sensitized to ask I
13 the question what happens with time.
I think that was the
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14 baseline actually, where we look into the inspections or
)
(j 15 maintenance effectiveness or we're talking about ISI, IST or 16 tech spec requirements.
We're sensitized to ask the 17 question what happens with time as a part of the NPAR 18 program.
19 We identified the functional indicators and 20 parameters.
This is very important, in my mind.
Every 21 component, system and structure has certain indicators or 22 parameters.
By trending those things over time will give us 23 an indication of results throughout the operability life.
24 For MOVs or for cables, we identify what we should check, 25 what we should monitor, what we should trend, which will I
l
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24 l1' give uscan-indicat' ion of the degradation effects over time.
' /' T L 2
.Then actually we can establish the criteria that Q
3l when it exceeds above those' points, that we need to do some 4-
' mitigative research.
.5-But'for each of these components, systems and
.L.
'6-structures:we studied,.we'did identify _those indicatorsLand 7
parameters, and we reviewed inspection condition, monitoring methods,.and we reviewed.applicableLregulatory requirements,j
-8 L
9
. codes and' standards.
j 10 This is phase one, which is primarily a paper 11.
study.
We looked into the NPRDS, we looked into the LERs, 12 IPRDS, other programs, the industry program, the code 13 standards.
Talked to the designers, to the vendors, and 14 brought this'information.
()
15 And for many components, we find out that there 16 are no significant. age-related degradation effects which are 17-not being managed today.
And for that, those components, 18 systems-and structures, we did not have to do the phase two l
19 study'as a part of the NPAR program.
l 20 For certain components, systems and structures, we
- 21 =
did some studies on those things as part of the phase two 22 program,.was primarily to do some confirmatory in situ 23 condition monitoring.
Once we identify the age-related 24 degradation' effects, identify the indicators or parameters 25 which will givggus the health of the component over time.
q
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Sometimes we were actually provided an opportunity
/~x (V) 2 to do some in situ monitoring and checking of the naturally 3
aged component versus a new component.
We were able to 4
actually monitor, for example, the cables in a given plant i
5 where we had the new cables, with the same vintage of cable 6
with ten years, 15 years, or if you can monitor the R factor 7
or power factor, or the testing or modulus, would that give 8
us an indication of health of the component over time and to 9
see whether diagnostic and condition monitoring method is 10 effective indeed to detect the age-related degradation.
11 And then the final phase of the program was the 12 utilization of the research results.
13 Based on the experience gained from the NPAR 14 program, we have actually provided the technical basis to
)
15 support the initial license renewal rulemaking, the first 16 one.
Actually, also develop the reg guide on the format and 17 content.
This is the earlier version of this one.
18 We also provide the support on the development of 19 codes and standards, like, for instance, IEEE Standard 1205, 20 which talks about understanding and managing aging in the 21 el,ectrical components in operating nuclear power plants.
22 We also provide the support for the development of 23 bulletins and information notices, the resolution of generic 24 issues which involve primarily the mechanical components, 25 and we also, in many instances, what we heard from the
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1 regions on certain issues about the aging of water systems 2-or the chlorine release from the cable, that we are able to 3
provide.some of the technical input and insight and some 4
references which were useful also to the regions.
l 1
1 i
5'
'And we'are continuing.to support the current l
- 6 --
activities of license renewal and many of the current 7
activities for license renewal include the development of 8
the GALL report, the development of the standard review 9_
plan, and many of the license renewal technical issues which 10 have been assigned to the Office of Research.
11 And currently, as a part of my responsibility, I 12 am integrating the various activities of the Office of 13 Research within NRR and Research.
I have the opportunity 14 and they were very grateful to invite me to every week on 15.
the two-step interface meetings and then I take that 16
.information and data and try to get it to the right people
'17 in the Office of Research, so that the programs are totally j
18 integrated, and try to do the effective job to support NRR i
19 in everything.
20 I think'the important thing is that the NPAR 21 program, the reason Mr. Stello and Mr. Arllato had, in the l
22' early '80s and mid '80s, and last ten to 15 years of work on 23 the nuclear plant aging research program has provided some 24 good sound technical bases and much more confidence to make 25 our decisions that as we go from 40 to 60 for extended life, t
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that, okay,.we do have the technical bases, we have the
()
2, approach, and we can bring all this information together for 3
the next step.
1 4
lSo.this~is the part of my presentation, and thank I
5' you;very much, Mr. Chairman.
f 6
DR. BONACA:
Thank you, d
l 7
DR. SHACK:
Do you feel that those results were 8"
captured in the standard review plan?
Would that be the 9
real document that really puts this to use for the license 10 renewal process?
J
~11 DR. LEE:
Yes.
These are in the real document, 12.
but the thing is GALL is like the basis document or SRP.
13-You provide a basis why some of the programs are adequate.
14 DR. SHACK:
It just seems to me, as I think about
()
15 it, the standard review plan sort of stops at the -- it's 16 selecting components, it's looking at some of the designs 17 and characterizing the aging mechanisms, but it really kind 18' of stops short of identifying parameters.
I 1
19.
It really didn't incorporate that part of the 20 information, did it?
L 21 DR. LEE:
It will.
l 22.
DR. SHACK:
It will.
23 DR. LEE:
It's in some of the -- the draft SRP has 24 some of that information already, but it doesn't cover all 25
-the parameters.
It doesn't cover all the programs.
f)
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MR. VORA:
Also, information of the GALL report, 2
as we go through it,.. talking about mechanisms, the effects, 3
and we're going through the. evaluation and the references, J
4 at that point in time, we also integrate the others to 5'
identify -- when we do the evaluation, we'll identify the 6
. parameters.
7 DR. SHACK:
Okay.
I felt the SRP was better at 8
raising questions than it was at answering them.
j 9
MR. VORA:
Yes' The GALL report we integrate into l
10 the next version of the SRP.
It should be an integrated 11 approach.
12 DR. LEE:
I guess the draft SRP raised a lot of 13 questions and we have to case-by-case, we will.
As we move 14 on, we'll learn more and then we'll be able to put in some rr
(
)
15 acceptable methods to address it.
16 DR. BONACA:
I had a question regarding the GALL 17 report.
I didn't understand.
Is the GALL report going to 18 be_a living document?
What I mean is that it seems to be 19 the results of the review of 550 different documents and so 20 it really reflects past experience.
And as we go forward 21 and we have more information about aging, will it be updated 22 on a routine basis?
Is that the plan for it?
23 DR, LEE:
Yes.
The GALL and SRP will be updated.
24-We are just looking backwards now, because we are moving on 25 to GALL, also.
1 J
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29 1-MR. VORA:
The GALL-was reported, was published in
()
2
' December 1986 and it took'the information up to that point 3'
and the draft of the GALL-2 report now has the information 4
to 1998.
We are reviewing, for instance, as we said, 5
program, too, that we a,re going to bring in some of the work 6
that was done since 1993 to date.
So I think hopefully we 7
will keep it up-to-date.
j j
8 DR, ]BONACA:
You also showed, in your last 9
overhead, under license renewal, three bullets.
One of them 10 is the GALL report, standard review plan, then you have 1
11 license renewal issues.
12 I imagine that by the time that we get to a 13 finalized procer, those will be all closed, those issues.
14 DR. LEE:
Well, as people identify issues, we will
()
15-address them.
Hopefully, the inventory will go down.
We 16 have like 100 license renewal issues right now.
I guess 17 that's the next presentation.
We are trying to work in the 18 Office of Research to contribute significantly to the 19 effort.
20 But as industry or the staff or the stakeholders 21 identify issues, we're going to use that process to continue 22 to address it.
23 MR. VORA:
I think some of them are for process 24 issues, some of them are technical issues.
So the technical 25 issues are being narrowed down and Research and NRR together l/
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1 willotry-to address them.
()j f
2 DR. BONACA:
I understand.
Because some of the 3
issues really would be dealt with as we learn more in the 4
future..So some of the determinations would be long-range.
5 Okay.
6 MR. GRIMES:
This is Chris Grimes.
I'd like to 7
comment that the vision that I have of the generic license 8
renewal issues is that we would hope to work off a large 9
quantity.of them early in the process, but I think we are 10 going to always have to deal with the existing process, 11 suggestions and issues that need to be addressed.
12:
We're going to continue to learn from events and 13 develop generic communications that contribute to 14 maintaining plant safety.
I would expect that we're going
()
15 to' continue to have opportunities to improve our 16 understanding of how aging can be managed, i
17 So I.think that there is always going to be some 18 generic renewal issues that are pending and I think what's 19.
most important to the process is that the process clearly 20 identify which of those things need to be done for the 21 purpose of improving the decision process for the licensing 22
'as clearly distinguished from technical issues that need to 23 be dealt with in the arena of conducting research for the 24 purpose.of improving knowledge.
25 We always need to focus on distinguishing the l
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l' generic renewal issues just like we distinguish the safety 2
issues.for present license requirements.
3' DR. BONACA:
I guess my question was trying to 4
understand how their closure will affect-individual j
5 applications and approval of the applications.
I understand 6
how some of them can be dealt with by commitment for future 7
closure or future inspections maybe, but I'm trying to
(
8 understand how, as issues are being raised, they're going to 9
be dealt with with the plants that already received an 10-approval for li'e extension.
11 MR. GRIMES:
I would expect that they're going to 12 have to be dealt with in the same way, that we would have to 13
-impose the same rigor that we do on the development of new 14 requirements, as they relate to existing licenses, and when 15 we make future decisions about changing the decision 16 criteria on what constitutes an acceptable aging management 17 program or what constitutes an applicable aging effect,
-18 we're going to have to reflect back and cee whether or not 19 that affects_ previous decisions in license renewal.
20 That's why, as'I mentioned before, we have such an 21
' aggressive schedule to try and get through the bulk of the 22 generic renewal issues as early as possible in order to 23 minimize the potential impact on these initial license 24 renewal decisions.
l 25 DR. BONACA:
Thank you.
l O
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MR. GRIMES:
Are there any other questions about
-[~h 2
.the developmen?. of license renewa: guidance?
3 DR. SHACK:
I guess it's still not clear to me --
4 it seems to me a large part of the guidance is actually the 5
existing license'-- the application fr o the last guy.
I 6
mean, if.I was writing my license application, my chief f
7
' guidance would be the one that made it through the process.
8 I'm not sure how that gets captured here and maybe 9
it shouldn't be.
There's sort of a precedence, a common law 10 kind of -- you know, if it worked for this guy, it's going 11-to work for me thing, but you seem to be reluctant to give 12 those generic blessing, but, in fact, I suspect they will 13 turn out to be generic, because, again, if it worked for 14 this guy, why won't it work for the next one.
()
15 MR. GRIMES:
And that's the part of the struggle
)
16 that we have, is that we deal with issues on a 17 plant-specific basis, but then the community as a whole, all 18 of our stakeholders don't necessarily agree that that's the 19 right answer that's going to apply for everybody.
l 20 So what you see in the standard review plan today 21 is basically our best guess at what would constitute the 22 decision basis upon which we do the first two applications.
23 Well, the first two applications didn't turn out exactly 24 that way.
We discovered, first and foremost, this 25 opportunity to reformat the standard review plan so that the O
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decisions are made more consistently with the structure of
[
'2 the rule, in. terms of scoping methodology, identifying 3
systems, structures and components that are passive and 4
long-lived, identifying aging effects, and then going into 5
the aging management programs.
6 So you're going to see a large move towards having 7
the standard review plan more consistent with the decision 8
basis that we came to for these first two applicants, but 9
then there are still going to be these minor details that 10 we're going to sort out.
And as'we talk about how we're 11-going to address generic renewal issues, a lot of the j
12 questions that were left unanswered in the standard -- the 13 first draft of the standard review plan, we've now dealt 14 with.and we can go through and learn from that experience
]
()
15 and focus on, as the Commission pointed out, focus on those i
16 areas where we believe that there is a firm foundation for a I
17 need to augment existing programs.
18 So the approach that Sam and Jit have described is basically 1
19-to take our collective experience now and to re-craft the 20 standard review plen so it looks more like the decision 21 basis that we used for Calvert Cliffs and Oconee, or will 22 use.
L 23 So we're moving in the direction of having the 24-process, keep the standard review plan in conformance with 25 the decision process.
l (O)
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34 1-DR. UHRIG:
The two applicants to date, Oconee and II 2
Calvert Cliffs, have different structures.
One has been V
3 characterized as being a vertical structure and one has been
.4 characterized as sort of a horizontal structure in terms of 5
the approach that they've made.
i 6'
Has there been any preference, from the staff's 7
standpoint, as to which approach they would prefer or is 1
8 this an issue that is strictly left up to the utilities?
9 MR. GRIMES:
This issue is being resolved in the 10 context of the-standard format and it ends up being more of 11 a horizontal than a vertical structure, because even for the 12 staff, we find that it's more efficient to deal with 13 programs that cut across a large body of systems, structures 14 and components and evaluate them once, rather than 15 evaluating them on each individual structure or component.
16 But we still find that in the context of better 17 understanding the methodology for scoping, that there be a 18 little bit more vertical in terms of making clear what is 19 the scope that these programs apply to.
I think that we're 20 headed towards an agreement with the industry that we can 21 find some efficiencies in packaging that will basically 22 address.the major programs and then smaller commodity groups 23 in a more efficient way.
24 DR. UHRIG:
Will this be included in the standard 25 review plan?
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MR. GRIMES:
We would intend to reformat the f
'['
2:
standard review plan to follow the standard format.
We
\\.
l 3
would expect the standard review plan to talk about the l
4.
review process in that way.
'5 DR. UHRIG:
What is the time scale on that?
It j
6
'was here, I think.
7 MR. GRIMES:
Actually, we'll start with-the letter 8
that was just handed to me, which is NEI's agreement on an j
9_
approach to the standard format, and then we would expect, 1
10 in accordance with the draft schedule that Sam put up, to 11
.have a revised standard review plan worked out by next 12 summer.
13 DR. UHRIG:
So that really won't affect the two 14 anticipated applications.
O)
(,
15 MR. GRIMES:
Arkansas and Hatch have been very 16 closely following the dialogue on the standard format and 17 both of them are going to -- have indicated a desire to 18 comport, to the extent that it's practical for them to do
.19 that.
20 Are there any other questions?
[. o response.]
21 N
22 MR. GRIMES:
Okay.
If you are ready, we'll move 23 on to the next presentation, by Jake Zimmerman.
He is going 24
.to describe where we stand with respect to sorting out and
~
25 managing the generic license renewal issues.
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1
'MR.
ZIMMERMAN:
Good morning.
My name is Jake 2
Zimmerman'.
I'm a project manager in the License Renewal and 3'
Standardization Branch.
4 Today I'd like to cover with you the licence 5
renewal' issues, the process.and the status.
We've recently 6
gone through and re-categorized all of the license renewal 7
issues.. We've done away with the priority scheme.
I'd also 8
like to' discuss plans for resolving'the issues and what our i
9 schedules are.
shdI' 10 Let me just put this up first, but I'm sure many of you are
'11-wondering why are we re-categorizing it this time.
12 Categorization was done because the old prioritization 13 system was originally established with the concept that 14 selected issues would be resolved to support the staff A
i]
15 review of the first license renewal applications.
16 Since Calvert Cliffs and Oconee reviews are 17 proceeding through issuance of a new license, with 18 plant-specific resolution to these issues, and the generic 19 resolutions have not been established at this time for most 20 of these issues, we felt that it was time to go back and 1
21-reevaluate all of the issues and categorize them to, one, 2 2 _.
better focus our efforts to resolve the generic issues, to 23-separate them by their complexity, to allow better 24 identification of our resources needed and the schedules to 25 complete those reviews, and, also, to identify those issues CD Court Reporters
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which are-impacted by outside influences and thus cannot be V) -
.l 2
resolved until action is completed.
~3 What I'm referring to there is a Commission 4
decision or a plant-specific resolution that we're still 5
currently working on.
6 Therefore, we developed these four categories.
7 Number one, resolution pending management, Commission or
~Er plant-specific action.
The next two categories, high 9
technical complexity, medium technical complexity; 10-subjective decision as to where an issue would fall.
11 Basically, it's a value judgment between NRC and 12 industry, based on the issue's technical complexity, the
- L3 value-added of that resolution being completed and then also 14 the resources that we're going to need to resolve that
)
15 particular issue.
16 DR. KRESS:
Excuse me.
What exactly will you do 17 with.this information?
Will you assign different categories 18 to different people to work on or put more resources on the 19 ones that are higher technical complexity?
20 MR. ZIMMERMAN:
What we are planning to do, and I 21 will cover that a little bit later, is we're going to try to 22 develop a top ten like list and it won't necessarily be ten.
23
' Currently, it appears that there's going to be 19 items on 24 that list, and.that list will be developed between NRC and 25 the industry and the list will be a mix of category one, ANN RILEY & ASSOCIATES, LTD.
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two, three's and four's.
t-
[V) 2 Category nour's are easier, editorial in nature 3-and there's 45 items that NEI has categorized as category 4
four..So we feel that vue might direct some resources in 5
that area because there's more bang for the buck, so to 6
' speak, that we could close out.
7 Category one issues, there's currently three that 8
NEI'has identified, and I keep referring to what-NEI has l
9 identified.
The letter that we gave to you this morning is
'10 a letter that we just received from NEI, where they went through and re-categorized all the issues.
They took the 12 first cut at re-categorizing them.
13 We are in the process of evaluating their re-categorization.
14 Some of them we might not agree with and we sti.'.1 need to
()
15 work that out.
So that's where we stand with t'ae 16 re-categorization.
17 DR. SHACK:
You sort of half answe red my question.
18 This categorization still doesn't solve your prioritization 19 problem.
20 MR. GRIMES:
No.
And I'd like to add, it doesn't i
21 solve the prioritization problem, but it does help us to 22 understand better how to manage the workload.
Just the 23 categorization itself gives us some insights into where 24 we're having communication problems or where we've got some l
l 25 underlying conceptual disagreements.
So it's helpful in l
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that respect and it also is helpful from the standpoint of 2
trying to assign resources.
3 If both we and the industry agree that we've got
-4 one that's a'high technical complexity, then that's one 5-that's going to be very resource-intensive or demanding.
So 6
we'll be -- I would be more reluctant to dive into 7
commitments on resolving something that we and the industry 8
_both think is a very complex technical issue.
9 Whereas for all those things chat we and the 10 industry agree that it's easier, editorial in nature, then 11 maybe with just a little investment, I can get a lot of 12 stuff.out of the way.
13 So that's why we felt that the categorization 14 would be useful for the purpose of allocating resources and
[~~N g,)
15 committing resources to start working these issues off.
16 MR. ZIMMERMAN:
That letter that you have, there 17 are three issues in category one, there are 18 in category 18 two, 40 in category three, and 44 editorial style changes 19 that are in category four.
20 So just looking at the total number of issues, we 21-have 106 issues.
If we could handle some of those editorial 22 type issues, we could basically cut the list in half.
We 23 currently have approximately 25 issues that are under 24 review.
So we'd be basically down to 25 percent of the list l
25 that still needs to be planned and scheduled, i
l
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't 40 1-So'what are our plans for resolving the issues?
()
2 We're currently' working on a revision to Office Letter 805,
-3 that's NRR Office Letter, which is our license renewal
- 4-fapplication review process.
What we're doing is we're going 5
to incorporate a guide for processing license renewal issues L
~6 and.a formal appea'Is process for identifying and elevating 1
7-
. disagreements on NRC staff positions, and those are i
8 disagreements that the NRC staff and the industry have on.
9 those positions.
10 The' guide for processing the license renewal
'11
' issues will describe the overall process and the individual 12 steps that will be taken for identifying, documenting, 13 tracking, and developing the technical basis for resolving 14
.the license renewal issues.
O( j 15 The appeals process is a multi-step process that 16
- elevates in management involvement as disagreements remain 17 unresolved.
After each step in the process, the originator l
18 and/or.stakeholders have the option to appeal the l
19 disagreement to the next level of NRC management.
20 We're planning to also use that appeals process 21 for plant-specific' issues that come up during an 22 application's review.
And if necessary, issues related to 23 policy decisions will be raised to the Commission.
24 As I said, this is under development.
We plan to l
25
-- I had hoped to have it out before this meeting, but we're O'
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scheduled to have a license renewal steering committee f*% '
i
( )
2 meeting with NEI next week on the 29th and we're hoping to
.3 have it issued by then,. and once we do have it issued, we'll 4
certainly get copies of that provided to the members of the 5
'ACRS.
6 MR. GRIMES:
I would like'to add that the topic.
7 was discussed at the last steering committee meeting as it 8
related to the concerns that the industry expressed in 9
. relation to credit for existing programs, relative to the
~10 industry concern that license renewal reviews were going to 11 continually have an accretion of requirements or what's also 12 referred to as a regulatory creep; as we get smarter, we 13 become more demanding in the requirements.
14 And underlying that concern was basically to what
()
15 extent would the NRC rigorously hold to the scope of the I
16 review and a set of predictable requirements that would be c
17
' fulfilled.
This is not unique to license renewal.
This is 18 a similar concern that was raised relative to how license 19 amendments are processed, how many rounds of questions are 20 there, how do you stick to the standard review plan or the 21 applicable guidance.
22 So we're attempting to address it by having a very 23
-formal stylized appeal process that basically would permit 24 disagreements to, first, be recognized and revealed; that 1
'25 is, to stop dialogue and recognize that there is a
[
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g-lt 42 1
fundamental disagreement that needs to be resolved, and then
[~')-
2 have that disagreement work very formally through a process C
3L of decision-making and appeals, depending on.whether or not 4
either party, the NRC staff or'the industry or the 5
. applicant,.isn't satisfied that the decision was 6
appropriate.
7 It's the same concept.that we use to deal with 8
differing professional views and differina professional 9
opinions, and that is to take the personalities out of it by 10 simply saying, well, if we have a disagreement, here's what
'1'1 you do, here are the steps, here are the responsible 12 individuals who have to make decisions and stand by those 13 decisions.
14 So that is the concept that Jake is now attempting
)
15-to implement by adding an appeal process to our procedures.
1 i
16 MR. ZIMMERMAN:
Next, I'd like to talk about our 17 plans for involving stakeholders.
We do plan to encourage 18 stakeholders' input during the resolution of our license 19 renewal issues.
Our first' step in this process will be to 20 identify all of our stakeholders, and those could be 21 interested applicants, the public, and professional 22 organizations.
23 We must develop a means to notify them and I guess l
24 that's one of the things that we're going to ask the ACRS to l
25 provide us feedback on, is how we go about doing that.
One O'
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of the ideas that we're discussing is putting these issues V) on the license renewal web site so that the public will have j
2 3
that information available to them and that they could, 4
either through, we would hope, a formal letter documenting 5
their concern and perhaps a proposed resolution for the 6
issue, that would be something that would be acceptable.
7 But I guess we're looking for some feedback from the ACRS on 8
that.
9 MR. GRIMES:
I would also mention that I have 10 contacted Dave Lochbaum and Dave Lochbaum has agreed to 11 serve as a focal point for public interest groups and public 12 advocates and we need to negotiate through him some way to 13 try and get some more public advocates involved in the 14 comment and review process.
/"%
(_,)
15 As Jake mentioned, the first step in trying to get 16 more exposure would be to put the proposed issue resolution 17
-- put the issuus and the proposed resolutions out on the 18 web and see if we could stimulate some more feedback from a 19 broader range of stakeholders.
20 We also need to figure out whether there is some 21 way that we can get contacts in the ASME, the IEEE and the 22 other professional organizations to participate in some kind 23 of dialogue on the resolution of generic renewal issues.
24 DR. SHACK:
Somewhere, is there a more complete 25 description of the issues than we seem to have in the tables
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44 l1, that we get in the list?
~2 MR. ZIMMERMAN:
Tha't is the most complete 3~
description that we have in our database.
Early on, we 4
identified;that some of these issues were not very clear as-f 5
to what specifically the problem was and rather than go back i
1 6
and try to re-clarify all of the issues, there were meetings 7
'and conference calls to discuss specific issues and as these 8
issues were worked, the clarification was developed and the 9
issue proceeded to resolution.
10 I guess that's.something that we could look into 11 is going back and making a better definition of what the
$;%W* ^
12 particular issue is.
.re 13 DR. SHACK:
When I see'something like 14 risk-informed license renewal, it seems to be something that
' ('N
( )
15 bets for a little more explanation.
)
16 MR. GRIMES:
We discovered that as we were going i
17 through some of these issues.
A number of them are simply 18 comments that NEI gave us on the standard review plan and
.19 some of them are like credit for existing programs to i
20 illustrate the process, we spent almost six months just 21 trying to define what is the problem we're trying to 22 address, and credit for IWE/IWL, we spent several meetings 23
.and phone calls and exchanged correspondence just to get a 24 problem statement to work on.
25 So part of the review process, the first part of ANN RILEY & ASSOCIATES, LTD.
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the review process is to define a problem that's going to be
/D).
2-addressed and in relation to the risk-informed license 3
renewal, we're in the process now of getting assistance from 4'
the Idaho' National Environmental Engineering Lab to talk 5
about conceptually where could risk insights serve license 6
renewal, including the question ; hat Dr. Apostolakis raised
.7 about.how do you quantify renewal risk.
8 DR. BONACA:
I still have a -- I feel uneasy about 9
a strategy that you have to deal with these license renewal 10 isst 1 The reason that I feel uneasy is that I'm thinking 11 about a strategy that we, as the ACRS, will have to deal 12' with in looking at those.
13 What I mean by that is that a number of these 14 issues -- well, first of all, if I had to have a definition
)
15 of a license renewal issue, aren't they issues where the 16 staff disagrees with industry on what the -- how to deal 17 with them?
18 MR. GRIMES:
It's a potential disagreement.
In 19 many cases, we have found, for example, on the position on 20 fuses, we started off with a potential disagreement.
We i
21 eventually reached an agreement.
So these are areas where 1
22 there are questions for which either the industry wants.to j
l 23 know'more about what the NRC's view is or the NRC has put a 24 view out there and the industry is challenging it.
3 25 So we need to clarify, well, what is the nature of 1
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the cotential disagreement:and'then if we do disagree, what
()
2 are we going _to do'about it.
3 That's part of the process, is clarifying where we 4
misunderstand each other and distinguishing that from where 5
we_just fundamentally disagree.
6 For example, we put a position out on consumables 7
and NEI wrote a letter back and said that they understood 8
part of it, but disagreed with part it, and now we need to
~
9 confront that disagreement and decide what we're going to do 10 about it.
11 DR. BONACA:
But I'm saying that still I would 12 like to have a definition of what is a license renewal 13 issue.
Then it seems to me that those are issues that have 14 to do with disagreements between the industry and the staff
()
15 on how to deal with an issue or if the issue exists or 16 things of that nature.
17 Am I correct?
18 MR. HOFFMAN:
This is Steve Hoffman, License 19 Renewal Branch.
Some of these are just area where 20 additional guidance was recognized as being needed in either 21 the Reg Guide 9510 or the SRP.
The comment about the one in 22 there right now on risk, in 9510, there is a brief statement 23 about use of risk in developing your aging management 24 programs.
25 A comment came in on the 1996 draft reg guide that
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says can we get more guidance on how to apply that.
So some
()
2 of these are just -- they're actually items that need to be 3
addressed in the SRP, reg guide, or 9510.
Some are 4
disagreements, some are just development of additional 5
guidance.
6 MR. GRIMES:
I'd like to play off Steve's comment 7
and clarify that we view generic renewal issues as any area 8
where there is a question for which somebody deserves an 9
answe because our fundamental responsibility is to make 10 our expectations about the regulatory requirements very
'11 clear.
12 DR. BONACA:
Good.
So that's at least trying to l
13-understand exactly what's in this hopper here.
14 The second issue is it seems to me that many have
()
15 to do with the process and not only those which are called 16 administrative, but even others which are classified here as 17 highly technical. For example, I'm looking at 98-0033, 18 primary water SSC of high nickel alloy components, i
l 19 The industry here would like to do something and 20 the staff would like to do something else with the i
21 inspection.
At some point, there will be a resolution of 22 that and I expect'that the resolution will be in the SRP.
23 What I'm trying to understand, the question I had 24 originally was how do we get to the stability that you were 25 talking about before, where you do have still a hopper of i
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generic' issues, because in particular, in aging, things will lb-2 come up that we'd never seen before; therefore, you've got V
l 3
to have that hopper there.
It will be a limited one, 4
because most of the process issues would be dealt with, as a 5
minimum, there will be commitments.
6 That's really what I.would like to understand, 7
what is the strategy to get there, because by that point, I 8
would expect then you will have a much more stable license 9
renewal process.
10 MR. GRIMES:
And that was part of the strategy 11 behind the categorization, because by sorting these generic 12 renewal issues into the categories, Jake pointed out that 13 more than half cf them really get down to just clarifying 14 editorially what we were trying to communicate and then
()
15 there are'a smaller subset of those that have underlying 16 technical dialogue going on.
17 And the staff's expectations with respect to how 18 to deal with fatigue in the absence of a resolution of 19 GSI-190, for example, and even after GSI-190 is resolved, 20 whatever outgrowth there is in terms of the future
'21 activities to try and improve fatigue management techniques.
22 Reactor vessel internals is still an area that's 23 very unstable.
Technically speaking.
I mean, there's a lot 24' of development work that's going on.
There's a lot of 25' effort'that the industry is putting into improving the Os ANN RILEY & ASSOCIATES, LTD.
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inspection strategies for reactor vessel internals and i identifying areas where IASCC vulnerabilities need to be 3
concentrated in improved inspection techniques.
4 But what.we can do for license renewal is to carve 5
those out and focus those and where there is a particular 6
benchmark or reference, to highlight that in the review 7
guidance in order to make sure that everyone understands 8
there is an area where there is plant-specific or industry 9
work going on.
10 I think that's what the Commission envisioned when 11 they instructed the staff to concentrate on areas where
.12 programs may need to be augmented, because the stability is 13 going,.,to come from documenting the evaluation basis for how 14 environmental qualification is managed.
15 We had a long dialogue.on that on the first two 16 applicants and we learned that there are some basic precepts 17 of EQ that are common to all plants, that constitute an 18 agreeable expectation in terms of how the process works.
19 We need to collect the rest of that experience 20 from the first two applicants and also recognize the areas 21 where we had one applicant say that there is a big new 22 program to manage aging effects for buried piping and the 23 other applicant said that, no, that's just piping is piping, 24 one's in air, one's in water,.and one's in dirt, so what's 25
-the difference.
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'l-We need to reconcile some of the different L()
2 industry. views and say,:well,_ buried piping is going to be 3
dealt with uniquely perhaps.
But by cataloging what areas
~4 there was substantial agreement, where there wasn't a lot of 5
controversy, that in and of itself is going to achieve a lot 6
of stability and predictability and then it will boil down i
7 to some subset for which there will probably never be 8
complete agreement, but at least we and the industry will l
9 understand the' extent to which there might be plant-specific 10 approaches or there is a need for further work on a generic 11 basis beyond the process, outside this process.
12 That's why I mentioned the importance of 13 distinguishing between criteria that will be used for 14 decision-making from the constructive tension that exists 15 between the regulator and the industry in terms of area 16 where more research needs to be conducted to improve the 17 techniques.
18 MR. ZIMMERMAN:
In the area of ACRS involvement, 19 we plan to provide the ACRS with the new list of license 20 renewal issues based on the new categories.
Again, the I
21 letter that you have is NEI's first cut at that.
We're J
~
i l
22
' going to evaluate that list and we'll work out any of the 1
l 23 changes that we feel are necessary with NEI and once that 24 has happened, we will issue a final list with the new 25 categories and we will provide you with a copy of that.
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52
'l DR.' KRESS:
Does_this mean that those items that
'[]
2
'aren't on the list wouldn't get any attention until they
%/
3 make it to_the list?
1 41 MR. ZIMMERMAN:
No, sir.
What we plan to do is 5.
focus our attention and our resources primarily to those 6'
items on the. list.
I've proposed that as one is completed, 7-we add an additional item to the list.
j 8'
What we're trying to do here is focus our efforts.
9 and NEI's efforts on a set number of issues, develop a 10 detailed schedule, and work the issue till resolution and 11
' finally implementation, which would include possibly being l
12 incorporated into the SRP, the reg guide, the GALL, or
-13 NEI-9510.
14 There is staff review going on right now on other.
O g j 15 issues that are not on the top ten like list, but, again, we
~16 want to focus our efforts on that particular list and drive 17 them to completion.
18 DR. KRESS:
What are the criteria, again, for 19 making it on the list?
20 MR. ZIMMERMAN:
Well, the list originally just 21 included the priority one items and we've carried those 22 over.
We've added three additional items that NEI felt we 23 needed to devote some attention to that were high priority 24 items on their list that we had not previously characterized 25 as high priority.
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DR. KRESS:
So you will maintain some sort of
--Ij 2
prioritization within the categories.
3 MR. ZIMMERMAN:
Yes, so to speak.
4 MR. GRIMES:
But the prioritization is active or 5
not.
What it boils down to is, as Jake mentioned before, 6
the real criteria for getting on the list is basically what 7
do we and the industry both agree to are going to -- are 8
things that we're prepared to work on and we're prepared to 9
dedicate resources to, that we're prepared to commit 10 schedules, prepared to commit to schedules.
11 So it's a very simple criteria and it's one of 12 making a commitment to take an action.
We haver't made a 13 whole lot of progress up until this point, because almost 14 all of our resources have been fulfilling the commitments to (3,)
15 meet the milestones for the first two applicants.
And now
/
16 we've just revealed today that we're preparing to start 17 making a commitment to meet milestones and apply resources 18 towards a substantial generic activity to develop GALL, to 19 develop the standard review plan, and in order for those 20 things to be successful, it's also important that we make 21 progress on some of these generic renewal questions.
j i
22 To do that, we're going to need a commitment and l
23 an agreement from our stakeholders that they're prepared to l
24 support applying their time and energies first, but then i
l 25 beyond that, to follow a practice and a procedure that's i
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54 2.
d sagreemen 3
DR. BONACA:
I understand that'for the pilots, at 4
.least the one underway, there may be some supplemental SERs
-5
' coming.in the_near future.
s 6-How have they dealt with these open generic 7.
. issues? _They must have dealt in a way that you feel 8
satisfactory for closure?-
9 MR. GRIMES:
As a matter of fact, we're in the 10 process right nowzof_trying to come to closure on the open
-11 items for Calvert Cliffs'and Oconee_and in doing so,.the 12 generic renewal issues'are actually embedded in our safety 13 evaluation..So they're treating them on a plant-specific 14 basis.
15 DR. BONACA:
So essentially they're pointing out
}
l 16 to possible solutions of some of the issues.
17-MR. GRIMES:
Yes.
But we promised not to -- we've 18 promised the.first two renewal applicants that we weren't 19 going to abuse them by saying, well, you know, Oconee 20 promised to do this, so Calvert Cliffs ought to do that.
21' Similarly, we're not going to abuse the generic 22' resolution by saying, well, we managed to get the first two 23 applicants to cave in with this approach.
So we consciously 24 set out on a path that said, well, the first two renewal 25 applicants will do whatever they need to do in order for us j
i
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57 1
working on with BG&E to try to close out.
A i
2 The first one deals with stress corrosion cracking O
3 in the reactor coolant system and what the staff is trying 4
to work on with BG&E is discussing the possibility of this 5
and what aging management programs would be necessary if it 6
was found to be agreed upon to be plausible by both parties.
7
..DR.
SHACK:
Can you tell me how they treated this 8
differently than Oconee, so it's an open issue for them and l
9 a closed issue for Oconee?
10 MR. SOLORIO:
I would have to ask Joe to see if he 11 remembers how Oconee dealt with that, because I'm not 12 familiar with Oconee's particulars.
13 MR. SEBROSKY:
Recognize that I'm not the expert 14 on this, Dr. Shack, but I think the issue for stress
'O
(_,)
15 corrosion cracking in the RCS piping deals with CAST.
16 DR. LEE:
This is Sam Lee, from the License 17 Renewal and Standardization Branch, NRR.
The way Oconee --
18 the way they address it in the B&W owner's group topical 19 report and their SCC or the RCS piping is susceptible to 20 aging effects and they rely on Section 11 and such programs 21 for Oconee.
22 MR. GRIMES:
This is Chris Grimes.
For Calvert 23 Cliffs, they're treating it as an issue that they don't 24 consider a plausible aging.
25 DR. SHACK:
But they would have the same aging ANN RILEY & ASSOCIATES, LTD.
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management-program then that Oconee does.
They would have 2
Section 11.
3 MR. GRIMES: LIf they admitted that it was an aging 4
effects that needs to be managed.
5 MR. SOLORIO:
Just to clarify for you, Dr. Shack, l
6-we did, when we wrote the safety evaluation, we considered 7-that while there was a disagreement with BG&E on whether or 8
not the aging effect was plausible, we considered it if they 9
used -- if they committed to continue to perform the ASME 10 Section 11, their tech spec leakage requirement, and 11 programs based on Bulletin 82-02 and their primary water 12 stress corrosion programs, that we would find that an 13 acceptable way to manage the aging effect. 4 These were existing programs they already do, f3
(,/
15 because they don't agree that the aging effect is plausible, 16 they-weren't willing to commit to those programs for 17 managing that aging effect.
18 We're continuing to discuss it with them and we're 19 getting pretty close, actually, to closing this out.
20
.The next item that the staff is working with BG&E j
l 21 fto close out is on'small bore piping.
The staff believes L
22 the applicant should perform an augmented inspection of 23 small bore piping to determine if cracking is occurring on 24 the interior surface.
BG&E currently has a program that 25 looks en the exterior surface.
i I \\
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BG&E initially responded that inspections they i
[V')
2 intend to perform on their chemical and volume control 3
system as part of their age-related degradation inspections 4
would bound small bore piping on the RCS and the staff 5
initially had trouble accepting that response without 6
knowing about the similarities of the material, construction 7
of the piping and such.
8 So the staff is trying to get that information 9
from BG&E and to work towards closure on this, to see if, in 10 fact, they can bound it.
11 DR. SHACK:
That's another one where it seemed 12 like a sample inspection is not terribly useful, because 13 then that problem arises because of a very specific sort of 14 circumstance.
If your sample includes small bore piping C
5 15 with those conditions, then you may find it.
If it doesn't, 16 it doesn't, but that doesn't really give you any assurance 17 that it isn't a problem somewhere else.
18 It would seem to me that that somehow has to be a l
19 more specific review of the particular design and geometry 20 rather than an inspection program, a sample inspection 21 program.
I 22 I mean, the Oconee people look in particular 23 places because they had a history, they know sort of what 24 they're looking for.
25 MR. SOLORIO:
Right, correct.
You're probably I
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they're working on'it.
.[m) 2 DR. SHACK:
I guess my comment was that inspection
\\_/
3 didn't strike me as the way to really -- the best way to 4
resolve it, probably.
5 MR. HERMAN:
I don't think I'd argue with you.
6 MR..SOLORIO:
One of the next items we're working l
7 with BG&E to close out regards the reactor vessel flange 8
leak-off line.
The staff believes that because BG&E has 9
seen cracking in the line before that it's an aging effect 10 warranting an aging management program.
BG&E initially 11 responded that they rely on RCS leakage detection procedures 12 that are performed daily to let them know if they've got a 13-problem with that line.
14 The staff is working with BG&E to understand some
/~%
)
' (_)
15 additional details about how -- other ways they might detect 16 problems with that line, and that's kind of where that
-17 stands right now.
18 The next item involves cracking in the pressurizer 19 cladding.
Staff believes that industry experience --
i.e.,
20 Haddam Neck -- has shown that cladding in the crscking is a l
21 plausible ARDM and that in itself is not the worst concern.
22 The worst concern would be whether or not that would crack 23 or propagate into the base metal.
24 BG&E doesn't believe it's an aging-related
(
25-mechanism.
They believe it's related to some initial I
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fabrication or initial startup testing operations that would 2
have caused these problems at Haddam Neck.
3 DR UHRIG:
Is'Haddam Neck the only plant that had j
4 this?
l l
5 MR. SOLORIO:
That I'm aware of.
I don't know if l
6 there are others.
But BG&E -- nevertheless, BG&E agreed to 7
inspect.
What the staff is doing is now trying to discuss 8
with BG&E what'might be the most appropriate location to 9
look.
So that's kind of where that one stands.
1 The last open item that the staff and BG&E are 11 working on is the final safety analysis report supplement 12 that was submitted with the LRA.
There's kind of two parts 13 to this First was whether or not it needed to be updated 14 prior to issuing a license to reflect the staff's review and 15 the commitments made by BG&E as a result of the staff's 16 review, and, also, what level of staff information that was 17
-- what level of information the staff relied on in making 18-the safety evaluation conclusions needed to end up in FSAR.
19 We've had a couple public meetings with BG&E back 20 on 8/20 and 8/27 to talk about this.
BG&E, we provided BG&E 21 with some options on how to resolve this, so we could
.22 proceed towards closure.
They chose an option by which they 23 would take a cut at coming up with a list of information 24 they believed should be included in the -- ultimately the i
25 FSAR, once it's updated, because that's the whole intention l
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1 of submitting the FSAR supplement with the LRA, is to have a
[ \\
2' set of information that gets put in the FSAR that comes to d
3 the -- is the licensing basis from there forward.
4 Basically, the staff is working with BG&E to try 5
to reach closure.on this based on'their option.
I'm not 6
sure I explained the option correctly.
They provide the
]
7 list of what they believe and the staff will take a look at 8_
that and try to make sure that it's what we would think~was 9
necessary to gain the regulatory control we're looking for 10 by putting information in the UFSAR.
11 What I didn't put on this slide, there are two j
12 other confirmatory items the staff is working with BG&E to 1
13 close.
One of them involves cast, cast austinetic stainless 14 steel. ~BG&E has had and the staff has had a lot of
()
15 discussions on this.
r 16 MR BARTON:
What is the issue?
17 MR. SOLORIO:
It has to do with inspections of 18 cast austinetic stainless steel.
BG&E and the staff had 19 come together and talked about a criteria by which the 20 components that had a certain amount of cast or certain
- 21 '
amount'of ferrite were determined to be uubject to an i
22 inspection, and that's discussed in the safety evaluation 23 report.
24-DR. SHACK:
And you've agreed on that, the 25 screening criteria.-
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MR. SOLORIO:
We've agreed on that.
What the 2
staff needed to'go a little bit farther and talk-about what 3
do you do once you've come_up'with a sample and how do you 4
evaluate it by analysis, do you evaluate it by a certain
)
5 kind'of inspection, what do you do next.,
6' We're waiting for some additional information from 7
BG&E to help the staff disposition that issue.
8 And the last one is the control element assembly 9
' shroud = bolts.
This was initial'y a confirmatory item.
What 10 the' staff has done, based on BG&E's response, is tried to
.11 look at the potential failure mechanism of these bolts, 12 whether or not it would be a localized or a dispersed 13 failure mechanism and whether or not -- you know, what 14 appropriate steps might need to be taken if it was concluded 15 to be a localized potential failure mechanism.
16 We're still waiting for additional information 17 from BG&E.
I think they're working with CE to try to get l
18 that for us.
19 DR. SHACK:
Is this one of these arguments of how 20_
many bolts do you need to actually make the thing work?
21 MR. SOLORIO:
That is part of the --
22 DR. SHACK:
Discussion.
23, MR. SOLORIO:
-- discussion.
Before there is a 24 safety impact.
I mean, there can be a certain number of 25 failures that can occur.
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DR. SHACK:
And it's not a problem.
()
2 MR. SOLORIO:
And it's not a problem.
It's just 3.
whether or not you assume localized or dispersed random.
4 And that's all I have regarding the status of the Calvert 5
Cliffs LRA.
6 If there aren't any other questions, I'll turn it 7
over to Joe, 8
MR -SEBROSKY:
My name is Joe Sebrosky.
I'm the 9
project manager for Oconee license renewal.
.I'm going to 10 follow the same format that Dave did and just go over the 11 schedule adherence and open items of interest.
12 As far as the schedule adherence goes, all the 13 milestones have been met to date.
The next major milestones 14 that we're working towards is Duke is to respond to all the
()
15 SER open items.by October 15.
We're to issue our final SER 16 February 12 cnd the Commission is to reach its decision in 17 August of 2000.
18 The open items of interest are basically the list 19 is similar to the one that we presented to the full 20 committee on' September 1.
I deleted some things and made 21 some -- have some additional information for you.
22 Regarding the first issue, the scoping issue, that 23 was the subject of recommendation in the letter that the 24 full committee gave us on the 13th, as you are aware.
25.
Where that issue stands right now is the staff Os ANN RILEY & ASSOCIATES, LTD.
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.i Lvisited the site the week of August 116 through 18 to have a
/
(-
l 2
discussion with Duke.
As a result of that discussion,
(
3' things.were. clarified and discussed further in a management 4
meeting that we had with Duke in late August.
5 It was decided at that management meeting in late 6
August that the ball is in the staff's court.
We are to --
7-the action item that the staff currently has is to develop a 8
plan for the resolution of this issue and send it.to Duke.
9 We're currently working on a letter to transmit that plan to 10
-Duke.
We have not done that yet.
11 As far as -- so that's where the scoping issue 12 stands right now.
13 As far as the complex assemblies issue --
14-DR. BONACA:
Before you move out of that.
I read
()
15 this August 5' letter on license renewal issues, scoping 16 guidance, and in reading through, clearly there is a 17 discussion of the difference in the definition of what the 18 set of events is, but it's not clear what the staff proposes 19 to use as the set of events per -- for the license renewal 20 rule.
21 Is it the set of events which is used in the SRP?
22 MR. SEBROSKY:
I'll turn that over to Chris.
23 MR. GRIMES:
I'll respond to that.
We're going to 2'4 feed back the experience from the Oconee review into 25 improving that guidance on scoping.
It was our intent with l
(~}.
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concentrating on what are the underlying safety functions.
J
(
2 DR. BONACA:
Exactly.
(
3 MR. GRIMES:
That are relied upon in order to l
4 prevent and mitigate events.
And in some cases, what we 5
found when we were going through the Oconee scoping 6
evaluation is that they relied on some structures and i
7 components to perform functions that aren't analyzed events 8
in their licensing basis, but ended up being enhancements to 9
the plant over time as the licensing basis has been 10 maintained.
11 So that's why it's been somewhat difficult, 12 because we need to clarify that the interest that we have is 13 in the functions that the systems, structures and components 14 perform and not necessarily whether it's officially an
/~~
(,3/
15 analyzed event for the purpose of a design basis event in 16 the final safety analysis report.
17 It also gets us back to the problematic aspect of 18 the definition of what is a current licensing basis, which 19 is still somewhat controversial.
20 DR. BONACA:
But I think that the focus should be 21 function and the question I have is, is there any 22 consideration of looking at IPEs or to look at some of those 23 components which, in fact, are pointed to be important 24 functionally.
25
~MR. GRIMES:
In the review guidance and the
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~1:
inspection guidance, we look at the IPE in order to identify
~
those areas of particular concern and so we use that as a 2
l
.3-
. pointer to test the process.
4 And in developing or -- excuse me.
During'our 5
review of.the' scoping guidance, we went to the functions and 15 pursued the functions as a way of revealing this issue.
And 7
some of the functions are important.in the IPE and we 8
confirmed that those components are -- we hope to confirm 9
that all those components are within the scope of an aging 10 management review.
11 So that we use-the risk insights, but we expect 12 that in the future you will see, as. risk-informed 13 requirements mature, that we'll be able to do that in a more 14 methodical way.
Right now we'do-it based on engineering 115 judgment.
16 DR. BONACA:
I have just one more question that 17-comes regarding that.
In the scope issues, there are 18 proposals on.the table for risk information of Part 50 and 19 there is an option two that is being pursued, I think, 20 expeditiously, which has the potential for changing 21
.significantly the number. components that are under, for 22 example, a quality assurance program.
23 How would that' affect implementation of this rule?
24 LThat would be a major change or shift in it.
And I guess 25 the question I'm pursuing is really the use of risk ANN RILEY & ASSOCIATES, LTD.
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70 information is becoming part of supporting Part 50 and I
'(
2 don't'see as much~ movement in the direction in the-license 3
renewal area.
4 MR. GRIMES:
And the reason that you don't see 5
much in license renewal is because we are primarily 6'
approaching this from a deterministic perspective in terms 7
of what functions are relied upon in the licensing basis.
8 We expect that risk-informing Part 50 will change 9
.the licensing basis and then there would be a comporting 10 change in the scope for license renewal.
11 But we rely heavily on maintaining the current 12 licensing basis and extending it into the period of license 13 renewal and as we gain experience in how Part 50 can change, 14 we would expect that Part 54 -- let me say -- theoretically,
()
15 Part 54 can naturally evolve from that.
16 But as I stated at the Commission meeting on the 17 proposed changes to the maintenance rule, I would suspect
.18 that as the industry moves forward to risk-infonn the 19 licensing basis, it's' going to cause some confusion in
- 20 scoping for license renewal because we go to the traditional 21 Q list as a starting point.
We go to the licensing basis as 22 the starting point and say, well, what are the 23
. safety-related structures and components.
24 So when you start-changing the definition of 25 safety-related, when the definition is already as fuzzy as O
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72 1-haveLis complex assemblies.
For that issue, the staff does L
~
/~h L.Y 2
not agree with Duke that passive long-lived skid-mounted 1
'3 equipment'should:be excluded from an AMR.
This issue was 4
brought to the_ staff's attention during a review of the
'5' diesel generator, the suoporting equipment for the diesel 6
generator.
- 7 We have since -- since the September 1 meeting,
.8L we've since gotten an indication from Duke that they're 9.
rethinking their position on complex assemblies and they may 10 scope in additional portions ~of the skid-mounted equipment.
11 And Mr. Westman, during the break, reminded me 12 that this issue, along with some other things that we're 13 discussing with Duke, has the potential to add additional 14 workload to the staff that we had not necessarily budgeted.
()
15 Specifically, Duke has indicated, like I said, 16 verbally, that for the diesel generator, they may scope in 17.
additional portions..They have also indicated that the 18 chilled water system, we had an open item on the chilled 19_
water for the control. room, why was that not within scope, 20 and Duke has since told us that they have rethought their 21 position and now consider that to be within scope.
22-The problem with those two issues and then as part 23
'of their license renewal application update, they have 1
24-identified two changes that were made to -- at the~ site 1
25 after their' license renewal application was provided.
That
/~
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. was an emergency vacuum system was installed and they did an
()
2 updated Chapter 15 analysis on their steam generator tube 3
rupture.
)
4
.So the short story is they're going to be adding 5'
systems, structures and components, either because of 15' changes at'the-site or because they've rethought their 7
positions.
From a resource standpoint, we're going to have 8
to review, once you determine that that system is now within 9
scope, it doesn't end there.
You have to determine if the i
10 aging management review was done appropriately.
i 11 So the issue with complex assemblies, although we i
12 may reach agreement on that, the problem then becomes how
-13 are we going to review that in a sufficient amount of time 14 to make our next major milestone, which is February 12 to
()
15 issue the FSAR.
16 So that's a little more background on that issue.
17 Continuing on with the items of interest, again,
'18 the content of'the FSAR, there was mention of that in -- the 19 updating of the FSAR was mentioned in the ACRS letter.
Dave 20 also had this item noted.
21 Duke may be taking a different course than Calvert 22 in resolution of this.
They may provide us with an updated 23 FSAR.
That has not been-determined yet.
24 MR. GRIMES:
If I could clarify.
Duke has talked 25 about providing an updated supplement and just to make it
[~'
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74 1-clear that we're not trying to get the whole FSAR updated' (3
2 before a Commission decision, because that's a much larger 3 j 3
job.
4 But.we still have, in both cases, a question to f
5 resolve 1in terms of what's the appropriate level of detail 6
in the characterization of the commitments that have been 7
made.on managing aging that are appropriate for the FSAR.
%I So that's a common theme for both plants, although 9
Calvert is approaching it from a listing perspective and 10 Duke is approaching'it from the standpoint of revising the 11 supplement.
12 Both of them are going to have to deal with this 13 question about how the commitments are going to be treated 14 for the purpose of the license decision.
()
15 _.
Sorry, Joe.
16 MR. SOLORIO:
That's fine.
I appreciate the i
17
. clarification.
The next two items provide the basis that 18 void swelling is not an issue or provide an aging management 19 program and resolution of reactor vessel internals issues.
20-When_we presented that to the full committee, 21 those issues were lumped into a Section 3.4 of our SER open 22 items.
We have several open items in 3.4 that relate to 23 these issues.
24-As far as the status of these items go, we have a 25 meeting scheduled with Duke on the 29th of September to give ANN RILEY & ASSOCIATES, LTD.
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1 them feedback'on the responses that we've gotten from the l'
(
2 owner's group and the plant-specific responses that we've I
3:
gotten from Duke on if they hit the mark or not.
4 The reason that we need to do that,- we're doing 5
that in a meeting, is we'will not have the final safety 6-evaluation out for 2248 probably until the'end of October 7
and if you go back.to the milestones schedule, Duke has to 8c
'have all their responses in by October 15.
So we're giving JD:
'9 them verbal feedback in order for them to meet the schedule.
10
.The last' item that I have under open items of 11 interest are fatigue-related issues and the status of that 12 really hasn't changed since we briefed the full committee.
13-
'We had a meeting with Duke and we told them, we gave them 14 some feedback, which they said they would consider and give
()
d5 us'an updated response by October 15.
16 DR. KRESS:
Was there an open item on the need for 17 inspecting'the dam,_providing auxiliary power?
18 MR. SOLORIO:
There were some open items related 19 to Kiwi,_which is the hydroelectric station itself.
But as 20 far as the aging management program for the dam, Duke relies 21 on FERC criteria, the Federal -- I don't remember what FERC 22 stands for, but 23 MR. GRIMES:
Federal Energy Regulatory Commission.
24
'MR.
SOLORIO:
Yes.
They have an existing program ~
I L
25
,that'they're required to inspect those structures under FERC I
1 I
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1$ '
requirements and we found that acceptable in our SER.
We l
2' also have a -- there was a generic license renewal position 3
on that that-we issued.
Was that your question about the 4
' dam itself?
5-DR. KRESS:
yes.
I didn't realize you resolved 6
it.
7 DR. SHACK:
Just to get back to the
,8 fatigue-related issues, as I recall, the resolution of that 9
was not to resolve it now, but to wait, basically.
.10 MR. SOLORIO:
Yes.
What the -- if you go back to 1).;
t le meeting that we had' in August,, basically, the pitch that
~
12 the staff gave to Duke was we think that there is enough 13 information out there now that you can resolve this on a 14 plant-specific basis, and that's what Calvert did.
/
15 And otherwise, if you rely on a process that takes 16 into account all the research that is being done and, at a 1Y later date, will' implement that process that falls out of 18 the research that's going on, there's some regulatory 19 uncertainty associated with that.
j']Q,..
m t,
So-the feedback that the staff -- Duke's proposal 2i was' basically we're going to rely on a process and the 22' staff's feedback was that may be acceptable, but if you take 23 the plant-specific tack that Calvert did, we can write off 24 on that and we think that there is enough information out 25 there that you can do that.
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Duke told us in August that they suld consider 2
that and let us know by October 15 which tact they would 3
take.
4 The next item was not discussed with the full j
5
' committee, and that's the inspection report item.
The 6
section -- the second inspection report for oconee was just 7
issued.
It was issued on September 21.
One of the findings 8
in that inspection report, it states that the NRC does not 9
agree that no aging management programs are warranted for 10 electrical cables and connectors.
11 We have -- if you go to our SER, our SER found the 12 scoping and what Duke did for an aging management review for 13 the cables acceptable.
So there was no open item.
But the j
14 reviewer that was involved with that said I'm concerned
- about aging effects and I unde $ stand from the application 16, -
that Duke determined that there were no aging effects, but 17 I'd like to be part of the inspection team that goes down
-18 and reviews the site documentation.
i s
iesult-of that, they determined that there are some 20 moisture radiation and heat aging effects that are going on I
21 at the site that were revealed to them during walk-downs and 22 also through a look at Duke's problem investigation process.
23 The reason that I put that as a separate item, 24-again, we do not have an open item for the electrical 25 cables,'but'we are going to, based on the results of that
)
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inspection report, we're probably going to have to take a
()
2 look at the aging. management review again for the' cables.
3 It becomes a scheduler issue.
That's all the 4
items I have-for Oconee.
5 MR. MATTHEWS:
I'd like to make an additional 6
comment.for the members' benefit, given that this is a 7
discussion of generic activities-affecting license renewal.
8 The_other half of my organization would feel 9
slighted if I didn't discuss where we are with regard to the
- 00 environmental review and the fact that we had a critical 11 path item that the members may recall relative to Part 51 12 and its treatment of environmental impacts of transportation 13 of spent fuel to and from an ultimate repository; in this 14 case,_ Yucca Mountain.
()
15 We did publish in the Federal Register a final 16 rule approved by the Commission indicating that those 17 transportation impacts would indeed be treated on a generic 18 basis and it provided that generic basis, supported by an 19 addendum to the generic environmental impact statement for
- 20 license renewal.
21 However, we do have some tight schedules yet to 2 2.,.',mee,t in this regard, given that the addendum to the generic
.h '
2$,
environmental" impact statement has to be submitted to EPA j
24 and subjected to interagency and potentially CEQ review 25 before it'can be viewed as being effective.
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79
- 1 That comment period will be over on the 4th-of 2
' October, at which point the two subsequent supplemental
~. 3 EIS's for Calvert Cliffs and forLOconee will then themselves 4-be subjected to an interagency review, since-they rely on 5-that addendum to the GEIS, and those time periods. toll 30 6'
days after they're submitted to EPA.
fY In terms of timing, this works out such that we
-8; expect to' issue the Calvert Cliffs supplemental impact 9
~ statement in support of license renewal on November 16, 10 That's dependent'upon this EPA review being completed by 11 November 15.
-12 In a similar way, we expect the Oconee 13' supplemental environmental impact statement to be subjected 14
.to EPA review and interagency examination and if all goes 15 according to schedule, we will be issuing it on schedule on 4..,
]p ~.
- 16
'. February 12, along with the SER.
17 So there's still some critical dates that need to 18:
be met for this all to fall into place.
As you can tell,
.19:
the staff has been managing these milestones down to almost 20 the. hourly basis..But I wanted to indicate to you that we 21 are on a path to success'here.
The Commission did approve 22-the rule and did approve the supplemental environmental 23
' impact. statement.
24 So that major hurdle.I think is, for the most 25 part, past.
By'the way, this is David Matthews.
I'm the ANN RILEY & ASSOCIATES, LTD.
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3.
MR. GRIMES:
And I will add to Mr. Matthews' 4
explanation.
We're now looking at all the milestones l
5 leading-to a Commission decision for Calvert Cliffs in order 6
to determine exactly how much more time is needed in order 7
'to complete the license renewal review.
We're going to be 8
working with the committee to develop a schedule to get the 9
earliest possible ACRS conclusion.
10 The regional activities are going to be concluded 11 with a one week inspection in December that's going to look
'12 into open items and whatever other aspects of the renewal 13 evaluation Hub Miller wants to have explored in order to 14 make his recommendation to the Commission.
()
15' So we'll be setting up detailed schedules in terms 16 of the milestones to closure that we'll be sharing with 17 Baltimore Gas & Electric at the management meeting on the 18 29th of September, and we're going to identify all of those 19 -
actions that need to be taken in order to get to a 20 Commission decision and then determine whether or not we can 21-improve on the May 2000 completion schedule that we're 22 continuing to work towards.
23.
' s /-
I will say that I don't see any way that we can
.,Q'
' ).,, '
improve 'n the N.ovember 16 date to complete the safety 24 o
25 evaluation.
We've basically used the time that's necessary
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j 81 1
to develop final safety evaluation. inputs with ongoing h
2
. dialogue on-some of these controversial topics.
V l
3 I think the status for both.Calvert Cliffs and i
4 Oconee that Mr. Solorio'and Mr. Sebrosky just described
-5 illustrates to you the kinds of controversies and questions 6
that are coming up as we try and finalize the safety 7
evaluation, and'thby are in areas where the technology is 8
evolving pretty fast.
9 So it will give you some idea about, from a 10 process perspective, the kinds of things that you're going 11 to be faced with, that we are faced with, and you'll get to 12 share with us.
13 DR. BONACA:
Again, we're trying to support your 14 schedule.
On the other hand, one strategy -- we're (7
t
.V
_ 46^ -
developing a strategy right now for our review of the 16 process and the applications and one of the recommendations 17 that we're going to make most likely is that we will have a 18.
subcommittee meeting before to review the supplemental SER.
19 Probably that's one of the important points for us 20 to give some perspectives.and to support a December letter, 24 we'will need to have material in hand sometime in October 2Y
'for us to be able to then support that kind of ACRS report.
23
'MR. GRIMES:
In order to be able to work the 24 milest'ones, and I would propose that we would bring to the
_25
-- we would work with the committee to der ribe the
(
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resolution of the open items in parallel with developing the
,n
(
)
2 final safety evaluation by November 16, and then however 3
many ever meetings it takes or whatever ends up being the 4
most efficient way for us to communicate with you, but we'll 5
continue to work with you towards trying to support some 6
activity in October and then the earliest possible final 7
safety evaluation that we can share with the committee, the 8
subcommittee.
9 DR. BONACA:
One thing the subcommittee will be 10 interested in seeing, at least I will be interested in 11 seeing is not only the specific closures that you have on 12 open issues right now, but at some point, to understand how 13 the specific applications dealt with all the license renewal 14 issues.
(
15 That may not be -- I don't want you to go to a new 16 project now or having to pull out the information and do 17 that, but certainly, for some of the issues, I remember, 18 there's some, and I think it would be worthwhile for us to 19 understand what kind of modalities were presented and that 20 were acceptable to the staff.
21 MR. GRIMES:
We did explain the relevance of 22 generic renewal issues when we presented the original safety 23 evaluation conclusions to the subcommittee.
So the material 24 exists and it can be updated for that purpose.
25 DR. BONACA:
Right.
In looking at the longer
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schedule here, I'm looking at the overhead number six that
()
2 you presented at the b'eginning.
In that schedule, you have 3
identified an ACRS' meeting on GALL, SRP and reg guide based 4
.on NEI 95-10, that is supposed to be in February 2001, and 5
we certainly would support that.
But I would expect we 6
would~have to have at least one more meeting, if not 7
MR. GRIMES:
That was in order to make sure that 8
there was a stake put in the. ground for you, in terms of 9
where we felt we'd need some ACRS action, but that didn't 10 mean that we'wouldn't expect to have ongoing contact with 11-you up until that point.
We would expect to keep the
~
12 subcommittee informed as we progress along this schedule.
13 But we did want to let you know where we felt it 14 would be important to have an ACRS decision point.
O( j 15 DR. BONACA:
Sure, and we will support that.
But 16 certainly in the next year, I think it would be important to 15 have at least one meeting where we would like to see some 18 progress, what kind of progress is.being made on the license 19 renewal issues and how they're coming together.
Again, the 20 objective would be to understand how we get to the stability 21 we were discussing before and what issues are really the 22 hard spot after we go.through the license renewal of the 23 first two applicants.
24-MR. GRIMES:
We'll do that.
We'll continue to 25 work with the subcommittee on scheduling periodic meetings
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84 1-like.this to discuss the status of generic renewal
'2 activities.
l 3
DR. BONACA:
We also need to have from you l
4-information whenever-some issues appear, like the credit for 5
existing programs, that-you may require from us a review and 6
we will attempt to support that.
7 MR. GRIMES:
As we mentioned before, at this 8
point, we' haven't identified any other policy issues.
As 9
soon as we identify a policy issue, we'll let you know.
In 11 0 the meantime, we'll leave it to the subcommittee to choose a
11 amongst the proposed resolutions of generic renewal issues, j
l 12 those which you'd like to be briefed on.
Otherwise, we'll i
13 just plan on some periodic meetings with the subcommittee to 14 discuss the overall activities.
15 DR. BONACA:
Any other questions from members?
16 MR. SOLORIO:
We have the last two slides to 17 present.
18 DR. BONACA:
Sure.
Okay.
19 MR. ANAND:
Good morning.
My name is Raj Anand.
20 I'm the project manager in the License Renewal and 21
'S"tandardization Branch.
The industry's last approach to 22' license renewal was to submit plant-specific and owner's 23
. group technical reporte on particular topics for staff 24 review, instead of submitting a complete license renewal 25 application.
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85
- 1 Let me briefly present to you the status of review
]f 2
of the owner's group generic technical reports, the Babcock 3
and Wilcox owner's group, representing five B&W units, have
,0 formulated a generic license renewal program.
The B&W 5
owner's group submitted generic license renewal reports on 6
the reactor coolant system piping, the pressurizer, the 7
reactor vessel and the reactor vessel internals.
8 The staff has issued the final safety evaluation 9
report on all the B&W owner's group report except one, which 10 we intend to issue sometime the end of next month.
11 The Duke Power Oconee has used thebe license 12 renewal reports by reference in their license renewal l
13 application.
The Westinghouse owner's group also has a 14 program for license renewal and has submitted technical O(,,/
15.)
reports on the aging management activities on the reactor 16-
'ccciant system supports, the pressurizer, the Class I I
17 piping, the containment structure, and the reactor vessel 18 internals, i
19 The first Westinghouse plant license renewal 20 application is for Turkey Point, which is not scheduled to
~
21
- NRC sometime till December 2000, 22 The boiling water reactor owner's group is 23 currently concentrating their efforts on reports related to 24 vessel internal programs for license renewal.
So far, BWR 25 VIP group has submitted 11 license renewal appendices and e
O\\
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the staff has issued a finsi safety evaluation report on BWR
_2 VIP-49,'the instrument penetration.
The staff plans to 3
issue the' final safety. evaluation report on BWR VIP-27,
'4-which is the liquid standby control system, sometime next 5
month.
6-The first BWR plant license renewal application is 7
for Hatch, which is due in March 2000.
8 DR. UHRIG:
Is there-one for the CE owner's group?
9-MR. ANAND:
No.
CE has not announced any kind of 10 involvement.
11 MR.. GRIMES:
Let me comment, though.
I understand 12 that an outgrowth of the Calvert Cliffs application, that 13 the CE owner's group is now going to pursue some of the ip',
experience that Calvert Cliffs had and that the new company
$ N,,, :that evolved from the Calvert Clif fs ef forts, the 6
Constellation Energy Services is going to be working witn 17-the CE owner's group and they may be developing some topical 18 reports that will at least be developing some shared 19
' experience that the CE plants will draw on.
But they still have not specifically identified 2,,0 e
Il any schedules for submitting topical reports.
22,
, 'i MR. ANAND:
The second slide is the announced a.
23 future renewal application.
In the opening remarks by Mr.
, Chris Grimes, he hc.a briefly stated the future announced 24
.a 2F,
,slicehse renewal applications.
For the budget purposes, we Q
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will'have two applications in FY-2000, which is Arkansas g ()
2 Unit 1-and Hatch Unit 1 and 2, and we might have four
- 3 applications in FY-2001 from Turkey Point Unit 3 and 4, 4
Catawba Unit 1 and 2, and McGuire Unit 1 and 2.
5 DR. UHRIG:.What do you mean if the exemption 6
request is approved?
7 MR. BARTON:
They're not 20-year-old plants yet.
8 MR. ANAND:
The Duke Power's McGuire has submitted 9
a request for exemption.
The rule requires that the utility 10
-or the plant will not submit an application until it has 11 experience of 20 years.
McGuire unit will be a -- Unit 1
.12 will be the earliest. plant which will be completed, it's 20
'13
' years in June-2001, which will be followed by Catawba, which 14 will be followed by McGuire Unit 2, which is 18 years old,
()
15 and will be followed by Catawba Unit 1, which will be 16 and 16 a half years, and Unit 2, 15 years.
17 Our' evaluation of this exemption request is in process and 18 will be issued pretty soon.
19' DR. UHRIG:
Is the. purpose simply to keep the team 20 in place from -- that's been working on the Oconee?
21 MR. HOFFMAN:
This Duke -- that is one of the 22 primary purposes.
When they had the team together to 23 experience,,they're going to shift it over to the 24 McGuire/ Catawba,.but they're also looking for efficiencies, 25
'they believe, on their side, as well as the staff's review, O
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.because of.the similarity between the design, maintenance O.
- 2
-operation, the common programs between the two sites.
V 3-Once we-kind of get through Oconee, they're going 4
to start focusing, we're going to start a dialogue on where 5-
-- how actually to package that application and to see where
'6 efficiencies might be achieved and it's actually going to 7-tie in'with -- Virginia Power has fajicated they want to 8
send in their North Anna and Surry applications at the same 9
time and look at -- because they've got some common aging 10 management programs and such.
11 So that's an effort that we're going to be taking 12 up in the near future,.is looking at those combined -- I 13 won't say combined applications, but the applications coming 14 in concurrently.
j
()
15 MR. GRIMES:
That completes the staff's 16 presantations and we're prepared to respond to any other 17 questions you might have.
18 DR. BONACA:
Any other questions from members of 19-the subcommittee?
If not, then we want to thank you for a 20
.real informative presentation.
We need to, again, as we've 21 stated before, to be staying in touch as we develop our own 22 strategy to review and support your process.
23 MR. MATTHEWS:
We would like to thank the 24 subcommittee and the full committee members, of course, for 25 your continued support in this process.
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89 1:
I wanted to state that from the NRR's management
()
2 perspective, with regard to the timeliness and resources to 3
be dedicated to license' renewal reviews, that we intend to l
4 hold to the schedule template that we had established at the 5
beginning of this effort relative to the 24 to 30 month 6
schedule associated with site-specific individual 7-applications.
8 We intend to utilize our planning, budgeting and 9
performance management process to adjust internal assignment 10 of resources to sustain those schedules and so, therefore, 11 the limitations on any future improvements of those 12 schedules will not be as a result of any absence or lack of 13 NRC resources to be applied to them.
14 The limitations exist primarily as a result of (O
,/
15 limitations of what I would call process driven.
As you 16 know, there are established schedules for public comment on 17 environmental impact statements and for their noticing.
We
]
18 have limitations on our stakeholders, of course, the 19 applications themselves have their own constraints 20
-associated with timeframes for response.
NEI has its 317 limitations in terms of its ability to respond on generic 22' issues.
23 So we recognize there are some. constraints on 24 further improvements in those schedules from the process 25 standpoint, but NRR's management is committed to the
{'
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principal that for the foreseeable future, we're going to
{f 2
-adjust and apply resources as necessary to maintain the 3
schedules that we've advertised.
4 We appreciate that the ACRS has appreciated the 5
sensitivity we have to these milestone schedules and are 6.
doing everything they can to facilitate it, and we will 7
continue to apply the resources necessary to ensure you have 6
the information and support that you need from the staff in 9
order to do that.
10 So with that, the staff's presentation is 11.
concluded.
Thank you.
12 DR. BONACA:
Do we have any other presentations 13 before?- With that, thank you, again, and we're going to 14 move into the last item on the agenda, which is a discussion
()
15 of the ACRS review strategy.
And this is going to be on the 16 record, right?
17 Here I would like to say that we are scheduled 18 next week to talk about strategy, the ACRS.
So in order to 19 support that process, we put together a first draft of a 20 five-page -- what I'm referring to is the document chat says 2 1,.
. revision,one, Rev.
1.
Rev. 1 really is equal to the first 22 document we had before, plus those additions which we have 23 marked on the side to give a little support to logic that 24 I'm presenting here for the number of review meetings we 2 q,.
,should have in supp0rt of every application.
1 O
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This document will require additions, for example, 2
on the1second'page, under evaluation of effectiveness of 3'
license' renewal' process, we'have to identify possible
'4 additional' meetings that we need with the staff, as we had 5
today, and they're not identified here.
6 But what I would like to do is simply walk through 7
it very briefly and get your feelings about the proposed 8
approach, as well as modifications of these documents we 9
need to make_for us to have a document next week.
10 This five-page document _ essentially goes, the 11 first page, where we've just stated that the ACRS should 12 review a report on each license renewal application.
That 13 was an issue that we discussed at the'ACRS.
Some people
-14 felt-that maybe we had to continue our involvement through 15' the establishment of the process, but we feel'that because 16 of a number of reasons which are presented here, we should
- 17 be involved in review of each license renewal application, if
'sven after the process is established.
19 On the second page --
20 MR. BARTON:
Mario, on the first page, the only 21' comment I got is item three,. evaluation of policy issues in 22'
~1igh't'of.the recent SRM.
IP this still something we ought 23' to be involved in?
24 DR. BONACA:
I'm sorry?
'25 MR. BARTON:
Evaluation of policy issues, item O
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1 three.
2 DR. BONACA:
That's --
3 MR. BARTON:
Is this something we still are l
4 chartered to or want to be involved in based on the recent 5
SRM that said the ACRS should not be delving in policy 6
issues?
7 DR. BONACA:
Yes.
l 8
DR. KRESS:
If they involve safety matters, we 9.
still can. Clearly, we would limit it to that.
10 DR, BONACA:
See, if you look there, John, on page 11 two, at the end of those four bullets, I put a statement 12 that says-discussion of evaluation of policy issues by the 13 full committee.
I feel that everybody should be involved 14 and I think that next week, when we meet to discuss, we can 15 touch on those.
16,
DR. KRESS:
We can probably do that as we go along e:
y 17 and it won't take extra meetings.
18 DR. BONACA:
I agree with that.
One could even 19 propose that we leave them open and we learn from the 20 experience in the application and see where they go.
21 For example, the issue of grandfathered plants I 22 think is falling off as we address the functionality of l
23 components that should be included in the rule and we're 24 looking at scope.
25 DR. KRESS:
I have more concern about the t '
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evaluation and the effectiveness, why actually are we doing
()
2 that.
3 DR. BONACA:
The effectiveness?
4 MR. BARTON:
How are we going to measure that?
5 DR. KRESS:
Yes, how we're going to measure that, 6
that's the problem I have with it, j
1 7
DR. UHRIG:
Is that also outside the domain of --
8 DR. KRESS:
And is it in our domain.
Those are 9
the two questions I have, f
10 DR. UHRIG:
It's not safety, per se.
11 DR. KRESS:
So I had more issue with that one.
i 12 DR. BONACA:
That's a good point.
If you remember 13 the presentation we ad, that's a good point you're making 14 here.
Here, more the evaluation of the effectiveness really O'(,j 15 is contribution to the process.
16 MR. GRIMES:
This is Chris Grimes.
Just as a 17 point of -- maybe this is a linguistic detail that you're 18 not concerned about, but I would point out that the criteria 19 that the staff is trying to achieve is the phrase in Part 20 54.421 on aging management programs, says that the staff is 21 supposed to find whether there is demonstrably effective 22 programs.
L 23 So from that standpoint, our focus is on the i
24 effectiveness of the programs and we would be seeking ACRS i
25-endorsement of our finding.
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94 1
DR. KRESS:
Clearly, that's a safety issue and we I
\\
2 didn't talk about that one.
L) 3 MR. BARTON:
As opposed to the effectiveness of 4
the whole process.
i 5
DR. KRESS:
Of the process.
6 DR. BONACA:
So here we're talking about 4
7 evaluation of the effectiveness.
8 MR. BARTON:
We probably want to narrow it to what 9
Chris has described.
10 DR. KRESS:
That would be part of our review of 11 the SER and the application.
12 DR. BONACA:
That's right.
So the effectiveness 13 demonstration.
Again, under item two, we expand it to 14 recognize that we will have meetings to deal with those, j
/~N
(,)
15 And the focus of the ACRS reviews, here is a tentative list 16 of items that I felt some of the members should focus some 17 attention on and this is open to be expanded.
18 MR. BARTON:
I didn't have any problem with the 19 list as it currently stands.
I don't think there is 20 anything on there that would take --
21 DR. UHRIG:
Just a question.
Are you going to 22 assign teams to different plants?
Are you going to assign a 23 particular area to individuals for the review for all plants 24 or how do you --
25 DR. BONACA:
The last section, subcommittee review f)
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95
'l process, one recommendation there was that we would keep an
~'\\
2 individual looking at certain portions, because he's
[J 3
becoming an expert in those,'most of all by comparing how l
4 different applicants are doing the same thing.
5 You really become much more capable of repeating.
l 6
So the thought was -- and, also, it would facilitate, I 7
think'it would facilitate the review process for us.
So we 8
.might want, at:some point, to change that, but my 9
' recommendation would be that individual assigned for i
10 specific topic already on the plant or issue, they could 11 review'the same topics or issues.
i i
.12 DR. KRESS:
I didn't notice in here' factored in 13 the need to review any technical. reports.
Are we through 14 with those?
I 15 DR. BONACA:
No.
You mean like --
16 DR. KRESS:
Would they show up in here as -- where 1
17 would I find those?
18 MR. BARTON:
The topics, you're talking about?
19 DR. KRESS:
This list we were just given that 20' MR BARTON:
The list of topicals.
I 21 DR. KRESS:
The topical reports that are 22 referenced, those things.
So are we going to review all 23 those?
24 DR. BONACA:
Yes, but typically we review those as 25 part of the. applications.
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(.
1 DR. KRESS:
As they're referenced in an j
2 application, we would try to review them.
3 DR. BONACA:
That's right.
The way we did it for l
4-Oconee, for. example.
5 DR. DUDLEY:
The problem with reviewing them at 6
the' time that-they appear in the application is that they 7
are al' ready final.
.If the committee wants to review the 8
contents and have comments and recommendations on the 9
contents of the topical reports, it really needs to review 10 those topical reports in a draft stage.
11 DR. BONACA:
But that would be almost 12 participating in the process, in the review process of the 13 applicants or actually the owners' groups, and I don't think 14
. we want to be involved in that.
)
15 My feeling is that we should be looking at what 16 the staff has concluded with respect to what they are 17 proposing.
18.'
MR. DUDLEY:
Then the appropriate time would be 19
.when the staff's safety evaluation report on a topical 20 report is in a draft stage.
That would be the appropriate 21 time for the ACRS then to review the topical report, which, 22 in some cases, will be before there is even an application 23 for that vendor type plant.
1 24 DR. BONACA:
But it seems to me that if you l
25 disconnect that topical report from a specific application, l O ANN RILEY & ASSOCIATES, LTD.
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97 1-you are missing some elements.
I guess we could do it, but I
()
2 3
DR. SHACK:
Clearly, we can't review all of those 4
reports.
That has to be on a selective kind of basis.
I'm 5
kind of inclined to agree that we probably -- you'know, what 6
Noel says is desirable, in general, but as a practical 7
matter, I really think it's going to have to come as they 8
are referenced and you sort of have to take into account 9
their importance to the process.
10 DR. KRESS:
I think maybe we -- my thought was we 11 might want to look at them and prioritize ttem and select a
)
12 few of them to look at.
That's what'I thought.
13 DR. SHACK:
I mean, even for Oconee, we didn't 14 review them all.
(
15-DR. BONACA:
That's right.
But, again, it seems 16 to me that it would be more appropriate to make the 17 selection in the context of applications.
For example, i
18 because, you know, hypothetically, somebody could submit all 19 these topicals and nobody uses them for license re.ewal, so 20 they are sitting there --
21 DR. KRESS:
They waste their time.
22 DR. SHACK:
I wouldn't lose too much sleep over 23 that one.
24 DR. BONACA:
That's right.
But then I think it 25 would be good to verbalize this in the strategy.
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L 1
DR. KRESS:
Yes, that's what: I thought.
Some
/~
l 2
mention of it somewhere.
3 DR. SRACK:
This:is actually the first time I've 4'
- seen this list.
5 DR. BONACA:
Right.
6 DR. KRESS:
That's a good question.
Is this a 7
complete list or are there others that haven't showed up 8
yet?
I presume this is a complete list.
9 DR. SHACK:
I know this isn't a complete list of 10 the VIP projects.
11 MR. GRIMES:
This is a' complete list of the j
12 topical reports that.will be relied upon for aging 13 management'for license renewal.
This is all that -- let me I
i 14-put'it in a more pragmatic way.
This is all I'm prepared to
()
15 commit resources to.
16 DR. SHACK:
But 14 in VIP-59, you don't think 17 they'd be referring to those for their aging management for 18 various --
19 MR. GRIMES:
They're captured in other VIPS that the BWR vessels internals program is a huge, complex J
20 21 matrix of interrelated work.
That's the most polite way I 22 can put it.
23 We went through, with the assistance of the BWR 24-
' VIP folks, and they're pointing at specific things that they 25 want to rely on for license renewal.
i
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So with the assistance of Mr. Strosnider and his 2
staff, we're looking to these things as the ones that we 3
need to track.
'4 DR. SHACK:
I see.
So they-pulled this 38 for the 5
shroud support out even though the relevant technical 6
information is in 59, for example.
7.
DR. KRESS:
I guess it would be helpful if, when 8
the staff reviews these and they come up with some issue 9
'that.they disagree with, look at specific issues, that would 10 be nice.
That would help give our opinion on how to resolve 11 it.
12 MR. GRIMES:
But as Dr. Bonaca mentioned before, 13 they're revealed during the course of the staff's -- in the 1
14 referencing of the reports, in B&W's case, but like generic
/
( )
15 renewal issues, as we stumble across any controversies in 16-the topical reports, we notify the subcommittee.
17 DR. KRESS:
That, I think, would be particularly
'18 interesting.
Kind of like your four-step and two-step 19 process, that's practically about the best way to do it.
20 DR. BONACA:
That's why I was concerned about the 21 issue of the issue list, where there are those.
My feeling 22 is still once we have an SRP, that it captures most of the 23 process, we should not have a lot of objections to the SER, 24 that we.should generate an interim letter.
We could wait l
25 for a supplemental SER for us to have an ACRS meeting and
[
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then a letter.
(
2 DR. KRESS:
I think that SRP is going to have a l
3 lot of that.
That's fine.
~
1 4
DR. BONACA:
Because many of the issues I see i
l 5
right now, the license renewal issues, really have to do f
i 6
with decisions on what's an acceptable process.
I would 7
expect the majority of the list to be closed.
I mean, there 8
will always be a list.
9 DR. SHACK:
Okay.
So we don't need interim 10
. letters in all circumstances.
11 DR. BONACA:
That's right.
There is a provision 12 here, I think, on page four.
13 MR. BARTON:
The top of page four.
14 DR. BONACA:
Third paragraph, there may be some g,)
.15 instance where the SER has significant comments on the SER 16 that may effect the SER and the resolution of open items, 17 and then in that case, we would schedule an interim full 18-committee meeting to review the SER and to write an interim 19 report.
20 DR. KRESS:
Do we have enough time associated with 21 full ACRS meetings to review an SER?
We generally --
'22 maximum is generally a couple hours.
Sometimas we squeeze 23.
it in in two and a half hours.
Is that enough?
24 DR. BONACA:
To look at the closure, you mean?
25 DR. KRESS:
To look at an SER.
./
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101 1-DR. BONACA:
You mean to the supplemental SER.
()
2 DR. KRESS:
Yes.
3 DR. BONACA:
Well', I wantedLto add some words here 4
that the burden will fall on the Chairman to communicate.
5-So there.will-be maybe some interim meeting.
I don't think 6
that we should -
unless there is a need, I don't think we-7 should cycle the whole committee, but bringing closure and 8
.then the Chairman could summarize for the full committee 9.
some information before the full committee meeting takes 10.
place.
11 DR. KRESS:
How many members do we have, 12
-subcommittee?
13 DR. BONACA:
That's the whole thing.
It's the 14 majority of the committee.
15 MR. BARTON:
Dana is missing.
16 MR. DUDLEY:
It's seven members.
17 DR. BONACA:
Seven meabers.
18' DR. KRESS:
We prolun.y ought to expand that to i
19 the full committee.
20 MR. BARTON:
Just like we do with the new reactor 21 designs.
Put it out and every member of the committee gets 22 a piece.
23 DR. BONACA:
I thought about it, too, because for 24 the license.of new plants, I believe that that's a way to 25 operate it, isn't it?
?
- ~
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102 t 1' DR. KRESS:
A subcommittee of the whole or 2
.something.
3.
DR.HBONACA:
I_didn't have a proposal either, so I 4
thought I would just float it there.
5
-DR. KRESS:
I think that's something we can 6
discuss.
7 DR. BONACA:
I believe that particular -- I mean, 8
'we have to find a way to-be efficient enough in that process 9
that we can do it.with two meetings.
10 DR. KRESS:
On these-focus items.
11 DR. BONACA:
Yes.
12 IMt. KRESS:
Which is a good idea.
Do you have in 13 mind taking specific members and say this is yours and from 14 now on, on every issue, so that they get more --
()
15 DR. BONACA:
That's right.
Yes.
My sense is that 16 that would be the right way to do it.
I realized after we i
17 wrote this that we really had an issue list here, but we 18 didn't have any owners.
So I think that we should assign 19 some owners so that the issues don't get dropped.
20 Now, it may result from application that you
.21 always end up with the same issue anyway.
For example, the 22 guy who reviews scoping issues is going to and up with the 23-scoping issues.
24 DR. KRESS:
Right.
' 2 5.
'DR. BONACA:
But there are others that may -- you O
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know, you'still want to have.some people that are owning the 0
.2 issue.
1Ql
'3 DR. KRESS:
Yes.
I think that's an efficient way 4'
to do it.
'5 DR. BONACA:
Okay.
I'll put some words in the 6
back and we will develop a process for that.
At-some point, 7
I want to go back to page two and item two.
I agree, 8
evaluation of the effectiveness of license renewal process 9
is not the right characterization, but I would like to agree 10 on the words here.
11 We'ra talking about the effectiveness of the 12 demonstration.
13 DR. SHACK:
Well, no, I really thought you were 14-talking about the effectiveness of the process here.
I
(,g) 15 mean, the effectiveness of the demonstration I thought was 16 really an item one' issue.
17 DR. BONACA:
Evaluation of the -- you're right.
18 DR. SHACK:
There is a question of whether that is 19 in.our purview or not.
20 DR. KRESS:
If we were looking to cut down on what 21 we have to do, that looks like an area that would be --
)
22 DR. SHACK:
But it seems to me that the Commission 23 seems to ask us about that' question.
24 DR. KRESS:
I think that's something that the
- 25 -
staff will definitely have on their agenda.
I don't know i
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why -- I. don't know if they're much more efficient and
()
2 effective in evaluating that sort of thing than we are.
3 DR. SHACK:
I really thought this was almost a 4
somewhat larger scope issue, for example, what risk 5
information would do to the whole process.
6 DR. KRESS:
That may be a different subject.
7 EDR. SHACK:
It's effectiveness in kind of an upper 8
case.
9 DR. KRESS:
That one may be a better one to add 10 in.
My own feeling is that's trying to close the barn door.
11 DR. SHACK:
Yes.
That's a --
12 DR. BONACA:
When we wrote this, I had in mind, 13 for example, the scoping issue.
The scoping issue could be 14 the' debate of what's the licensing basis for this plant.
(G,/
15 The issue is --
16 DR. KRESS:
That's exactly where you would 17 probably have -- that's where you -- if you're going to do 18 any risk-based part of this whole thing, I think that's 19 where it is, the scoping issues.
20 DR. BONACA:
But to me, when I hear that they are 21 going to look at the functionality of the systems --
22 DR. KRESS:
It's basically a risk --
23 DR. BONACA:
That means that the effectiveness --
24 the license renewal process for scoping is effective.
So in 25 that case, these words would be acceptable, because we are e
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performing an' evaluation that says, yes, they're effective
()
2 or they're not effective.
3 DR. KRESS:
I think there is a real issue of what 4'
functions they include in that.
5 DR. BONACA:
Of course.
6 DR. SHACK:
I think they're constrained by legal
.7 requirements there.
8 DR. BONACA:
But it's broad enough.
We're talking 9
about 10 DR. KRESS:
How are they legally constrained
=11 there?
By Part 54, you mean?
12 DR. SHACK:
By the current licensing basis.
- Now, 13 it's a question of how you interpret the current licensing 14 basis.
)
15 DR. KRESS:
The current licensing basis is in 16 almost everything.
You could lump almost everything in 17 that.
.18 DR. SHACK:
I'm not sure that everybody would 19 agree with that.
20 DR. KRESS:
But I don't think that's much of a 1
21 limitation.
j 1
22 DR. SHACK:
I think that's a considerable 23 limitation.
24 MR. GRIMES:
Our experience on Oconee is it's a 25 limitation most of the time.
Some of the times, it's just ANN RILEY & ASSOCIATES, LTD.
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' total confusion.
Let me illustrate it by, we attempted to
()
2 explore the licensing basis for Oconee as it relates to 3-spent fuel pool cooling and we ended up with that half of 4-the loaf that. relates to the integrity of the pool boundary, 5
because the boundary is clearly relied upon in the licensing 6
basis to perform a function.
It holds the water.
7 But the cooling function is not safety-related.
8 It's not described in the licensing basis as being relied 9
upon.
There is a pool temperature limit that's not 10 characterized as a safety limit.
It's not in the tech 11 specs.
That's my fault, too.
We specifically said that 12-maintaining the spent fuel pool below 105 or 150 or 13.
whatever, that that's not a safety function.
14 So we got the boundary, we didn't get the cooling
)
15 loop, so we settled -- we were constrained to that extent, 16 that we thought it would be appropriate that the cooling 17 function be included.
But we couldn't get there.
18 Now, in hindsight, though, that seems to be a 19 sexier issue than perhaps it needed to be simply because of 20 reflections on Millstone.
But we're going to run into those 21 kinds of questions on scoping as we go through and the 22 statements of consideration for Part 54 says the Commission 23 concludes that the current licensing basis does not need to 24 be reconstituted to perform license renewal.
25 But I want to tell you, it would be a hell of a b
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'1 ;
lot. easier if it was, i
2-DR. KRESS:
That would make your life a lot 3L easier.
4-MR. GRIMES:
Yes, it would.
Otherwise, it's just 5
~ fun.
6 DR. KRESS:
It's too bad we didn't comment on that 7'
to the. Commission.
8 DR. SHACK:
I mean, there is rulemaking somewhere 9
up here ahead and that's another battle.
1 10 DR. KRESS:
You're going to change Part 54, are j
11 you?
i 12 MR. GRIMES:
I will share, personally, I've been 13 there three times now.
I was there in 1978, when the 14 Commission said that we did not need to reconstitute the
- n
(,)
15 design basis for the purpose of the impact of new regulatory 16 requirements.
That's when we moved into the generic issues 17 process'that made backfitting decisions.
18 Up until then, the rules that evolved in licensing 19 basis just sort of trailed on behind it.
Then the 20 Commission had to address it again somewhere between '81 and 21-22-DR. SHACK:
Early '80s.
23 MR.~ GRIMES:
In '81 to '84 somewhere, the 24 Commission again had an opportunity to require that the 25 design basis be reconstituted and they concluded, no, it's C\\
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just a paper exercise.
-()
2 The process manages the design-basis and then with 3
- license ~ renewal, the Commission again was confronted with 4'
the question about do you have to reconstitute the licensing 5
basis and Mr. Riccio will constantly point out that there is 6
all'this anecdotal evidence about how we don't know what the 7
-licensing basis is, and he points dramatically to the 8
Millstone.
9 So we ride that fine line a lot.
)
10 DR. KRESS:
You think there is an opportunity to 11 do.something when we risk-inform all of Part 50, you think 12 that would be --
.13 MR. GRIMES:
That was an opportunity because I 14 remember that this same issue came up when we were talking
()
15 about the PRA quality and completeness aspect and there was 16 a question about to what extent do you have a clear 17 reflection of the licensing basis, the design basis within 18 your PRA, said how do you know that you've done that.
19 It was more a reliance on the practitioners going 20 out and checking to see whether or not the systems were 21 actually contigured and operated properly than there was on 22 the underlying design basis and underlying engineering, 23 which still is characterized by many as simply the L
24 paperwork.
25 So we continue to struggle with that enigma about i
[~
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what is a good knowledge base and I think most utilities
)
2 have recognized that with the growing -- with the aging t
3 workforce, that they're losing corporate knowledge and that 4
there is an advantage to taking the design basis information 5
and pulling it up and getting it in electronic and 6
retrievable form.
7 So a lot of that is going on, but not to the 8
extent that there is a systematic approach that the NRC 9
could refer to so require an upgrading of the design basis 10 and underlying licensing basis.
11 DR. BONACA:
I've got some discomfort from some 12 things you said before, about really the licensing basis of 13 the plant.
The fact is that Oconee doesn't have main steam 14 isolation valves, it doesn't have main feedwater isolation (O) 15 valves.
Yet, those are two essential functions in certain 16 events.
17 MR. GRIMES:
For certain plants.
18 DR. BONACA:
Certain plants.
But since you rely 19 on stop valves in the plant and on governor valves on 20 feedwater systems, you want to include those, as they did, 21 and, in fact, they took some events that are not in their 22 FSAR and evaluated those.
I think the main feedwater -- was 23 it main feedwater?
l 24 MR. GRIMES:
Actually, I thought that was one of 25 the ones that we questioned them on.
f)
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DR. BONACA:
Well, but they did some, added a
()
2 couple of events.
And the question we had, as an ACRS, was 3
why not other events.
I mean, to the degree to which those 4
events define possible functionality for which you have to 5
demonstrate that you will effectively perform certain safety 6
functions, and what limits the process right now from doing 7
-- from questioning and including those components.
8 MR._ GRIMES:
And that's the legal question that we 9
run into in terms of -- we can explore any potential event 10 for which there might be an underlying safety function in 11 the licensing basis, but when we get down to a point where 12 we ask about a system capability, and the example that I 13 used was loss of spent fuel pool cooling, if the licensing 14 basis does not require that that be an analyzed capability
()
15 and otherwise have some kind of regulatory control on that 16 capability, then we can ask, but if we get into a challenge, 17 we're challenging the current licensing basis.
18 DR. KRESS:
Can't you challenge it on the basis of 19 adequate protection?
20 MR. GRIMES:
Yes, but when we do --
21 DR. KRESS:
It's not exactly the same.
22 MR. GRIMES:
We can and should challenge it on the 23 basis of adequate' protection, but then it ends up being an 24 existing license issue.
Then we go into backfit space and 25 that's what -- that's the -- from the NRC staff's O
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perspective, we say, well, that's the chilling effect.
Not
(
2 really, because whenever we challenge the 31 censing basis, 3
whether it's with respect to the scope of Part 54 of the 4
adequate protection standard, we have to rise to a level of 5-justifiable need and be able to defend it in either case.
l l
6 So that' ends up being a subtle distinction in l
7-terms of if we find something that'we think is just 8~
fundamentally wrong, the answer is we fix it.
But it ends l-9' up being something that you don't -- you don't fix it in 1
10 Part 54, you don't fix it in the renewed license.
11 MR. BARTON:
You fix it in the. current.
12' MR. GRIMES:
Right.
13 DR. BONACA:
But it makes it a struggle for you, 14 and I understand and that's okay.
()
15 MR. GRIMES:
If this were easy, then they wouldn't 16 be paying us this much money.
17 DR. BONACA:
But.we, as a subcommittee, as the 18.
ACRS, we're going to evaluate the adequacy of this process.
19 I'm trying to, again, look at what we do here as far as 20 reviewing the process and maybe --
21 DR. KRESS:
Adequacy from the standpoint of 22 protecting health and safety.
23 DR. BONACA:
So maybe I could rephrase two as that 24 and that would -- because really, I mean, we certainly want 25-to question these. kinds of issues.
They really are the l
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center of --.you may have a component out there that is very
()
2 important and you're not going to monitor it, no, I don't 3
believe that any licensee would be so irresponsible at 4
presenting their position, but if you have to negotiate that 5
kind of activity on every single item, you're going to have 6
.possibly a lot of items which are not included and they 7
should be included.
8 If you have any additional comments on this draft 9
10 MR. BARTON:
The only question I've got, Mario, is 11 you've got down here, after the pilots, we might go into a 12 two-step review.
The only question I've got there is do you 13 want to limit it to after the pilots or do you want to limit 14 it after there is an application for each different reactor
()
15 design, or doesn't it matter?
16 Because you've got the CE and B&W.
We haven't 17 seen any Westinghouse or GE at this point.
Does it make any 18 difference on reactor design here or is it strictly the 1
19 pilot versus everybody else that comes down the pike?
20 That's just a question.
21 DR. BONACA:
That's a good comme ~~.
22 MR. GRIMES:
I'd like to offer, you should be 23 careful about the use of the terms, too, because Calvert 24 Cliffs and Oconee we've typically referred to in our 25-official correspondence as the initial applicants.
We O.
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()
2 MR. BARTON:
As opposed to pilots.
3 MR. GRIMES:
Yes.
We don't have a formal pilot 4
program.
5 MR. BARTON:
That's true.
6 DR. UHRIG:
We didn't use che word pilot, did we?
7 MR. BARTON:
Yes, we do.
We used it throughout 8
this document.
We'd better fix that.
We might want to look 9
at each reactor design and after that go to reduced review 10 schedule.
11-DR. BONACA:
That's a good point.
12 MR. SIEBER:
It's based now on the issuance of a 13 final standard review plan, right?
It should be adequate, 14
-because once you do that, you fix the process.
()
15 MR. GRIMES:
The only difference would be that 16 we're hoping to finish the standard review plan and get it 17 out at about the same time that Turkey Point would be coming 18 in and.they're the first Westinghouse, 19 MR. BARTON:
The first Westinghouse unit.
That's 20 something to think about, Mario.
21 DR. BONACA:
Yes, but that's a good point.
I 22 mean, that was the thought process, John, that I had saying 23 once the SRP is in place, most of the processes are going to 24 be established, and there's going to be -- probably the main 25 comments we're going to have is when an applicant proposes O
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something different from the SRP and various issues of-()
.2 adequacy and so on and so forth.
3 But'certainly we want to look at the other 4
designs, too.
So, okay, let me think about it and I will 5
propose something there.
1 6
-MR. SIEBER:
I~ guess if you go back to page two 7
and evaluation of the effectiveness of the process, really i
-8 what you're trying to' determine is whether the process is 9 ~
effective in ensuring the goals of the protection of the 10 public health and safety, identification of all the aging 11 mechanisms, as opposed to evaluating the efficiency.
12 DR. BONACA:
No.
In fact 13 MR. SIEBER:
So if-you clean that up, then it 14 becomes a safety issue, which we should be involved in.
()
15-DR. BONACA:
We changed the title to evaluation of 16 the adequacy of the license renewal process and below that 17 we'll put the words that say that we're evaluating whether 18 the process is adequate to provide adequate protection of 19 the public.
20' MR. GRIMES:
Excuse me.
There might be some 21 language that you want to draw from the reactor arena 22 strategic plan, because there was some language that was put 23 in there that speaks to the' objective of license renewal as 24 it relates to maintaining plant safety, as distinguished 25 from the goal that speaks to effective, efficient and O
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l' realistic decision process.
1
(}
2 And if you have any suggestions for metrics for l
3 any-of those performance goals, I'd be -- I'm ready, willing 4
'and able-to take some suggestions.
I don't know whether to
~
5
-get my yardstick or my micrometer out.
l 6.
DR. BONACA:
Okay.
If you have any additional 1
7 comments next week, just bring them to us before -- even by 8
Thursday and we will put them inside this document.
- Again,
{
9-we'll call it' draft'anyway until we discuss it with the full
)
i 10 ACRS meeting.
11 DR. SHACK:
Again, that revisit to item two really I
12 turns into an item three, doesn't it?
It becomes a policy 13 issue then.
14 I understood Jack's suggestion was almost is the
()
15 current rule sufficient and that clearly is policy.
16 MR. SIEBER:
No, it's the process as by the 17 requirements of the rule. 'The Commission has issued the 18 policy statement that says this is what the rule is supposed
-19 to do'and there is a process behind that that ultimately 20 ends up as the standard review plan and the effectiveness of 21 that is it says by the requirements of the rule.
22 So it's a mechanical kind of a thing as opposed to 23 a policy type thing.
24 DR. KRESS:
I think it's too late to take that on 25 as a fourth issue.
1 i
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DR. BONACA:
Okay.
We will put in some words here 2
and then see what,you think.
3 One last item I'd like to touch on.
These are 4
just two tentative slides that'actually I hadn't seen them, 5
but Noel and I talked about the presentation to the 6
Commissioners, the fact that we'd like to keep it in two
)
7 pages.
These are not the actual slides, but these are the 1
8 thoughts.
If this seems to be on the right track, then 9
we're going to work on this and develop a couple of slides 10 that will convey these thoughts 11 DR. UHRIG:
What do you mean greatest contribution 12 will be to the process?
13
.DR. BONACA:
It means that ue expect our greatest 14 contribution will be to the process.
What that means is
()
15 that when we look at individual applications, that we're not
-16 attempting to reproduce the review of the staff.
We won't 17 even come close to their ability to contribute there.
18 I think where we can contribute the most is in the i
19 development of the process.
We had some examples, like 20 credit for existing programs.
21 What about this bullet, beneficial changes to Part 22 54?
That's like a trap for a presenter.
23 DR. KRESS:
In red letters.
24 DR. BONACA:
I don't feel comfortable with that.
25 DR. KRESS:
I think we ought to stay away from f
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that'one.
e.()
2 DR. BONACA:
Yes.
I think that's like a trap.
'3
-Anyway, we will use some of thoughts to' generate a couple of L
4 slides and then --
5 DR. KRESS:
.I hope you've got something for bullet 6
-three.
That sounds like a real winner.
7 MR. BARTON:
What was that, Tom?
8 DR. BONACA:
Denial of application.
I 9
DR. KRESS:
Bullet three, I hope he's got 10 something in mind there, because.it's a real winner.
11 DR. BONACA:
Any thoughts?
Have you had a chance
~
12 to discuss this with Sam?
r 13 MR. DUDLEY:
No, I haven't.
This was just to 14 stimulate discussion.
/'"
')
N,/
15 DR. KRESS:
I think it looks like a good outline.
16 MR. DUDLEY:
And hopefully generate comments back, 17 and it would shorten the amount of time we spent with the 18 full ~ committee'on the same issues.
19' DR. BONACA:
This, again, is another trap, because 20-the question comes can you give me an example and that's 21 tough to do, after having the whole staff review.
22 DR. KRESS:
I would be a little tempted to go easy 2/3 on bullet three on the first page, also.
I don't know if 24 I'd mark it out all together, but.
I 25 DR. BONACA:
Well, I think we need to go back and
)'
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1.
develop a couple of --
()
2 DR. KRESS:
Clearly, if we thought the staff was doing a 3
lousy job, we would say something.
But at this point in the 4
game, that's not a very likely thing to come down on.
5 Clearly, they'are doing a good job.
We can make that -- we i
6 already make that decision, so it's not much of a bullet.
l l
7 DR. BONACA:
We'll put together a couple of slides 8
and then --
9.
MR. BARTON:
Do we have an SRM or as a part of l
1 10 charter, is there something -- what gets us into this 11 process to begin with?
And do those bullets line up with --
12 DR. KRESS:
That's a good question.
13 MR. BARTON:
-- what we're supposed to be doing 14 for this process?
)
15 DR. KRESS:
Good question.
I don't know.
I think 16' the SRM just says we will review it.
17 MR. DUDLEY:
It comes out of Part 54 itself, which 18 states that the staff will provide the ACRS with the final 19 SER.
Well, they don't even say that, but with the report 20 and that any ACRS report will be included in the final 21 license package.
22 DR. KRESS:
I think that's about all it says.
-23 MR. DUDLEY:
That's about all it says.
So that's 24 j
25 MR. BARTON:
That's about all we want to say, too.
l l
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L19
]
1 We're responding to what's required in the rule.
/\\
2' MR. DUDLEY:
The question to try to answer is how V
l 3
is the ACRS going to do those two ' Lings.
1 4
MR. BARTON:
Then you have a couple sub-bullets.
5 MR. SIEBER:
And going with that, once you get 6
through the -- from the four-step process to the two-step 7
process, the contribution will not be to the process i
8 anymore.
It will be to the quality of the SER and the 9
acceptability of the licer.see's application.
10 MR. BARTON:
That's a good point, Jack.
11 MR. SIEBER:
So I'd be careful about that, too, 12 because we defined this two-step process or this two-stage 13 process.
14 DR. BONACA:
Okay.
15 MR. DUDLEY:
Is that it?
16 DR. BONACA:
Yes.
I think we are done.
We will 17 clean up the stuff and prepare a couple of overheads for 18
' review by the policy and procedure next week and then I 19 think we are done.
20 Any other comments from the members?
i 21 MR. BARTON:
Not at this time.
22 DR. BONACA:
If not, then this meeting is 23' adjourned.
24 (Whereupon, at 12:03 p.m.,
the meeting was 25 concluded.]
i
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REPORTER'S CERTIFICATE i
This is to certify that the attached proceedings v) 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 i
reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
)
A Mark Mahoney Official Reporter Ann Riley & Associates, Ltd.
O i
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
,m PLANT LICENSE RENEWAL SUBCOMMITTEE MEETING
()
SEPTEMBER 23,1999 ROCKVILLE, MARYLAND
- PROPOSED AGENDA-topic PRESENTER
))MJ 1.
Opening Remarks M. Bonaca, ACRS 8:30-8:35 a.m.
II.
Development of License Renewal Guidance NRR Staff 8:35-10:15 a.m.
A.
Resolution of credit for existing programs and Commission's Staff Requirements Memo B.
Development of NUREG on Generic Aging Lessons Learned (GALL), SRP, RG, and Industry Guidance (NEl 95-10)
C.
Format of renewal applications and SRP D.
Schedules E.
History of Plant Aging Research Program RES Staff
- BREAK -
10:15-10:30 a.m.
Ill.
License Renewal Issues - Process and Status NRC Staff 10:30-10:55 a.m.
A.
New categorization of issues B.
Plans for resoMng issues C.
Schedules IV.
Staff Activities NRC Staff 10:55-11:30 a.m.
A.
Calvert Cliffs and Oconee reviews B.
Review of Topical Reports C.
Announced future applications V.
Discussion of ACRS Review Strategy M. Bonaca, ACRS 11:30-12:00 noon A.
Applications B.
Priority 1,2, and 3 License Renewal Issues C.
Policy issues D.
Changes to License Renewal Regulations E.
Scheduling future Subcommittee meetings VI. Adjournment M. Bonaca, ACRS 12:00 noon
.O3 V
i i
I
l INTRODUCTORY STATEMENT BY THE CHAIRMAN OF THE f'
PLANT LICENSE RENEWAL SUBCOMMITTEE 11545 ROCKVILLE PlKE, ROOM T-2B3 ROCKVILLE, MARYLAND SEPTEMBER 23,1999 i
The meeting will now come to order. This is a meeting of the ACRS Subcommittee on Plant License Renewal. I am Mr. Mario Bonaca, Chairman of the Subcommittee.
ACRS Members in attendance are: John Barton, Thomas Kress, William Shack, amk Robert Uhrig.
TEk' frJ"E4 SJCo q The purpose of this meeting is for the Subcommittee to hear presentations from the staff conceming development of licc~e renewal guidance, resolution of license renewal issues, standardizing the format for license renewal applications, the status of the staff's review of the Calvert Cliffs and Oconee applications, and associated activities. The Subcommittee will gather information, analyze relevant issues and facts, and formulate proposed positions and Q.
actions, as appropriate, for deliberation by the full Committee. Mr. Noel Dudley is the Cognizant ACRS Staff Engineer for this meeting.
The rules for participation in today's meeting have been announced as part of the notice of this meeting previously published in the Federa/ Registeron September 3,1999.
A transcript of this meeting is being kept, and will be made available as stated in the Federal Register Notice. It is requested that speakers first identify themselves and speak with sufficient clarity and volume so that they can be readily heard.
We havs ;<:alved no written comments or requests for time to make oral statements from members of the public.
This Subcommittee met on April 28-29 and June 30-July 1,1999, and heard presentations on the Calvert Cliffs and Oconee license renewal applications. On the basis of these O_
me iin9s and associated 4CRS Committee meetings, the ACRS issued interim letters on
L the staff's safety evaluation reports related to the license renewal applications.
[v The Subcommittee plans to use the information presented today to develop a strategy for more efficiently reviewing staff safety evaluation reports and to establish a schedule for reviewing selected issues. I request that the staff, during its presentations, provide suggestions as to when an ACRS review of specific issues will add the greatest value to the license renewal process.
We will now proceed with the meeting and I call upon Mr. Christopher Grimes, Chief of the License Renewal and Standardization Branch to begin.
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